Skip to main content

Privacy Policy

Last Updated: October 27, 2025

1. Introduction​

Welcome to Pluto Systems Inc. ("Pluto," "we," "us," "our"). This Privacy Policy describes how we collect, use, and disclose your personal information when you use our software platform, including the Client Portal, Customer Connect, and the Pluto Signing Service (collectively, the "Services").

This policy is designed to be transparent and to help you understand your rights. By using our Services, you agree to the collection and use of information in accordance with this policy and applicable privacy laws.

2. Our Role as a Service Provider​

It is crucial to understand our role. Pluto Systems provides the Services on behalf of our clients, who are typically real estate developers, builders, or their agents (our "Clients").

  • Data Controller vs. Data Processor: In the context of a real estate transaction, our Client is the "Data Controller." They determine the purposes and means of processing the personal information required for your transaction. Pluto Systems acts as a "Data Processor" on their behalf, processing your information according to their instructions and our service agreement with them.
  • Scope of this Policy: This policy explains how Pluto, as a company, handles your data to provide our Services. The use of your data within a specific real estate transaction is governed by the privacy policy of the respective Client (the developer). For questions about a specific transaction, please contact your developer directly.

3. Information We Collect and Why​

We collect only the information necessary to provide and secure our Services. Below is an explanation of the main types of personal information we collect and how we use it. Privacy laws may otherwise permit us to collect, use and disclose personal information for other reasons, including with your consent or as needed to prevent fraud and to protect users, our Clients and our organization.

A. Information You Provide to Us:​

  • Account and Contact Information: This includes your name, email address, and phone number.
    • Purpose: To create and manage your user profile, to communicate with you about the Services, and to send security verification codes for authentication.
  • Identity Verification Information: This may include images of your government-issued identification.
    • Purpose: To facilitate identity verification on behalf of our Client. We use a trusted third-party service to securely manage this process. Pluto Systems does not store the raw images of your ID on our primary servers once the verification is complete.
  • Transaction Information: This includes documents, contracts, and other information you access or sign through the Services.
    • Purpose: To facilitate the real estate transaction between you and our Client and to provide an auditable record of all actions taken within the Services.

B. Information We Collect Automatically:​

  • Technical and Usage Data: This includes your IP address, device type, browser information, and interactions with our Services.
    • Purpose: To monitor the performance and security of our Services, to prevent fraud, to improve the user experience, and to troubleshoot technical issues. We use third-party performance monitoring services for internal monitoring and analytics.

4. How We Share Your Information​

We do not sell your personal information. We only share your information with the following categories of service providers ("sub-processors") who help us operate our Services:

  • Our Clients: We share your information with the specific developer with whom you are transacting, as necessary to facilitate your real estate transaction.
  • Cloud Hosting Providers: We use reputable cloud hosting services to host our platform and your data.
  • Communication Service Providers: We use third-party communication services to send security verification codes and other notifications to you via email and SMS.
  • Identity Verification Service Providers: We use trusted third-party identity verification services to securely process and verify your government-issued identification on behalf of our Client.
  • Performance Monitoring Service Providers: We use third-party performance monitoring services to help us analyze and improve the technical performance of our Services.

We have agreements with all our service providers that require them to maintain the confidentiality and security of your information.

5. Data Storage and International Transfers​

Your personal information is stored on secure servers located within Canada. We have specifically chosen our hosting providers for their Canadian data centers to ensure your data remains within the country.

Our third-party service providers may process data in other countries. We have verified that they have robust privacy and security standards in place to protect your information, regardless of where it is processed, and that they follow privacy practices comparable to those required by Pluto and required by applicable privacy laws. A list of our primary hosting and service providers and their data storage locations are as follows:

  • DigitalOcean: hosts our files, databases, and web servers in Canada.
  • Yoti: provides identity verification services and stores related data in Canada.
  • Stripe: facilitates payment processing services and stores related payment data in accordance with their global infrastructure.

6. Data Security​

We take the security of your information very seriously and use a combination of technical, administrative, and physical controls to protect it. Our security measures include:

  • Encryption: We use industry-standard SSL/TLS encryption for all data in transit between you and our Services.
  • Access Controls: We strictly limit access to your personal information to authorized Pluto Systems employees who have a legitimate business need.
  • Data Separation: Each of our Clients has a logically separated database to ensure that data from different developers is never commingled.
  • Secure Authentication: We use a secure authentication system, including one-time verification codes and industry-standard token logic, to protect your account.

While we take all reasonable measures to protect your data, no method of transmission or storage is 100% secure.

7. Data Retention​

  • Personal Information: We retain your personal information on behalf of our Client for the duration of our service agreement with them, and for any period required to assist them in meeting their legal record-keeping obligations. At the conclusion of our agreement with a Client, we may be required to delete your data. We may retain copies as needed to meet our legal and business requirements, including backup and archival purposes. You are responsible for downloading and retaining your own copies of any documents you need for your records.
  • Anonymized Data: We may retain anonymized and aggregated data indefinitely, as it cannot be used to identify you.

8. Use of Anonymized and Aggregated Data​

We reserve the right to process your information to create anonymized and aggregated data sets. This data has been stripped of all personally identifying information. Pluto Systems owns this anonymized data and may use it for any lawful business purpose, such as for creating analytics, improving our Services, or for commercial purposes like producing and selling market-trend reports.

9. Marketing Communications​

We may use your personal information to inform you about current or new products, services, or other updates that we believe may be of interest to you, in accordance with Canada’s Anti-Spam Legislation. You may opt out of receiving marketing communications at any time by contacting us at the email address below.

10. Your Privacy Rights​

You have rights regarding your personal information. The process for exercising these rights depends on the nature of your request.

  • Access and Correction:
    • To access or correct information related to your real estate transaction (e.g., details in a sales contract), please contact the developer (the Data Controller) directly.
    • To correct your Pluto account information (e.g., your email address or phone number), you may do so through the Services or by contacting us.
  • Withdrawing Consent: You can withdraw your consent to use our Services at any time by notifying us. Please be aware that this will terminate your access to the platform and you will need to proceed with your transaction using paper documents with the developer.

To exercise your rights with Pluto, please submit a written request to info@plutosystems.net. We will acknowledge your request, verify your identity, and respond within 30 days. If your request pertains to data controlled by our Client, we will forward the request to them to handle.

11. Cookies and Tracking Technologies​

We use cookies and similar technologies for different purposes depending on whether you are using our secure Services or our public website.

  • Within the Services (Client Portal, etc.): We use only essential cookies required for the security and functionality of the platform. These are used to manage your session, maintain your security, and remember your preferences within the application. We do not use advertising or marketing cookies within our secure Services.
  • On our Public Website (plutosystems.net): Our public website is built on WordPress and may use cookies for analytics, performance, and marketing purposes to help us understand visitor traffic and improve our site.

12. Embedded Content and Links to Other Sites​

  • The Services may contain links to other websites or include embedded content (e.g., videos, maps, articles) that is not operated by us. If you click on a third-party link or interact with embedded content, you will be directed to that third party's site.
  • We strongly advise you to review the Privacy Policy of every site you visit. Embedded content from other websites behaves in the exact same way as if you have visited the other website, and these websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to This Privacy Policy​

We may update this Privacy Policy from time to time. We encourage you to review this policy periodically.

14. Contact Us​

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

Pluto Systems Inc.

Attn: Privacy Inquiries

scott.kemperman@plutosystems.net (Scott Kemperman, CEO)