Privacy Policy

This Privacy Policy describes how Pluto Tech LLC (“Pluto,” “we,” “our,” or “us”) collects, uses, stores, and protects information in connection with your use of the Pluto mobile application, website, software, and related services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you must discontinue use of the Services.

1. Self-Custodial Nature of the Services

Pluto is a self-custodial interface that does not access, store, or control your private keys, seed phrases, or digital assets. We cannot recover wallets or initiate transactions on your behalf.

All blockchain activity conducted through the Services occurs on decentralized networks and may be publicly visible. Pluto does not control or process on-chain transactions.

2. Information We Collect

We collect limited information necessary to operate and improve the Services.

a. Information You Provide

• Email address (if you choose to create an account or subscribe to updates)

We do not collect:

• Government-issued identification
• Financial account or payment details
• Private keys or seed phrases
• KYC or identity verification data

b. Information Collected Automatically

When you use the Services, we may collect:

• IP address
• Device type and operating system
• App version
• Crash reports and diagnostics
• Usage data and interaction events

This information is used only for security, performance, debugging, and aggregate analytics.

c. Blockchain Data

Blockchain networks are public. Wallet addresses, transactions, and balances associated with your activity may be publicly accessible and are not controlled by Pluto.

Connecting a wallet does not grant Pluto access to your private keys or assets.

3. Legal Basis for Processing

We process personal data in accordance with the General Data Protection Regulation under the following legal bases:

• Contractual necessity – to provide and operate the Services
• Legitimate interests – to maintain security, prevent fraud, and improve the Services
• Consent – where applicable (e.g., marketing communications)

4. How We Use Information

We use collected information to:

• Operate, maintain, and improve the Services
• Communicate with you regarding updates or support
• Monitor performance and diagnose issues
• Detect and prevent fraud, abuse, or security risks
• Comply with legal obligations and enforce our Terms

We do not sell, rent, or trade your personal data.

5. Third-Party Services

We use third-party service providers to support the Services, including:

• Infrastructure and hosting providers
• Analytics and diagnostics tools
• Blockchain infrastructure providers (e.g., RPC services)
• Market data providers

These providers may process limited technical data (such as IP address or device information) on our behalf.

Examples may include services from companies such as Cloudflare, Google, and Sentry.

These third parties operate under their own privacy policies.

6. Data Sharing and Disclosure

We may disclose information:

• To comply with legal obligations (e.g., court orders or regulatory requests)
• To protect the rights, safety, and security of Pluto, our users, or the public
• In connection with a merger, acquisition, or corporate restructuring

7. International Data Transfers

Your information may be processed outside your country of residence, including outside the European Economic Area.

Where required, we rely on appropriate safeguards such as Standard Contractual Clauses to ensure your data is protected.

8. Data Retention

We retain personal data only for as long as necessary to:

• Provide the Services
• Fulfill legal and regulatory obligations
• Resolve disputes and enforce agreements

Technical logs and analytics data may be retained for a limited period for security and performance purposes.

9. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Request a copy of your data (data portability)
• Withdraw consent where processing is based on consent
• Lodge a complaint with a data protection authority

To exercise your rights, contact us at the details below.

10. Security

We implement reasonable administrative, technical, and organizational measures to protect information under our control.

However, no system is completely secure. You acknowledge that any transmission of information is at your own risk.

Because Pluto does not store private keys or digital assets, we cannot recover funds or reverse transactions.

11. Minors

The Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that such data has been collected, we will delete it.

12. Cookies and Tracking

We may use limited analytics or similar technologies to understand how users interact with the Services.

Where required by law, we will obtain your consent before using such technologies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be made available within the Services and will include a revised “Last Updated” date.

Your continued use of the Services constitutes acceptance of any updates.

14. Contact

For questions or support inquiries, you may contact: support@pluto.meme