Data Processing Terms

When you use Plutoo Comet as a customer, you (the agency, landlord or property manager) are typically the controller of personal data about landlords, tenants, applicants and staff that you upload or generate in the product. Plutoo acts as your processor for that data.

1. Subject matter and duration

We process personal data to provide the Comet platform (portfolio, tenancies, compliance, rent, communications and related features) for the term of your subscription and any wind-down period agreed in writing.

2. Nature and purpose of processing

• Hosting and storing customer data in the application
• Enabling authorised users to view, edit and export records
• Sending transactional messages you trigger (for example emails or broadcasts you compose)
• Support, security monitoring, backups and service improvement (in aggregated or access-controlled form)

3. Types of data and data subjects

May include names, contact details, property addresses, tenancy and payment information, compliance certificates, enquiry notes, and other content you choose to store. Data subjects may include landlords, tenants, applicants, contractors and your staff.

4. Our obligations as processor

• Process data only on your documented instructions (including configuration and use of the product)
• Ensure persons authorised to process data are bound by confidentiality
• Implement appropriate technical and organisational security measures
• Assist with data subject requests, DPIAs and breach notifications where reasonably required
• Delete or return personal data at the end of the service, subject to legal retention needs
• Make available information needed to demonstrate compliance, including audits as agreed in writing

5. Sub-processors

We use infrastructure and service providers (for example cloud hosting, email delivery and authentication) to run Comet. A current list is available on request at [email protected]. We will give reasonable notice of material changes where contractually required.

6. International transfers

Where sub-processors process data outside the UK, we use appropriate transfer mechanisms (such as the UK International Data Transfer Agreement or equivalent safeguards).

7. Your responsibilities

You are responsible for the lawfulness of data you upload, providing notices to data subjects, configuring access correctly, and ensuring you have a valid basis to process landlord/tenant and related data.

8. Full agreement

These terms summarise our approach. Binding processing terms form part of your customer agreement or a signed DPA. For a formal DPA, contact [email protected].

Related: Privacy Policy · Security