top of page

Privacy Policy

1. Introduction


At Pluto Invest Ltd ("we," "us," or "our"), we place great importance on safeguarding and respecting your privacy and personal data. This privacy policy outlines the manner in which we collect, process, and secure your data. It also provides information about your privacy rights concerning this data. Personal data refers to data or combinations of data that can reasonably be used to identify you. This privacy policy is applicable to the personal data we collect or process pertaining to our users who utilise our services through our application and website. It is important to note that we may be legally obliged to collect specific personal data about you, or it may be required as a result of any contractual relationship we have with you. Failure to provide this information may impede or delay the fulfilment of these obligations.

2. Data do we collect

The categories of personal data that we collect about you are:  

  • Identity data: this is data relating to your name or email which you can optionally provide when using our services.

  • Usage data: this is data we collect from you in connection with your usage of the application.

3. Legality
As required by applicable law, we must have a legitimate legal basis to process your personal data. In most cases the legal basis will be one of the following: 

  • “Consent”: we may obtain your consent to collect and use certain types of personal data when we are required to do so by law, for example, in relation to our direct marketing activities, including by email. If we ask for your consent to process your personal data, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy.   

  • “Contractual obligations”: we may require certain information from you in order to fulfil our contractual obligations and provide you with our services. 

  • “Legal compliance”: we’re required by law to collect and process certain types of data, such as to detect, prevent and respond to fraudulent activity or other illegal actions, or to comply with our legal obligations such as responding to legally binding requests from regulators, law enforcement authorities or other government authorities.

  • “Legitimate interest”: we might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. This could include understanding how you use our services to enable us to derive knowledge that enables us to develop the services. When we process personal data to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

    4. How we use your personal data

    1. Our uses

in general, we process your personal data for the following purposes:

  • To operate and provide you with our services and ensure they function, such as lessons learned and polls. 

  • To improve our services by gathering aggregated data to enable research or analysis so that we can better understand and serve you.

  • To prevent and detect fraud and other malicious use of our services and to protect your security.

  • To comply with legal and regulatory obligations to which we are subject and cooperate with regulators and law enforcement bodies

Set out below is a table containing the different types of personal data we collect and the lawful basis for processing that data.

  1. Activity: when a user begins using the mobile app.

  2. Type of data: optional identity data - name and email address.

  3. Lawful basis for processing data: 

    1. Consent: the user consents to provide their identity data.​

  1. Activity: whilst the user is operating the mobile application their behaviour is being recorded in the form of anonymised usage data.

  2. Type of data: anonymised usage data.

  3. Lawful basis for processing data: ​

    1. Legitimate interests for the product to function correctly, we require this data to assess application functionality and analytics.


  1. Your rights and how you are protected by us

you have certain rights regarding your personal data, subject to local law. these include but may not be limited to the following rights depending on your location and jurisdiction:

  • Access your personal data

  • Rectify the data we hold about you

  • Erase your personal data

  • Restrict our use of your personal data 

  • Object to our use of your personal data 

  • Receive your personal data in a usable electronic format and transmit it to a third party (right to data portability)

  • Lodge a complaint with your local data protection authority


If you would like to discuss or exercise such rights, please contact us at the details below.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your personal data (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. 


We are committed to keeping your data secure and protecting it from inappropriate disclosure. Any personal data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. However, no transmission of data over the internet is guaranteed to be completely secure. it may be possible for third parties not under the control of Pluto Invest Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us at the contact below.

  1. Your data and third parties

We may share personal data with third parties under the following circumstances:


We may share your personal data with our service providers, subcontractors and business partners/affiliates, for example where they facilitate us in providing our services (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions), but only after ensuring that their privacy policy aligns with ours stated here. The mobile application contains no third party software development kits (SDKs) so there is no situation where user data would be shared with them.

We may also share personal data with interested parties in the event that Pluto Invest ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology. If Pluto Invest Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your personal data to a third party as part of or in connection with the sale transaction. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal data uses it in a manner that is consistent with this privacy policy.

We may share your personal data at any time if required for a legal reason, including to comply with legal or regulatory obligations, or to protect our rights or the rights of any third party, or otherwise in order to enforce our terms or this privacy policy.

  1. Third-party links

This site/application may include links to third-party websites, plug-ins and applications. clicking on those links or enabling those connections may allow third parties to collect or share data about you in line with their respective terms and policies. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit. Any such links are are not financial advice or guidance and you should do your own research before clicking on them. In the event the link belongs to a real money investment firm, your capital may be at risk if you decide to use their services.


  1. How long will we retain your data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Once our relationship with you has come to an end, we will retain your personal data for a period that enables us to:

  • Maintain business records for analysis and/or audit purposes

  • Deal with any complaints 

  • Defend or bring existing or potential legal claims in respect of our relationship with you

  • Comply with record retention requirements under the law

  • Enforce our commercial agreements


  1. Age limit for our users

You must not use the application unless you are aged 16 or older. If you are under 16 and you access the application by lying about your age, you must immediately stop using Pluto Invest Ltd.

The website and app is not intended for children and we do not knowingly collect data relating to minors.


  1. Contact us 

Pluto Invest Ltd is the controller responsible for the personal data collected and processed. If you have any inquiries or concerns about the way in which your data has been used, please contact us either by email at

You have the right to make a complaint at any time to your local data protection authority, which in the UK is the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns or complaints before you approach the ICO, and would be grateful if you could contact us in the first instance.

  1. Notification of changes and acceptance of policy

We keep our privacy policy under review and will place any updates on this page. This version is dated 1st June 2023.


Contact us

if you have any questions about these terms, please contact us at

bottom of page