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Privacy Policy

PRIVACY & SECURITY

Your privacy and security online are very important to us, so we have written this policy to explain how we use the information we collect about you; how you can instruct us if you wish to limit the use of that information; our gathering techniques; and the procedures we have in place to safeguard your privacy.

This is the privacy policy (the “Policy”) for all websites owned and made available by Pomegranate Communications, Inc, including, without limitation, the website currently located at www.pomegranate.com (the “Site”). Please carefully review this Policy to learn about how we collect, use, and protect any Personal Information (defined below) and Non-Personal Information (defined below) you provide us on or through the Site and your choices for managing your Personal Information. By using the Site, you signify your assent to this Policy.

1. INFORMATION COLLECTED AND USED

Information You Voluntarily Provide Us
We collect information that personally identifies you (“Personal Information”) only if you choose to share such information with us. For example, you may be required to provide us with certain Personal Information to register with the Site, make a purchase, sign up for services available through the Site, subscribe to a newsletter, enter sweepstakes, contests, or other promotions, and at other times. The decision to provide this information is optional; however, if you elect not to register or provide such information, you may not be able to access certain content or features or participate in certain areas of the Site.
 
The following are examples of Personal Information we may collect from you:
  • Personal Information such as your name, mailing address, your email address, phone number, credit card information (including billing information), or other information that allows us to personally identify or contact you online or offline.
  • Demographic Information, which may include the following types of information about you: age or date of birth, income, highest level of education, gender, categories of products purchased, products owned or of interest, and other non-personal or survey-type information including attitudes, interests, and skills. In some instances, demographic information may be combined and stored together with your personal information.
  • Login Information such as username and password, private answers to security questions or other similar information that allows us to identify your account or authenticate you prior to giving you access to your account information.
Information Passively or Automatically Collected
We automatically collect information that does not reflect or reference an individually identifiable user (“Non-Personal Information”) to help us understand how our users use the Site. Like most websites, we automatically collect and use the following data contained in log files:
  • Technical Information, which may include certain information or characteristics about your computer, such as the type of browser and operating system you use, and your computer’s Internet Protocol (IP) address. For the most part, technical information remains anonymous (that is, it does not identify you personally), but in some cases, it can be traced back to personal information such as an email address.
  • Usage Information, which may include non-personal information about how you use or browse Pomegranate or related websites (“Website Usage” data) and what products you buy (“Order History”).
Cookies and Other Web Technologies
Like many other websites, we may use a variety of standard technologies to: (i) enhance and personalize your experience on Pomegranate (including saving you the time of having to repeatedly re-enter information); (ii) generate statistics and information about traffic to and on Pomegranate and related websites; and, (iii) run and measure the effectiveness of certain advertising or promotional campaigns, including those run by network advertisers on our behalf. These tools may include the following:
  • Cookies: these are small text files that we may store on your computer to remember certain things about your visit to www.pomegranate.com. For example, cookies might be used to remember the content you previously viewed, your order history, items you placed in a wish list or shopping cart, or the nickname or device profile name you created when registering on www.pomegranate.com or a related website. We do not use cookies to collect personal information. However, we may use cookies to remember or store certain personal information so we can save you the time of having to re-enter this information, or, together with using other cookie information, re-market to you products in which you have previously shown interest. We may also link information contained in a cookie to personal information collected from you by other means (such as through account registration).
  • Most common Web browsers today, such as Firefox and Internet Explorer, allow you to modify your settings to block cookies entirely, alert you every time they are being sent, or allow their use by only those websites you approve. You can also delete cookies that are currently stored on your computer’s hard drive. To do this within Firefox or Internet Explorer, go to Tools, then Options or Internet Options, and then choose the Privacy tab to make your selections. If you choose to disable cookies, certain features on www.pomegranate.com may not be available or work properly.
  • Log Files: these are files that record website activity and gather non-identifiable statistics about your visit to www.pomegranate.com. Log files may help us capture, among other things: (i) your IP Address, which is a unique set of numbers assigned to your computer by your Internet Service Provider (ISP) (note that, depending on your ISP, the number assigned to your computer can be different every time you connect to the Internet); (ii) the type of browser and operating system you use; and, (iii) other information about your online session, such as the URL you came from to get to Pomegranate.com and the date and time you visited. In addition to using this information to better understand how Pomegranate.com is used, we may use information captured through log files such as an IP address (together with your personal information) to troubleshoot technical problems, maintain website safety and security, and if necessary, prohibit or restrict access to www.pomegranate.com by certain users.
Web Beacons: often used to help deliver cookies or produce log files, these are small electronic images that can be embedded within a web page or included in an email message and are usually invisible to the human eye. When used, web beacons may tell us such things as: how many people are coming to www.pomegranate.com; whether they are one-time or repeat visitors; which pages they’ve viewed and for how long; how well certain online advertising campaigns are converting; and other similar website usage data. When used in an email, web beacons can tell us the time the email was opened, if and how many times it was forwarded, and what links users click on from within the email message. Based on this information, we can adjust the content, products, services, and promotions we provide you to better meet your interests.
 

2. INFORMATION SHARING AND DISCLOSURE

Internal Use of Non-Personal and Personal Information
We use Non-Personal Information and Personal Information for internal purposes only, such as to notify you of new products or services, to send service notifications, to customize the advertising and content you see, to fulfill your requests for products and services, to improve the Site, to conduct research, to solicit your feedback and input about the Site, and to provide more relevant products, services, and advertisements on or through the Site. Non-Personal Information and Personal Information may be combined with data collected from other sources so that we may further improve the relevance of products, services, and advertisements offered on or through the Site.
 
We may share Non-Personal Information and Personal Information with entities controlling, controlled by, or under common control with Pomegranate Communications Inc. We will not sell or rent Personal Information to third parties, and we will not otherwise disclose Personal Information to third parties, without your express permission or as expressly disclosed in this Privacy Policy.
Service Providers
From time to time, we might establish a business relationship with other persons or entities whom we believe trustworthy and whom we have asked to confirm that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as credit card processing, advertising, analytics tools, widget providers, personalization technology partners, data management services, Web hosting, and Web development.
 
We provide our Service Providers with the information reasonably necessary for them to perform these services. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification, or disclosure.
Third-Party Disclosure
We may use, and disclose to third parties, certain Non-Personal Information regarding the Site (e.g., number of visits, page views, number of registered members who reside in a particular geographic location, etc.) if we wish to generally assess (with the help of a third party company) how Pomegranate is doing in the Internet marketplace, its popularity or use amongst certain consumer demographics or profiles, and other similar performance metrics. The information disclosed for these purposes will be in aggregate form and limited to demographic or other anonymous data; no Personal Information will be shared.
 
In the event that Pomegranate is merged, sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Non-Personal Information and Personal Information in connection with such transaction.
Third-Party Ad Networks
We may work with third-party advertising companies which may use information about your visit to the Site in order to provide advertisements about goods and services that may be of interest to you on the Site and on third-party websites. From the Site, these companies may place or recognize a unique cookie on your computer or use other technologies such as Web beacons. Our Privacy Policy does not cover any use of information that a third-party advertisement serving company may collect from you. For more information about ad cookies and companies that provide users the ability to "opt-out" of the collection of information from such cookies, please click here.
As Required By Law
In certain instances, we may disclose Non-Personal Information or Personal Information when such action is reasonably necessary to comply with legal-related processes, enforce contract terms, respond to or resolve any claims (including valid consumer complaints), or otherwise protect the safety or rights (including intellectual property rights) of Pomegranate Communications Inc, our customers, consumers, or the general public.
Public Forums and Community Features
From time to time, we may provide social or community features for users that may allow users to publicly post, or share with other users, messages, stories, pictures, videos, testimonials, or other content. Along with such content, permitted users may also be given the opportunity to post certain Personal Information about themselves or others to whom the content relates (for example, name or part of a name, city, and state of residence). Although we may take certain precautions to protect those who use and participate in these activities, we cannot guarantee the privacy of these areas and are not responsible for any information you post or share. We encourage you to use common sense when using these services and never to reveal Personal Information about you that you do not want others to see. Any information you post or share in these areas is done so at your own risk.
 
Please be advised that, whenever you voluntarily post information to any community or interactive areas of the Site, such information can and may be accessed by the public. This means that any person or entity with access to such information can potentially use it for any purpose, including sending unsolicited communications.
 

3. ONLINE PRIVACY PROTECTION FOR CHILDREN

Information Practices and Sharing for Children Under 13
We recognize the importance of protecting children’s information and we strongly encourage parents to be actively involved in their children’s online activities. For this reason, we have adopted a special set of practices relating to Personal Information collected relating to children under the age of 13. Before reading these policies, however, please make sure to also review the sections above, which describe our privacy practices for our typical online consumers (i.e., parents).
 
We collect children’s Personal Information from adults. Access to Pomegranate is intended to be acquired by parents and not to be acquired by children directly. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.
 
For activities that necessitate the use of Personal Information from children under the age of 13, Pomegranate Communications Inc. will notify the respective parent of our privacy policy and obtain verifiable parental consent before collecting Personal Information in compliance with the Federal Trade Commission’s Children’s Online Privacy Protection Act.
 

4. SECURITY

Security Procedures
Information that we collect is stored on secure servers using standard security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure.
 
We use secure socket layer (SSL) to encrypt your data during transmission to us, but no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our end to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and other server security measures.

 

5. CONSENT

Managing Personal Information
We understand that you have rights over your Personal Information. You may review, correct, update, change, or delete your Personal Information at any time by visiting your account on the Site, or by contacting us at:
 
Pomegranate Communications, Inc.
105 SE 18th Ave.
Portland, OR 97214
Telephone: 503.328.6500
 
Opt-In/Opt-Out of Email Communications
Upon registration or from time-to-time, you may be asked to indicate whether you are interested in receiving information from us about special offers, news about our products and services, or promotional and community-building communications. You may also be provided with the opportunity to receive offers directly from select companies other than us. If you opt-in to these communications, at any time you can follow a link provided in every email message to unsubscribe from that mailing list or email service.
 
Pomegranate Communications Inc. will use information you provide through the Site, such as your email address or other personally identifiable information, without further consent for non-promotional or administrative purposes, such as notifying you of major website updates.
 
Please note that any opt-out or request not to receive future email will not apply to communications that relate to payment confirmations or reminders, communications in the event of a change in our Terms of Service or this Privacy Policy, and for other administrative purposes relating to your access to Pomegranate Communications Inc.
California Visitors and Customers
The California Consumer Privacy Act of 2018 (“CCPA”) provides California Consumers the right to direct businesses to not sell their personal information at any time (the “right to opt-out”).
 
In the preceding twelve (12) months, Pomegranate Communications, Inc. has not sold personal information (including the personal information of minors under 16 years old), and Pomegranate Communications Inc will not sell any personal information, including the personal information of minors.
 
Pursuant to the CCPA we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:
 
(1) We collected the following categories of Personal Information:
  • Identifiers, such as name, contact information and online identifiers;
  • Personal information, as defined in the California customer records law, such as name, contact information and financial information;
  • Protected classifications under California or federal law, such as sex, age and race;
  • Commercial information, such as transaction information, purchase history, financial details, and payment information;
  • Internet or network activity information, such as browsing history, online behavior, interest data and interactions with our websites;
  • Geolocation data, such as device location and IP location; and
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
As described above, we collect this Personal Information from you and from other categories of sources, including publicly available databases, authors and joint marketing partners, social media platforms and third-party service platforms, and our business customers, clients, and partners, when they share this information with us.
 
Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
 
(2) We disclosed the following Personal Information to third parties for our operational business purposes:
  • Identifiers, such as name, contact information and online identifiers;
  • Personal information, as defined in the California customer records law, such as name, contact information and financial information;
  • Protected classifications under California or federal law, such as sex, age, and race;
  • Commercial information, such as transaction information, purchase history, financial details, and payment information;
  • Internet or network activity information, such as browsing history, online behavior, interest data and interactions with our websites;
  • Geolocation data, such as device location and IP location; and
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We share Personal Information with our services providers for services such as website design and hosting, data analysis, payment processing, order fulfillment, information technology, and related infrastructure provision, customer service, email delivery, ad serving, research survey/interview/focus group management and analysis, marketing, and auditing.
 
If you are a California resident, you may request that we:
(1) Disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting Personal Information about you; and
  • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
To make a request for the disclosures, please email hello@pomegranate.com.
 
(2) Delete Personal Information we collected from you.
To make a request for deletion, please email hello@pomegranate.com.
You may also make the requests described above by contacting us in accordance with the “Contacting Us” page of this Site. We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
Linking and Third Party Sites
Please note that we are not responsible for the content or the privacy policies of websites to which our Site may link. Our Privacy Policy does not apply to the policies and practices of companies that we do not own or control, or to people that we do not employ or manage.
Changes and Updates
We may occasionally update this Policy. When we do, we will also revise the “last updated” date. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will attempt to obtain your consent before implementing the change. We encourage you to periodically review this Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of this Site constitutes your agreement to this Privacy Policy and any updates.