1. WHAT IS THE PURPOSE OF THIS PRIVACY NOTICE?
At Pomegranate Technologies Inc. dba “Pepper”, we take privacy seriously. This notice (“Privacy Notice”) explains how we collect, use, disclose, retain and protect information that identifies you personally (your “Personal information”). This Privacy Notice applies to each of our websites, apps, services or tools that contain a link to this Privacy Notice (collectively, our “Services”). Please also read our Terms of Service that govern your use of our Services (the “TOS”). We reserve the right to update or change this Privacy Notice from time to time. If we do so, the updated version will be made available through our Services and/or otherwise made available to you, and we will provide a prominent notice and/or contact you by email or other method if we make material changes to it. By using our Services after receipt of any notice of an update to this Privacy Notice, you agree to the updated version to the extent permitted by law. Please periodically review this Privacy Notice for the latest information on our practices with respect to your Personal Information.

2. WHAT INFORMATION DOES PEPPER COLLECT?
When you use our Services, we may ask you to provide us with certain Personal Information that can be used to contact or identify you. We collect or receive information in different ways, depending on how you use and interact with our Services. In some instances you can choose which information you provide to us, but in others certain information is required so that we can provide our Services to you (like when you create your user account as described in our TOS). Please read on for more information on this.

1. Personal identifiers, including information provided when you create or update your user account or fill out a web form. This is information such as your name, business address, e-mail addresses, payment information (including your credit card details), phone numbers, login and password.‍
2. Business information, including information about items or services you purchased, your feedback or reviews, or details related to your business.‍
3. Information generated from your use of our Services, including device, location and demographic information. Device information includes whether you are using our website or apps, your device and connection type and browser, and may include your device’s IP address (see our Cookie Policy below for more information on how this information is actually collected).  Location information is collected to ensure that our Services are provided to the most accurate location (you can usually turn location sharing off in your device’s settings). Demographic information includes gender, interests and favorites, including through user surveys.‍
4. Contact book information, if you give us permission to access your device’s contact book. We will use this information to allow you to invite others to use the Services and to populate the name and phone number of those individuals.‍
5. Your content, which we may collect from information you post on our website or on social media, or when you contact or otherwise communicate with us. It enables us to tailor our Services to your preferences. If your content contains any information about another person, please make sure you have their consent to share it.‍
6. Photos and other images you may choose to upload in your communications with other users.‍
7. Information collected from third parties, which serves to supplement the information we collect directly from you. It can be from commercial data aggregators as well as marketing and advertising partners.‍
8. For referral services, which we may offer for you to tell friends about our Services. In order to use this referral service, we will need to collect your contact’s name and email address, and they would receive an automatic one-time invitation via email that we send on your behalf inviting them to use our Services.
   

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3. HOW DOES PEPPER USE MY PERSONAL INFORMATION?
We use your Personal Information to provide, improve and personalize our Services for you, if we need to contact you about your user account or our Services, or to provide you with customer support or prevent fraud or other illegal activities. Below are additional details on how we use your Personal Information.

1. Providing you with our Services, including processing and communicating with you about your use of our Services, allowing you to invite and interact with other users of our Services, and to provide you with customer support or otherwise contact you about your use of our Services.
   
2. Communicating with you, including to answer any questions you may have of us, or with respect to any of your account activity.
   
3. Improving and personalizing our Services for you, which helps us provide you with a more customized user experience based on your provided preferences. We also might get information about you from third parties and combine it with what you’ve provided to us for this purpose.
   
4. For security purposes, to help protect you, our Services, company and our other customers from fraud or other illegal activities.
   
5. For marketing purposes, so that we can let you know about new features or promotional offers that you might be interested in based on your provided preferences.
   
6. Pursuing our legitimate interest, including, for example, direct marketing, research (including marketing research), network and information security and fraud prevention.
   
7. We use Personal Information as otherwise permitted or required by law, as long as it’s necessary or relevant to our business, or as we may otherwise notify you.
   

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4. WHO DOES PEPPER SHARE MY PERSONAL INFORMATION WITH, AND WHY?
We may share your Personal Information with third parties under certain limited circumstances. Additional detail on who we share your information with and why is directly below.

1. Third party service providers, who may, as our trusted service providers, need certain of your Personal Information for payment processing, billing, account security, customer support, personalized advertising and other business operations. Third party service providers and/or the equipment on which such service providers store or process Personal Information may be located outside the United States.
   
2. Third party collaborations. After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, we may use, sell, license and/or share your information with third parties for research, business or other purposes.
   
3. As part of a business transaction or in connection with negotiations and preparations for a possible business transaction, including if we are involved in a merger, acquisition, financing due diligence or other similar event.
   
4. Credit agencies or bureaus, with whom we may need to share (where legally permitted) certain information if you’ve missed payments or defaulted on your user account.
   
5. Any of our affiliated or related entities, in order to ensure that you have a secure and consistent experience using our Services. These companies may be providing you with various products and services as our business evolves.
   
6. To comply with applicable law, enforce our TOS, prevent, detect, mitigate or investigate fraud or other illegal activity or to protect our legitimate business interests.
   

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5. WHAT ARE MY CHOICES WITH HOW PEPPER HANDLES MY PERSONAL INFORMATION?
You have a choice about how we handle your Personal Information. There are various ways you are able to control the personal information of yours that we receive and retain, and how your activity is tracked when using our Services.

1. In general, you have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us at help@usepepper.com.
   
2. Opting out of marketing communications, which you can do by following the instructions in any marketing email or through your account settings. This does not apply to transactional messages that relate specifically to your use of our Services (because you’ll need to receive those in order to use our Services).
   
3. Updating your account information, including to update or delete incorrect user account information (you must log in to your account to do this).
4. Adjust contact book preferences, including to revoke our access to your device’s contact book.
5. Understanding cookies, tracking tools and your mobile device, more information for which can be found directly below. Your mobile device should allow you to control the types of notifications you receive and to turn off GPS location services if you prefer not to share that information. When you use our Services, we may place a “cookie” or other online tracking device (such as a web beacons) in order to improve your experience by recognizing you when you visit our Services, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address or clickstream data within our Services (i.e., the actions taken in connection with our Services). This information helps us improve the functionality of our Services. We also use cookies provided by Google Analytics to help us measure how visitors use our Services. The information collected is used for a variety of purposes, such as site traffic reporting, unique visitor counts and content optimization. Although Google Analytics logs the information coming from our Services on our behalf, we control how the data may and may not be used. If you do not want to help us learn how to improve our Services, you can opt-out of this website analysis tool by clicking: https://tools.google.com/dlpage/gaoptout. Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of our Services. We may keep track of the websites and pages users visit within our Services in order to determine which products or services are most popular. This data is used to deliver advertising to customers whose behavior indicates that they are interested in a particular subject area. To opt out of such interest-based advertising, visit Digital Advertising Alliance’s Choices page at optout.aboutads.info. We do not, however, engage in the collection of personally identifiable information about your online activities over time across third-party websites or online services.
   
6. Do Not Track (“DNT”), which is a privacy preference that users can set in certain web browsers. We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
   
7. Shine the Light Law (for California residents). If you are a California resident and have an established business relationship with us, you have the right to request certain information regarding our disclosure of your personal information to third parties for direct marketing purposes. To make such a request, you can email help@usepepper.com.
   

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6. FOR HOW LONG DOES PEPPER KEEP MY PERSONAL INFORMATION?
We keep your Personal Information for as long as is reasonably necessary in order to provide you with our Services, or until your account has been deleted (whichever happens first). This is subject to any longer period that might be required by applicable law or notified to you. If you delete your account, it may take additional time to fully delete your Personal Information. We may retain Personal Information from deleted accounts in order to prevent fraud, enforce our rights under our TOS, to enforce our legal rights generally or to comply with our legal obligations.

7. WHAT SECURITY MEASURES DOES PEPPER TAKE TO PROTECT MY PERSONAL INFORMATION?We strive to protect your Personal Information using reasonable, industry standard technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. However, no one can guarantee absolute protection on the Internet, so we cannot ensure or warrant the security of any information you provide to us.

8. HOW DOES PEPPER HANDLE INTERNATIONAL DATA TRANSFERS?
You understand and agree that we may transfer and process your Personal Information anywhere in the world, including the United States. We are located in and subject to United States laws, which may not afford the same level of protection as those in your country. We will take all reasonably necessary steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice.  By providing us with any Personal Information, you consent to our transfer of Personal Information across national borders.

9. PLEASE NOTE THAT OUR SERVICES ARE NOT INTENDED FOR CHILDREN.
‍Our Services are meant for adults. We do not knowingly collect Personal Information from people under the age of 16, nor do we sell such Personal Information. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us at help@usepepper.com. If we become aware that we have collected Personal Information from children under 16 without verification of parental or guardian consent, we take steps to remove that information from our servers.

10. WE MAY LINK TO THIRD PARTY SITES OR SERVICES WE DON'T CONTROL.
Our Services may contain links to third party websites that we do not control. This Privacy Notice does not apply to the privacy practices of those websites. Read the privacy notices of other websites carefully. We are not responsible for these third party sites. Our Services may also serve third party content that contains their own cookies or tracking technologies, and we do not control the use of those technologies.

11. IF YOU HAVE ANY QUESTIONS OR CONCERNS, PLEASE FEEL FREE TO CONTACT US.
‍If you need to reach us about anything related to this Privacy Notice or our handling of your Personal Information, please contact us via email at help@usepepper.com. Please reference this Privacy Notice and do not include any sensitive details.