Privacy Policy

Introduction

Planet Holding Ltd (hereinafter referred to as “Planet”, “we”, “us” and “our”) respects your privacy and is committed to protecting your personal data. Our Privacy Policy (hereinafter referred to as “Policy”) is designed to communicate our practices regarding the collection, use, retention and disclosure of information, and to inform you of your privacy rights and how the law protects you.

The General Data Protection Regulation (EU) 2016/679 (“GDPR”) is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. The Data Protection Act 2018 (“DPA 2018”) came into effect on 25th May 2018 and sets out the framework for data protection law in the UK, replacing the Data Protection Act 1998. It sits alongside the GDPR, and tailors how the GDPR applies in the UK – for example, by providing exemptions. It also sets out separate data protection rules for law enforcement authorities, extends data protection to some other areas such as national security and defense, and sets out the Information Commissioner’s functions and powers. Brazil has its own data protection law, the Lei Geral de Proteção de Dados Pessoais – LGPD, law number 13.709, dated 14th August 2018 (“LGPD”), which creates the legal framework for the use of personal data of individuals in Brazil regardless of where the data processor is located, as further detailed in section 10 of this Policy.

1. Who we are and the purpose of this policy

Planet is a proptech company which has created a free application that enables residents to interact with everything smart available in their neighbourhood. Currently compatible with iOS and Android, the Planet App allows users to access our services (hereinafter referred to as “Services”). The app and all Planet’s websites are not intended for children under 13 years old and we do not knowingly collect data relating to children under the age of 13.

It is important that you read this Policy together with any other policies we may provide on specific occasions when we are collecting and processing personal data about you. This will ensure that you are fully aware of how and why we are using your data. This Policy supplements other policies and is not intended to override them.

Contact details

Planet’s contact details are:

Planet Holding Ltd
2nd Floor 22 Eastcheap
London, England
EC3M 1EU
+44 203 9825216

We have appointed an external Data Protection Officer (DPO) who is responsible for handling questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our external Data Protection Officer (DPO) whose contact details are:

Robert Healey
Relentless Privacy and Compliance Ltd
Colmore House, Queensway,
Birmingham, United Kingdom
B4 6AT
+44 203 9825216
dpo@planetsmartcity.com

Should you wish to do so at any point, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Their contact details are:

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow
Cheshire, SK9 5AF
0303 123 1113 (local rate)
01625 545 745 (national rate)
Fax: 01625 524 510
casework@ico.org.uk

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Controller – GDPR and DPA 2018

Planet acts as the data controller and is responsible for your personal data under GDPR and DPA 2018.

Third party links

Our websites and the Planet App may include links to third party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data, which includes but is not limited to first name, last name, username, title, date of birth and image.
  • Contact Data, which includes residential address, email address and telephone numbers.
  • Technical Data, commonly known as online identifiers, which includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI), type of device, your login data, browser type and version, time zone setting and geolocation, browser plugin types and versions, operating system and platform, and other technology on the devices you use to access this website and the Planet App.
  • Profile Data, which includes your login details, orders made by you, your interests, preferences and feedback.
  • Usage Data, which includes information about how you use our website, the Planet App and our Services.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties, news about our products and your communication preferences.
  • Internet of Things (IoT) Data, which includes but is not limited to smart meter measurements, air quality measurements, occupancy sensors and home automation devices.

We also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law since it does not directly or indirectly reveal your identity. For example, we may aggregate your Planet App Usage Data to calculate the percentage of users accessing a specific feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We use mobile analytics software to allow us to better understand the functionality of the Planet App on your device. This software may record information such as how often you engage with the app, the events that occur within the app, aggregated usage, performance data, and where the app has been downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the Planet App.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you – for example, to provide you with Services. In this case, we may have to cancel the Planet account or Service you have with us – but we will notify you at the time if this is the case.

3. How your personal data is collected

We use different methods to collect data from and about you. This includes but it is not limited to:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Create an account with Planet.
    • Subscribe to our Service, app or publications.
    • Request marketing communications to be sent to you.
    • Request support for the Planet App or related Services.
    • Provide a review or feedback.
  • Automated technologies or interactions. As you interact with the Planet App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, as set out below.
    • Technical Data from the following parties:
      1. Analytics providers such as Google, based inside and outside the EU.
      2. Advertising networks such as Facebook, based inside and outside the EU.
      3. Search information providers such as Google, based inside and outside the EU.
    • Contact, and Transaction Data from providers of technical delivery services based inside and outside the EU.
    • Identity and Contact Data from data brokers or aggregators based inside and outside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register, based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. We will most commonly use it in the following circumstances:

  • For the performance of a contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

Some data is required in order to provide our Services and such data is collected or received in different ways. In many cases, you decide which data to provide.

The below table sets out all of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Also note that some types of Planet Services, accounts and features are not available everywhere and some examples may not apply where you live.

 

Purpose / activity Type of data Lawful basis for processing including basis of legitimate interests
Downloading the Planet App. (a) Technical. In order to take steps prior to entering into a contract with you.
Registering as a Planet user. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
For the performance of a contract in which you are a part of.
When you decide to invite new users to join the Planet App, you can choose to share their email addresses or their contacts with us, so we can send them an invitation and reminder on your behalf. In such a case, you must ensure that the potential new user has agreed to share their contact details. (a) Identity.
(b) Contact.
For the performance of a contract in which you are a part of.
For our legitimate interests (to develop our Services and grow our business).
If you want to join the Planet App, but we do not yet have the Service for your area, you can choose to provide us with your contact information and ask us to notify you when it becomes available. (a) Identity.
(b) Contact.
In order to take steps prior to entering into a contract with you.
If you use your Facebook account to access Planet (or subsequently connect your Facebook account to your Planet account), you authorise Facebook to share your personal information with us, including your name and email address. (a) Identity.
(b) Contact.
In order to take steps prior to entering into a contract with you.
Communications that enable us to manage our relationship with you, such as:
(a) Notifying you about changes to our terms or this Policy.
(b) Asking you to leave a review or take a survey
(a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
For the performance of a contract to which you are a part of.

To comply with a legal obligation.

For our legitimate interests (to keep our records updated and to study how users interact with our Services).

To enable you to partake in a competition or complete a survey. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
(g) IoT.
In order to take steps prior to entering into a contract with you.
To administer and protect our business, including but not limited to troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data for the Planet App and this website. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
(g) IoT.
Performance of contract.

For our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

To comply with a legal obligation.

For our legitimate interests to detect or prevent unlawful acts.

To deliver relevant content and advertisements to you, either via this website or the Planet App, and measure or understand the effectiveness of the advertising we serve to you. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
(g) IoT.
For our legitimate interests (to study how users use our Services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, the Planet App, our Services, marketing, customer relationships and experiences. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
For our legitimate interests (to better understand the types of users that use our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or Services that may be of interest to you. (a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
(f) Marketing and communications.
For our legitimate interests (to develop our Services and grow our business).
To process your job application to work with us. (a) Identity.
(b) Contact.
In our legitimate interests to attract and recruit talent.
To facilitate a duty of care to you when you participate in our Services, which include but are not limited to:

  • Consumption reporting
  • Chats (Planet App links to external chats by WhatsApp and Facebook).
  • Community management.
  • Home automation.
  • Security services.
  • Smart locks.
  • SOS requests.
  • Gamification.
(a) Identity.
(b) Contact.
(c) Technical.
(d) Profile.
(e) Usage.
For our legitimate interest (to help you manage aspects of your activities when interacting with our Services).

Marketing

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

  • Promotional offers from us. We may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have subscribed for an account with us or purchased Services and you have not opted out of receiving that marketing. All of our marketing communications to you contain an opt out option.
  • Opting out of geolocation. If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings for the Planet App.
  • Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your consent to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of your personal data

We may share your personal data with specific third party marketing partners listed here.

We may seek to acquire other businesses or merge with them. If a change happens to our business, your data will still only be disclosed for the purposes identified in this Policy and for which you have provided implicit or explicit consent, unless a law or regulation specifically allows or requires otherwise.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. All our third party processing partners are vetted under our third party due diligence process and have signed data processor contracts with us.

6. International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by making sure that at least one of the following safeguards is implemented:

  • The countries that your personal data is being transferred to has been deemed to provide an adequate level of protection by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we include third party Standard Contractual Clauses together with encryption technology to ensure the data is protected.

7. Data security

We have put appropriate security measures in place to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, disclosed or becoming unavailable. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to be aligned to the Principle of Least Privilege (PoLP). They will only process your personal data in accordance with our instructions, and they are subject to a duty of confidentiality.

We periodically review all privacy and security policies and update them when necessary, in line with changes of the GDPR, DPA 2018 and LGPD, as applicable, or when any new technologies are introduced into our business. Where the introduction of new technologies results in a high risk to your data, we will perform a data protection impact assessment and will only proceed if it meets the required security standards.

Methods of collecting personal information are reviewed by management before they are implemented to confirm that personal information is obtained (a) fairly, without intimidation or deception, and (b) lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of personal information.

We have a procedure in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How long we retain and use your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. A copy of our Data Retention Schedule is available upon request.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (including, but not limited to Contact and Identity Data) for six tax years, plus the current tax year, as part of our legal obligations to do so.

In some circumstances, you can ask us to delete your data: see “Request erasure of your personal data” in section 9 for further information.

In other circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research, statistical or other commercial purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights in relation to your personal data under data protection laws. Brief descriptions of such rights are outlined below.

  • To be informed: individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR, DPA 2018 and LGPD. This Policy and our Cookie Policy meet this requirement.
  • To request access to your personal data (commonly known as a “data subject access request”): this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • To request rectification of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • To request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
  • You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified of, if applicable, at the time of your request.
  • To object to the processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object as you feel it impacts on your fundamental
    rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which could
    override your rights and freedoms.
  • To request restriction of processing your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • To request the transfer of your personal data to you or to a third party: we will provide your personal data in a structured, commonly used, machine-readable format to you or a third party you have chosen. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to enter into a contract with you.
  • To withdraw consent at any time where we are relying on consent to process your personal data: note that this will not affect the lawfulness of any processing carried out before your consent is withdrawn. If you withdraw your consent, we may not be
    able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee is usually needed

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will inform you of an extension period of up to two months, as stated in the GDPR and DPA 2018. In this case, we will keep you informed on progress.

10. LGPD – Brazil

Data of Brazil data subjects collected by the Planet App and this website in Brazil is processed within the European Union. All Planet users of Brazilian citizenship are protected in full by the GDPR and the DPA 2018. When the LGPD comes into force, we will update this section, as applicable, to comply with its requirements.

11. Glossary

Lawful basis

Legitimate Interest is our interest in conducting and managing our business to enable us to give you the best and most secure Services and experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can contact us to obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.

Performance of Contract refers to the processing of your data where it is necessary for the performance of a contract you are a part of, or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Explicit consent for external marketing means your personal data will not be disclosed to any third party unless you have given your explicit consent to such disclosure.

12. Policy updates

Policies and procedures are reviewed and compared to the requirements of applicable laws and regulations at least once a year. Whenever changes to such laws and regulations are made, privacy policies and procedures are revised to conform with the requirements of the applicable laws and regulations.

This version of the Policy is dated as of the value of Status, below.

Document information

Approval authority
General Counsel

Responsible officer
Head of Data & Insights

Designated officer
Head of Data & Insights

First approved
16/09/2020

Last amended
16/09/2020

Review date
16/08/2020

Status
v2.0.0 (published 21/09/2020)

Related documents
Data Protection Policy

Linked documents
Information on Cookies
List of Third Party Marketing Providers

Related legislation / standards
General Data Protection Regulation (EU)
2016/679 (“GDPR”)
Data Protection Act 2018 (“DPA 2018”)
Lei Geral de Proteção de Dados Pessoais
Law No. 13.709 (“LGPD”)