Privacy Notice

Pluto Communications Ltd trading as Pluto of Frankfort House, Vergemount Hall, Clonskeagh, Dublin 6 whose registered number is 432810 is is committed to protecting and respecting your privacy. We provide creative services, event management services, digital marketing, and shopper marketing services.

This Privacy Notice (the “Notice”) together with any disclaimers sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Notice relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity. This Privacy Notice is provided to you, in line with the following Personal Data Protection Legislation:

The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 also known as the General Data Protection Regulation (GDPR), which became enforceable across the EU and the EEA from May 25th, 2018 having replaced the previous Directive 95/46/EC; In Ireland, the national law, which amongst other things, gives further effect to the GDPR, is the Data Protection Act 2018 (‘the 2018 Act’).

The Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 also known as the ePrivacy Directive, amending the Directive 2002/22/EC on universal service and users’ rights relating to electronic communications networks and services, Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EC) No 2006/2004 on cooperation between national authorities responsible for the enforcement of consumer protection laws;

This Notice sets out the basis on which any personal data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Laws:

• Pluto is the data controller when we act as an employer, as a service provider, and where dealing with suppliers.

• Pluto is a data processor when we provide our clients with event management support services.

If you have any questions in relation to this Privacy Notice, or wish to exercise your rights relating to it, please contact our Privacy Lead at anna@pluto.ie

Personal Data we collect from you

We collect Data from you which you volunteer when you provide such Data to us, or via our services with which you interact. We may also be given other Data relating to you by other persons, or we may obtain such other Data about you as may be provided to us in the course of our legitimate business activities.

We may collect and process Data, including the following in the course of providing services to you, which could contain your personal data including your special category data:

Your full name; your address; your various email addresses; your various phone numbers including mobile phone number; your gender, age, and nationality, your occupational information, your family and relationships information and your personal preferences, dietary information, and objectives and all other Data which you ask us to process on your behalf or which is necessary for us to process in order for us to fulfill our role as providing a service to you.

We may also process other data, which is not personal data.

When you access our website your device’s browser provides us with information such as your IP address, browser type, access time, and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer, and to offer services to you.

What personal data about you do we obtain from others?

When you use our services, we may obtain personal data from others: including your authorised representatives, if you are an employee of one or our clients, we may obtain your personal data from your employer and we may process your personal data on behalf of your employer in the context of our supply of our services.

If you provide us with personal information about someone else, (for example one of your employees) you are responsible for ensuring that you comply with any and all obligations and particularly any consent obligations under the Data Protection Laws in relation to such disclosure. In so far as required by the Data Protection Laws, you must ensure that you have a lawful basis to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

Security and where we store your Data

We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available.

The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your Data for their own purposes. Non-EEA countries may not provide an adequate level of protection in relation to processing your personal data. By submitting your data, you agree to this transfer, storing and processing.

Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to us. Any transmission of data is at your own risk. Once we receive your Data, we use appropriate security measures to seek to prevent unauthorised access.

Uses made of your Data

We use your Data that we hold to:

carry out our obligations arising from any contracts entered into between you and us.
to provide our services to you
comply with legislation; and/or
notify you about changes to our services. In our legitimate interest of advertising our services, provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes (our list of services below).

The legal bases for the processing of your personal data are:

Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract.
That you have provided consent for the processing for one of more specified purposes such as marketing for example when you fill out consent to receiving marketing material and or consent for photographs to be taken and used
Processing necessary for compliance with a legal obligation to which we are subject.
Processing necessary for the purposes of the legitimate interest which we pursue in providing you with quotes and proposals about our services prior to contract where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information.

The legal bases for the processing of your special category data or sensitive data (for example health data) are:

• That you have explicitly provided consent.

• Processing necessary for compliance with a legal obligation to which we are subject.

• Where we are acting as a processor for your employer who will have a separate legal basis for the processing of your personal data.

List of services and Retention

Our services include creative services, event management services, digital marketing, and shopper marketing services.

We may use your data to send you information relating to our services, events and products which may be of interest to you. If you do not want us to use your Data in this way, please notify us to that effect. You can contact us as set out at the end of this Notice.

We keep your Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Data to provide this service to you, you can request that we erase your Data and close your account with us. Please note that if you request the erasure of your Data:

We may retain some of your Data as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety
We may retain and use your Data to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.
Because we maintain our records to protect from accidental or malicious loss and destruction, residual copies of your Data may not be removed from our backup systems for a limited period of time.

Miscellaneous

Where we process your Data based only on your consent, you may withdraw your consent.

You have the right to bring a complaint to a supervisory authority if you have any complaints about the processing of your Data. In Ireland, the Data Protection Commission is the supervisory authority.

In circumstances where the provision of your Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we will advise you at the point of collecting your Data whether the Data is a required field, and the consequences of not providing the Data.

Links to other sites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any data to those websites.

Social networks

We maintain active social network accounts. We embed widgets from these networks to provide follow buttons, like boxes and stream embeds. This will result in cookies being set by these networks while using our site. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent.

Who Do we share this information with?

We may share your personal data with providers of our services. For example, our web hosting provider and our IT service providers.

In addition, we may disclose your personal information to third parties If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

We may share your information with selected third parties including:

Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you.
Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii)you ask us to share your information.
Statutory and regulatory bodies (including central and local government) and law enforcement authorities in order to comply with any applicable laws, grant applications and / or court orders
Service providers who provide us with marketing including, Wi Fi services, website and online platforms, and subcontractors who provide a service to us, and sub processors.

We attach at Schedule 1 a list of all entities with whom your personal data is shared.

Do we transfer your Data outside the European Union or European Economic Area?

We will, from time to time, make use of services provided by third parties for the delivery of our services which may necessitate the transfer of personal data outside the EU/EEA. For example, we use a variety of cloud-based tools such as Microsoft Office 365. Where data needs to be transferred or processed outside the EU/EEA, we chose providers who process data on the basis of:

SCC
An Adequacy Decision from the European Commission.

Your rights

As an individual, under EU law you have certain rights to apply to us to provide information or make amendments to how we process your Data. These rights apply in certain circumstances and are set out below: -

The right to access data relating to you (‘access right’).
The right to rectify/correct data relating to you (‘right to rectification’).
The right to object to processing of data relating to you (‘right to object’).
The right to restrict the processing of data relating to you (‘right to restriction’).
The right to erase/delete data relating to you (i.e., the “right to erasure”)and
The right to ‘port’ certain data relating to you from one organisation to another (‘right to data portability’).

These rights are not absolute and only apply in certain circumstances. You may exercise any of the above rights by sending an e-mail to anna@pluto.ie

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie

Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

If you are receiving marketing from us, you may opt out. If you no longer wish to be contacted for marketing purposes, please contact us at anna@pluto.ie and request to “opt out" of marketing

The exercise of Data Subjects’ rights as some other “interactions” requires the univocal identification of the person submitting such request as being, in fact, the Data Subject to whom such Personal Data pertains to, hence we may have to set in place a process or mechanism that allows it to document having undergone such assertive identification.

Changes to this Notice

We reserve the right to change this Notice from time to time in our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree

Contact Us

Questions, comments, requests and complaints regarding this Notice and your Data we hold are welcome and should be addressed to our Privacy Lead anna@pluto.ie

All requests will be dealt with promptly and efficiently.

This Notice is effective from July 19th, 2022

Schedule 1

We have set out below a list of third parties with whom we share your data.

Third party name

Description of services provided

IT Providers | IT Monkey

Travel Agents | PK Travel ltd

Cloud Service Providers | Microsoft

Web hosting | Spiral Hosting

Phones | Vodafone and Three Ireland

CRM tool | HubSpot

Email Service Providers | Microsoft

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