1. Who We Are
Pluto is a controller of your Personal Data and is responsible for handling it in accordance with Data Protection Law.
Pluto will also establish separate legal entities for some of our housing developments who will process your Personal Data when you enquire about, or enter into a contract for sale for, a house at that development.
Pluto has appointed a Data Protection Lead (“DPL”) to oversee our data protection policy and legal compliance. For any questions you have in relation to how Pluto handles your personal data, please contact our DPL at email@example.com.
2. Legal Basis for Processing your Personal Data
Under Data Protection Law, whenever we process your Personal Data, we rely on one or more legal basis to do so.
3. How we collect Personal Data
We may collect Personal Data from you in the following ways:
- when you make an enquiry, register your interest on our website or mobile device apps;
- when you contact us in person, by telephone, email, post, SMS or another channel;
- when reserving a property to purchase from us;
- when you enquire about or purchase other products or services (including any options and extras) from us;
- during the process of purchasing a property from us and/or selling a property to us scheme;
- if you take part in our competitions, promotions or customer surveys; and/or
- when making payment and/or transacting with us.
We may collect your Personal Data from certain third parties including:
- Companies that introduce you to us
- Homes England and Help To Buy
- Banks and building societies
- Lenders and other finance providers
- Social networks, comparison websites and property portals, e.g. Facebook, Twitter, Instagram, Rightmove, Zoopla etc.
- Credit reference agencies and identity check providers
- Trade contractors, suppliers of materials and equipment
- Fraud prevention agencies
- Land or estate agents
- Our agents and third party service providers such as IT systems providers, market researchers or website analysts
- Solicitors and surveyors
- Financial advisors and other professional advisors
- Mortgage providers
- The National House Building Council (‘NHBC’)
- Other house building warranty providers, such as Building LifePlans Ltd (BLP)
- Public information sources such as Companies House
- Third parties authorised by you, for example members of your family
- Government and law enforcement agencies.
Our website uses ‘cookies’. For detailed information about our cookies policy please visit https://www.plutoim.com/cookie-policy.
5. What Personal Data we collect
The type of Personal Data we may collect includes, but is not limited to:
- Contact Details: Name, address, telephone number (mobile and landline), e-mail address
- Particular housing developments, locations and properties that you’re interested in
- Your status such as: First time buyer, house on the market, and/or sale status of your current property
- Financial details such as: Your financial position or status, budget, history and mortgage eligibility/applications, tax status; bank account or payment card details
- Information you provide when using purchase schemes and incentives of interest
- Marketing preferences including preferred contact methods and property types, locations, developments, products and services you may be interested in knowing about
- Socio-demographic details: This includes details about your work or profession, nationality, education and where you fit into general social or income groupings
- Contractual details about the products or services we provide to you
- Locational data we get about where you are, such as may come from your internet browser, mobile phone or the address where you connect a computer to the internet and visit our websites or use our services
- Behavioural details about how you use our products and services when you visit our websites or use our services
- Technical details on the devices and technology you use when you visit our websites or use our services
- Information about you in letters, emails, conversations, voicemails, calls and other communication between us
- Social relationships: What we learn about your family, friends and other relationships recorded in communications between you and us that helps us better target our marketing and services; and
- Information about your personal circumstances and interests that also helps us better target our marketing and services.
When you reserve a property we may require further information about you including, but not limited to:
- Documents and information verifying your identity and/or residence such as passport, utilities bills, national identity card, national insurance number, driving licence or birth certificate
- Mortgage provider and mortgage status
- Advisors appointed by you including lawyers, financial advisors, surveyors
- Financial information
- Property records, searches, documents and files relating to the sale to you, and where you take part in a part exchange, files relating to the property you are selling to us
- Information about your property preferences
If you apply for a shared equity loan or Help To Buy loan, we may also collect and keep the Personal Data provided in your loan application, Reservation Agreement, loan agreement and Personal Data obtained from third parties, such as credit reference and fraud prevention agencies, to underwrite and manage your loan.
6. How we use your Personal Data
We may use the Personal Data about you as follows:
- To ensure that content from our website is displayed in the most effective way for the purposes of ensuring the security and protection of our systems and our information
- To carry out marketing and send information about Pluto or its other Entities’ products and services that may interest you or which are similar to those you have purchased or made enquiries about in the past. If you express interest in a Pluto Homes development we may contact you to let you know about other Pluto Entities and developments.
- There are laws which control electronic marketing and, if required, we will seek your consent to carry out electronic marketing. Where we rely on your consent to process your Personal Data, you can withdraw this at any time, by unsubscribing, through our website or contacting our DPL Lead.
- To process and manage the sale and/or purchase of properties
- To notify utility suppliers and local authorities about your purchase and/or sale of a property
- To notify you about changes to our services and products
- To carry out analysis to make improvements to our website, products and/or services
- To measure or understand the effectiveness of advertising we deliver
- To perform preparatory steps to enter into, perform and manage any contracts entered between you and us – for example your property purchase and/or options and extras from us or (if applicable) our purchase of your current property using our Part Exchange scheme
- To deal with and manage any defects or issues that arise in relation to our products and services, including any property you purchase from us
- To provide the warranties (such as NHBC and BLP warranties) which cover a property purchased from us and manage any claims on those warranties
- To assist you in applying for any government schemes which you have indicated you may wish to make use of
- To monitor customer satisfaction (both on our own behalf and/or for the NHBC) including processing customer satisfaction surveys
- To keep our records up to date
- To develop, manage and test our products and services, what we charge for them and who might use them
- To manage and facilitate working with other companies that provide services to us and our customers and, where appropriate, to make referrals
- To manage customer payments and debts
- To comply with laws and regulations that apply to us
- To carry out identity and money laundering checks and generally prevent, detect, investigate or report financial crime
- To manage risk for us and our customers
- To respond to and deal with any enquiries, complaints or claims and to manage our relationship with you
- For the purposes of us being able to obtain legal and other professional advice
- To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit
7. Sharing your Personal Data
Companies within the Pluto Group may share their technical or operational processes, procedures and systems, which means Personal Data may be accessible across Pluto Group Entities.
We may occasionally transfer your Personal Data outside the European Economic Area (‘EEA’) or United Kingdom to follow your instructions; comply with a legal duty; or in certain other situations, provided that we will adopt adequate safeguards to apply the same standards to protect your Personal Data that you would expect in accordance with Data Protection Law.
Where your Personal Data is accessed by third party providers who supply services to us and who process that data on our behalf, for example, IT vendors or data hosting suppliers, we will require them, under a written contract, to act only in accordance with our instructions and take appropriate security measures.
Within the purposes set out above we may share your Personal Data with the following third parties:
- In respect of any property you reserve from us, the sale of the property and/or the purchase of your existing property with our Part Exchange scheme, with estate and managing agents, financial and legal advisors and any relevant mortgage provider, the NHBC or any other relevant property guarantee and warranty provider, utility providers and local authorities.
- Third parties who provide services direct to you, for example if you ask us to put you in contact with solicitors and other professional advisors, estate agents, financial advisors or mortgage eligibility checkers.
- Third parties working on our behalf to help us provide you with additional services and improve our services and products such as focus groups conducting interviews to request feedback from you following development visits
- Sub-contractors where they need your Personal Data to arrange and carry out work to your property
- Third parties where authorised by you, for example mortgage brokers, mortgage eligibility checkers, financial advisors, legal advisors or your family
- Insurance providers where relevant to the insurance of the property you purchase and/or the property we purchase from you
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our contracts with you; or to protect our rights, property, or our safety and/or the safety of others.
- We may share your Personal Data with managing agents, management companies, landlords, or the Land Registry relating to the completion of your property transaction.
- Credit reference agencies, identity check providers, lawyers and other advisers for fraud prevention and anti-money laundering purposes.
- Police, law enforcement and security services but only where necessary to detect, prevent and prosecute crime or protect national security and where we are legally permitted to do so.
- In the event that we sell any of our business or assets, in which case we may disclose your Personal Data to the prospective buyer of such business or assets. If our assets are acquired by a third party, Personal Data held by us may be one of the transferred assets.
- Government bodies, where it is relevant to do as part of any property transactions we enter into with you, e.g. HMRC.
8. How we use your information to make automated decisions
We sometimes take automated decisions based on Personal Data we have. This helps us to make sure our decisions are quick, fair and efficient, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them. The key types of automated decision that Pluto makes are as follows:
- Tailoring products and services: We may place you in groups with similar customers. We do this to better understand our customers’ needs and to make decisions based on that understanding. This helps us to design products and services for different customer types and better manage customer relations.
- Profiling: We may use Personal Data to create a profile of recipients for direct marketing.
9. Protecting your information
We will seek to keep your Personal Data secure by taking appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage. If logging on to our website it is your responsibility to protect your log in details. You must treat these as confidential and must not share or disclose your log in details to any other party.
The duration for which we retain your Personal Data will differ, depending on the type of information, the reason why we collected it and what it may be needed for. Personal Data will be retained in accordance with criteria based on need and regulatory guidance. Key retention periods are:
- Records relating to your property purchase are held for a period of 15 years after completion of your purchase to deal with warranty claims and defect issues;
- Information relating to prospective customers is retained for a period of 6 years after our last contact with you in case there are any claims;
- Legal property information and legal files will be retained for approximately 12 years after completion for any property title claims;
- Information regarding fixtures and fittings will be retained for approximately 6 years after completion for claims related to breach of contract;
- Audio recordings will generally be retained for approximately 3 months and then overwritten or deleted, unless required by us, for example because of a dispute, or because the recording is needed as part of our training and quality programme;
- If for any reason your property transaction with us does not complete, then we would retain your records for approximately 6 years for claims related to breach of contract.
It is important to ensure that the Personal Data we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You may be able to update some of the personal information we hold about you by contacting your usual point of contact at Pluto or our DPL.
11. Enquiries and Exercising your Rights
You have certain legal rights under Data Protection Law. Further information on these can be found at: https://ico.org.uk/global/privacy-notice/your-data-protection-rights/