Privacy Policy (Pluto LMS LTD)

Privacy Policy

This Privacy Policy is effective as of: 7th June 2023 ("Effective Date")


1 Definitions and interpretation

1.1 In this Policy, the following definitions are used:

Cookiesa small text file placed on your computer by this Service when you visit certain parts of the Service and/or when you use certain features of the Service. Details of the cookies used by this Service are set out in the clause below ‚ÄúCookies‚ÄĚ and the Cookie Schedule;
Data Protection Lawsany applicable law relating to the processing of Personal Data, including but not limited to the Directive 96/46/EC (Personal Data Protection Directive), the Privacy Directive 2009/136/EC and the GDPR;
GDPRthe General Personal Data Protection Regulation (EU) 2016/679;
Personal Datacollectively all personal information that you submit to Pluto via the Service. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
PlatformOur proprietary web domain and all associated domains.
Pluto, we or usPluto LMS LTD, a company incorporated in England with company number 13494661, having its registered office at 71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ;
ServiceAs defined in the Terms of Service
User or youany third-party that accesses the Service and is not either (i) employed by Pluto and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Pluto and accessing the Service in connection with the provision of such services. This includes visitors to our Platform, our clients and employees and representatives of our clients where applicable.


1.2 In this Policy, unless the context requires a different interpretation:

1.2.1 the singular includes the plural and vice versa;
1.2.2 references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Policy;
1.2.3 a reference to a person includes firms, companies, government entities, trusts and partnerships;
1.2.4 “including” is understood to mean “including without limitation”;
1.2.5 reference to any statutory provision includes any modification or amendment of it;
1.2.6 the headings and sub-headings do not form part of this Policy.

2.  Scope of this Policy

2.1 This Policy applies only to the actions of Pluto and Users with respect to this Service. It does not extend to any websites of services that can be accessed from our Platform or any links we may provide to social media websites.

2.2 Throughout the Platform, we may link to other websites owned and operated by certain trusted third parties to make additional services and services available to you, or provide external services. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.


3.  Personal Data collected

3.1 We may collect the following Personal Data, which includes personal data, from you:

3.1.1 name;

3.1.2 role with your company;

3.1.3 e-mail address;

3.1.4 IP address (automatically collected);

3.1.5 web browser type and version (automatically collected);

3.1.6 operating system (automatically collected);

3.1.7 a list of URLs starting with a referring site, your activity on this Service, and the site you exit to (automatically collected); and

3.1.8 information about your interactions with the Platform and the Service (automatically collected);

in each case, in accordance with this Policy.


4.  How we collect Personal Data

4.1 We collect Personal Data in the following ways:

4.1.1 Personal Data is given to us by you; and

4.1.2 Personal Data is collected automatically.

4.2 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.

4.3 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


5.  Personal Data that is given to us by you

5.1 Pluto will collect your Personal Data in a number of ways, for example:

5.1.1 when you contact us via the Service, by e-mail or through any other means;

5.1.2 when you register with us and set up an account to receive the Service;

5.1.3 when you complete surveys that we use for research purposes (although you are not obliged to respond to them);

5.1.4 when you enter a competition or promotion through a social media channel;

5.1.5 when you elect to receive marketing communications from us;

5.1.6 when you use the Service;

in each case, in accordance with this Policy.


6.  Personal Data that is collected automatically

6.1 To the extent that you access the Service, we will collect your Personal Data automatically, for example:

6.1.1 we automatically collect some information about your use of the Service. This information helps us to make improvements to content and navigation and includes your IP address, the date, times and frequency with which you access the Service and the way you use and interact with its content.

6.1.2 we will collect your Personal Data automatically using tracking technologies. For more information about these tracking technologies, and how we use them on the Service, see the section below, headed “Cookies” and our Cookie Schedule.


7.  Our use of Personal Data

7.1 Any or all of the above Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Platform and Service. Specifically, Personal Data may be used by us for the following reasons:

7.1.1 internal record keeping;

7.1.2 improvement of our Service;

7.1.3 transmission by email of marketing materials that may be of interest to you;

7.1.4 contact for market research purposes which may be done using email. Such information may be used to customise or update the Service;

in each case, in accordance with this Policy.

7.2¬†We may use your Personal Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

7.3 For the delivery of direct marketing to you via e-mail, depending on your location, we may need your consent, whether via an opt-in or soft-opt-in:

7.3.1¬†soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out;

7.3.2 for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we will provide;

7.3.3¬†if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

7.4 When you register with us to use our Service, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may use your Personal Data to show you adverts and promotions from appropriate service providers as well as other content on other websites. If you do not want us to use your Personal Data to show you adverts and promotions from appropriate service providers as well as content on other websites, please turn off the relevant cookies as detailed in our Cookie Schedule.


8.  Who we share Personal Data with

8.1 We may share your Personal Data with the following groups of people for the following reasons:

8.1.1 our employees, agents and/or professional advisors in order to obtain advice;

8.1.2 our payment processing and billing partners in order to process payments and issue refunds; and

8.1.3 third-party service providers who process personal data to provide analytics which help us ensure the Service runs smoothly and optimise and customise the Service for you;

in each case, in accordance with this Policy.


9.  Keeping Personal Data secure

9.1 We will use technical and organisational measures to safeguard your Personal Data, for example:

9.1.1 access to your account is controlled by a password and a user name that is unique to you;

9.1.2 we store your Personal Data on secure servers; and

9.1.3 payment details are encrypted using by our payment processing partners and are not processed by us at any time.

9.2¬†Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us at [email protected].


10.  Personal Data retention

10.1 Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period necessary to fulfil the purposes outlined in this Policy or until you request that the Personal Data be deleted.

10.2 However, please note that even if we delete your Personal Data, it may persist on backup or archival media for legal, tax or regulatory purposes or we may retain anonymised records of your historical use of the Service for analytics purposes.


11.   Your rights 

11.1 You have the following rights in relation to your Personal Data:

11.1.1¬†Right of access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

11.1.2 Right of correction Рthe right to have your Personal Data rectified if it is inaccurate or incomplete.

11.1.3 Right to erase Рthe right to request that we delete or remove your Personal Data from our systems.

11.1.4¬†Right to restrict our use of your Personal Data – the right to “block” us from using your Personal Data or limit the way in which we can use it.

11.1.5 Right to data portability Рthe right to request that we move, copy or transfer your Personal Data.

11.1.6 Right to object Рthe right to object to our use of your Personal Data including where we use it for our legitimate interests.

11.2 To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact us. We will endeavour to respond to your request as soon as is practicable or within a reasonable timeframe.

11.3 If you are not satisfied with the way a complaint you make in relation to your Personal Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.

11.4 It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during the period for which we hold it.


12.  Transfers to third countries (EEA residents)

12.1 This clause only applies to residents of the EEA or countries that follow the GDPR regime.

12.2 Personal Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA) which have not been deemed safe third countries by the European Commission. For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

12.3 We will only transfer Personal Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example by way of Standard Contractual Clauses adopted by the European with the official version of the United Kingdom addendum as issued by the Information Commissioner. 

12.4 To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third-parties we share your Personal Data with. This ensures your Personal Data is treated by those third parties in a way that is consistent with the Data Protection Laws.


13.  Changes of business ownership and control

13.1 Pluto may, from time to time, expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of Pluto. Personal Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Personal Data for the purposes for which it was originally supplied to us.

13.2 We may also disclose Personal Data to a prospective purchaser of our business or any part of it.

13.3 In the above instances, we will take steps with the aim of ensuring your privacy is protected.


14.   Cookies 

14.1 This Platform may place and access certain Cookies on your computer. Pluto uses Cookies to improve your experience of using the Service and to improve our range of services. Pluto has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

14.2 All Cookies used by the Platform are used in accordance with the Data Protection Laws.

14.3 Before the Platform places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Pluto to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Platform may not function fully or as intended.

You can find a list of Cookies that we use in the Cookie Schedule.


15.  Changes to this Policy

Pluto reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Platform and you are deemed to have accepted the terms of the Policy on your first use of the Platform following the alterations.


Cookie Schedule

What Are Cookies?

Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent using our Service, pages visited, language preferences, and other web traffic data. We, and our service providers, use the information for security purposes, to facilitate online navigation, to display information more effectively, to personalise your experience while using the Service, and to otherwise analyse user activity. We can recognise your computer to assist your use of the Service. We also gather statistical information about the usage of the Service in order to continually improve their design and functionality, understand how the Service is used, and assist us with resolving questions regarding the Service. Cookies further allow us to select which of our offers are most likely to appeal to you and to display them to you. We may also use cookies to see how you interact with our offers, and we may use cookies or other files to understand your use of our Website.

How does Pluto use Cookies?

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this Website. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

How to disable Cookies

If you do not want information collected through the use of cookies when using your Pluto account or our Website, you will be given the choice to accept cookies when you first visit the Website. In addition, there is a simple procedure in most browsers that allows you to automatically decline cookies or gives you the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to However, if you do not accept these cookies, you may experience some inconvenience in your use of the Service. For example, we may not be able to recognise your computer, and you may need to log in every time you use the Website or Platform.

The Cookies We Set

Account related Cookies

If you register an account on the Platform we will use cookies to manage the signup process and general administration. These cookies will be deleted when you log out.

Login related cookies

To prevent you from having to log in every single time you visit the Platform, we use cookies to remember your login state. Those cookies are deleted when you log out to ensure that other users of your machine cannot access your private data.

Cookie details

Session cookies: These are used to maintain a so-called ‚Äėsession state‚Äô and only lasts for the duration of your use of the Website. A session cookie expires when you close your browser, or if you have not visited the server for a certain period of time. Session cookies are required for the Platform to function optimally, but are not used in any way to identify you personally.

Double Click Cookies: Third party vendors with whom we contract may use cookies to serve a user ads based on a user’s prior visits to the Website. Users may, however, opt out of receiving these ads by visiting

Permanent cookies: These cookies permanently store a unique code on your computer or smart device hard drive in order to identify you as an individual user. No Personal Information is stored in permanent cookies. You can view permanent cookies by looking in the cookies directory of your browser installation. These permanent cookies are not required for the Pluto LMS website to work, but may enhance your browsing experience.

More Information

If you are still looking for more information, you can contact us at [email protected]