Privacy Policy and Data Processing Disclosure

THIS PRIVACY POLICY CONSTITUTES A LEGALLY BINDING DISCLOSURE REGARDING THE COLLECTION, ELECTRONIC INDEXING, PROCESSING, RETENTION, AND ADMINISTRATIVE DISCLOSURE OF PERSONAL AND TELEMETRIC DATA BY PLUTO STUDIOS. BY ACCESSING OR UTILIZING PLUTO STUDIOS AUTOMATION OR PARTICIPATING IN THE PLUTO STUDIOS DISCORD SERVER, YOU ACKNOWLEDGE AND CONSENT TO ALL DATA PRACTICES SET FORTH HEREIN.

Effective Date: November 14, 2026

Last Updated: November 14, 2026

Data Controller and Operating Entity: Pluto Studios ("Operator," "we," "us," or "our")

Designated Application: Pluto Studios Automation (the "Application")

Designated Web Portal: https://pluto.smithw11.com

Designated Discord Community: Pluto Studios Server (the "Server")

1. Contractual Scope and Binding Acknowledgment

This Privacy Policy governs the systematic acquisition, storage, processing, auditing, and disclosure of information collected by Pluto Studios in connection with your interaction with Pluto Studios Automation, your membership or participation within the Pluto Studios Discord server, and your access to our web portal hosted at https://pluto.smithw11.com (collectively referred to herein as the "Services").

This Privacy Policy is incorporated by reference into, and must be construed alongside, the Terms of Service Agreement. By inviting, authorizing, or interacting with the Application, remaining present within the Server, or navigating the Web Portal, you unconditionally acknowledge that you have read, comprehended, and consented to the data collection and retention practices described throughout this instrument. If you object to any provision of this Privacy Policy, you must immediately cease all utilization of the Services and remove yourself from the Server.

2. Enumeration of Collected Data Categories

To execute community governance, automated moderation enforcement, administrative auditing, support ticketing, and infrastructure security, Pluto Studios systematically accesses, records, and retains the following distinct categories of electronic information:

2.1 Public Discord Profile and Server Participation Metadata

The Application automatically queries, ingests, and processes all account information made publicly accessible within the Discord Server environment via the Discord Application Programming Interface (API). Without limitation, this includes:

• Your unique numerical Discord User Snowflake Identifier, primary account username, global display name, and server-specific display nickname;
• Your public avatar asset hash and URL, profile banner hash, and publicly visible Discord account badges;
• Your assigned Server roles, hierarchical permission integers, and exact Server join date and UTC timestamp; and
• Your underlying Discord account creation date and UTC timestamp.

2.2 Server Subscription and Nitro Boost Telemetry

The Application continuously monitors, synchronizes, and records your Discord Nitro Server Boost status in relation to the Pluto Studios Server, encompassing:

• Affirmative or negative confirmation of whether your account is actively boosting the Server;
• The exact UTC date and timestamp upon which your Server boost commenced, renewed, or terminated; and
• Automated role assignments, administrative flags, or subscription-tier entitlements triggered by your active boost status.

2.3 Persistent Historical Moderation and Disciplinary Records

Pluto Studios maintains an immutable, persistent administrative database logging all historical and active disciplinary actions, sanctions, and staff interventions associated with your Discord User Identifier within the Server. This dataset includes:

• All formal and informal warnings, verbal cautions, communication timeouts, channel mutes, server kicks, soft-bans, and permanent bans;
• The specific infraction reasons, evidentiary notes, attached links, duration parameters, and exact UTC timestamps appended to each moderation event; and
• The Discord User Identifier and username of the administrative staff member or automated moderation module that initiated the disciplinary sanction.

2.4 Comprehensive Support Ticket Transcripts

Whenever you initiate, participate in, respond within, or are referenced inside any administrative, moderation, appeal, or general support ticket managed by Pluto Studios Automation, the Application records, compiles, and archives complete, verbatim Ticket Transcripts, comprising:

• Every textual message, command invocation, attachment, image URL, file upload, and rich embed transmitted within the designated ticket channel;
• The Discord User Identifiers of all participating users and staff members, exact UTC timestamps for each individual message, and ticket lifecycle state transitions (including creation, staff claim, escalation, closure, and archival); and
• Internal administrative annotations, resolution summaries, or evidentiary remarks attached to the ticket record.

2.5 Granular Command Execution and Interaction Audit Logs

Every instance in which you invoke, trigger, or interact with a slash command, prefix command, interactive button, selection menu, or modal dialog operated by Pluto Studios Automation generates a detailed audit record containing:

• Identity Parameters (Who): Your unique Discord User Identifier, username, and server nickname at the moment of execution;
• Action Parameters (What): The exact command name, subcommand group, subcommand identifier, and all raw user-supplied arguments, text strings, or target parameters submitted;
• Temporal Parameters (When): The precise UTC date and timestamp of the interaction execution; and
• Contextual Parameters (Where): The Server (Guild) Identifier, Channel Identifier, Channel Name, and unique Interaction or Message Snowflake Identifier in which the command occurred.

2.6 Web Portal Network and Edge Security Telemetry

When you establish an HTTP/HTTPS connection to https://pluto.smithw11.com, our edge network and hosting infrastructure provider, Cloudflare, Inc., automatically processes standard transport-layer and security metadata—including your originating Internet Protocol (IP) address, browser user-agent string, referring URL, Autonomous System Number (ASN), and request timestamps—strictly for Distributed Denial of Service (DDoS) mitigation, automated bot filtering, SSL/TLS encryption, and content delivery.

3. Lawful Bases and Operational Purposes for Processing

Pluto Studios processes the enumerated categories of data strictly pursuant to recognized lawful bases under applicable data protection statutes (including the UK General Data Protection Regulation and the Data Protection Act 2018), specifically:

1. Performance of Contractual Terms: Executing Application commands, provisioning Server boost entitlements, delivering support ticket functionality, and fulfilling obligations established under our Terms of Service Agreement;
2. Legitimate Operational and Security Interests: Enforcing community rules, preventing ban evasion through persistent moderation histories, auditing staff and user conduct via command logs and ticket transcripts, resolving user disputes, and protecting Pluto Studios infrastructure against technical abuse, spam, and exploitation; and
3. Compliance with Legal Obligations and Defense of Claims: Satisfying statutory mandates, adhering to the Discord Developer Policy, and preserving evidentiary records necessary to establish, exercise, or defend Pluto Studios against civil, criminal, or administrative claims.

4. User Liability for Submitted Content and Sensitive Disclosures

You acknowledge and agree that all messages, file attachments, command inputs, and ticket submissions transmitted through the Services are provided entirely at your own risk and personal legal responsibility. You are strictly prohibited from transmitting sensitive personal data—including government-issued identification numbers, financial account numbers, payment card details, passwords, authentication tokens, or private medical records—within Discord channels, command arguments, or support tickets.

Pluto Studios exercises no prior screening over user-submitted ticket contents or command parameters and expressly disclaims all legal and financial liability arising from any exposure, retention, or unauthorized access resulting from sensitive or confidential information voluntarily disclosed by you within the Services.

5. Data Disclosure, Sub-Processors, and Third-Party Transfers

Pluto Studios does not sell, rent, lease, license, or commercially monetize your personal data to advertisers, marketing agencies, or third-party data brokers. Information collected through the Services is disclosed or transmitted exclusively under the following strictly controlled circumstances:

• Authorized Administrative Personnel: Moderation histories, ticket transcripts, boost statuses, and command audit logs are accessible to vetted administrators and moderators of the Pluto Studios Server solely for legitimate community governance, rule enforcement, and support resolution;
• Essential Infrastructure Sub-Processors: Data is processed through core technical infrastructure providers necessary to operate the Services, including Discord Inc. (governed by the Discord Privacy Policy), Cloudflare, Inc. (governed by the Cloudflare Privacy Policy), and encrypted cloud database and server hosting providers utilized by Pluto Studios; and
• Compulsory Legal and Law Enforcement Disclosures: Pluto Studios reserves the unrestricted right to preserve, inspect, and disclose any stored records—including verbatim ticket transcripts, command execution logs, and moderation histories—to law enforcement agencies, courts of competent jurisdiction, or regulatory authorities when required by subpoena, court order, or statutory mandate, or when reasonably necessary to investigate unlawful conduct, prevent imminent harm, or defend the legal rights and property of Pluto Studios.

6. Data Retention Schedules

Pluto Studios retains collected information in accordance with operational necessity and legal preservation requirements:

1. Moderation Histories and Ticket Transcripts: Retained persistently for as long as necessary to enforce active bans and disciplinary restrictions, maintain accurate historical community security records, resolve administrative appeals, and preserve evidentiary audit trails for potential legal defense;
2. Command Execution Audit Logs: Retained for security monitoring, abuse investigation, and system diagnostics, and periodically purged or anonymized in accordance with internal database maintenance schedules; and
3. Public Profile and Boost Status Metadata: Synchronized dynamically via Discord gateway events and retained only while your account remains affiliated with the Server or as permanently embedded within historical moderation or ticket records.

7. Data Subject Rights and Statutory Exemptions

Subject to statutory conditions and jurisdictional applicability under the UK GDPR and EU GDPR, you may submit a formal request to access a copy of personal data directly associated with your Discord User Identifier, request rectification of demonstrably inaccurate factual data, or request erasure of non-essential personal records.

Mandatory Exemption for Moderation, Security, and Evidentiary Records: Pursuant to applicable statutory exemptions—including Article 17(3)(e) and Article 23 of the UK GDPR—Pluto Studios expressly reserves the legal right to deny, restrict, or defer requests for the erasure or alteration of historical moderation records, active ban logs, security audit trails, command abuse logs, and relevant support ticket transcripts where continued retention is strictly necessary for the establishment, exercise, or defense of legal claims, the prevention of ban evasion, or the protection of the rights and safety of the Server community.

All data subject requests must be submitted in writing to the contact address specified in Section 10 and are subject to strict identity verification procedures prior to fulfillment. Verified requests will be processed within thirty (30) calendar days.

8. Security Safeguards and Disclaimer of Liability

Pluto Studios implements reasonable administrative, organizational, and technical security measures—including Transport Layer Security (TLS/HTTPS) encryption, restricted access control lists, credential isolation, and permission-scoped API tokens—designed to protect stored data against unauthorized access, alteration, or disclosure.

Notwithstanding these measures, no electronic transmission over the Internet or digital storage architecture can be guaranteed to be completely impervious to intrusion. To the maximum extent permitted by governing law, Pluto Studios, its founders, developers, and administrators disclaim all liability for any unauthorized access, data breach, interception, or loss of data occurring beyond our reasonable control, as governed by the comprehensive limitation of liability clauses within our Terms of Service Agreement.

9. Children's Privacy and Minimum Age Compliance

The Services are strictly prohibited to individuals under the age of thirteen (13) years, or such higher minimum age of digital consent established by the laws of your jurisdiction. Pluto Studios does not knowingly solicit, collect, or retain personal data from underage children. Upon receipt of verified notice that an underage individual has accessed the Services without valid statutory consent, Pluto Studios will immediately terminate access and purge non-essential records associated with the account.

10. Policy Amendments and Formal Contact Procedures

Pluto Studios reserves the unilateral right to modify, revise, or replace this Privacy Policy at any time at its sole discretion. Any amendments shall take immediate legal effect upon publication at https://pluto.smithw11.com/privacy, accompanied by an updated "Last Updated" date. Your continued interaction with the Services following the publication of revisions constitutes binding acknowledgment of the updated Privacy Policy.

All formal privacy inquiries, statutory data subject requests, and legal notices must be directed in writing to Pluto Studios via:

• Electronic Mail: legal@pluto.smithw11.com
• Discord Administration: @smithw11 via official support ticketing channels within the Pluto Studios Server