Privacy Notice

PRIVACY POLICY

Last Updated: August 2026

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  1. WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

At Pepper, we take privacy seriously. This policy (“Privacy Policy”) explains how we collect, use, disclose, retain and protect  personal information. In this Privacy Policy, references to "Pepper", "we", "us" and "our" are to the Pepper Group. Pepper Group means Pomegranate Technologies Australia Pty Ltd (ACN 677 052 934), Pomegranate Technologies Canada, Inc. and Pomegranate Technologies Inc. References to "you", "your" and "yours" are to any individuals whose personal information we collect, including our customers, business partners and third parties.

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This Privacy Policy applies to each of our websites, apps, services or tools that contain a link to this Privacy Policy (collectively, our “Services”).
We reserve the right to update this Privacy Policy from time to time. If we do so, the updated version will be made available through our Services, and we will provide prominent notice and/or contact you by email if we make material changes. By continuing to use our Services after receipt of any such notice, you agree to the updated version to the extent permitted by law. Please periodically review this Privacy Policy for the latest information on our practices with respect to your Personal Information.

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  1. APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy does not apply to our processing of personal information on behalf of our business customers. If you are using the Services as an employee, contractor or other representative of one of our Foodservice Establishments, Supplier (as each term is defined in our Terms and Conditions), or our other business customers and you have questions about our privacy practices or would like to exercise any rights with respect to your personal information that we process on behalf of our customers, please contact the corresponding customer, as we only process your personal information in our capacity as a service provider to that customer subject to our agreement(s) with them.

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  1. WHAT IS PERSONAL INFORMATION?

Throughout this Privacy Policy, "Personal information" means information or an opinion about an identified individual or reasonably identifiable individual, whether true or not and whether recorded in material form or not.

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  1. 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, and for other business purposes. 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 (such as when you create your user account as described in our TOS). The personal information we collect and hold may include:

  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, 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. 
    1. Device information including 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 ”Managing use of cookies, tracking tools and your mobile device” section below for more information on how this information is actually collected).  
    2. 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).
    3. Demographic information including gender, interests and favourites, 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. Marketing information, such as your preferences for receiving marketing communications and details about your engagement with them.
  8. Information collected from third parties, which serves to supplement the information we collect directly from you. It can be from commercial data aggregators or business partners.‍
  9. 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.

We collect and record personal information about individuals such as:

  1. our customers/clients/members, potential customers/clients/members and their representatives, including but not limited to food distributors, manufacturers and restaurants;
  2. our suppliers, potential suppliers and their representatives, directors, partners, proprietors and shareholders;
  3. contractors, subcontractors, potential contractors and subcontractors and their representatives in relation to providing goods and services to us;
  4. our employees past and present, including employment applications; and
  5. other individuals who come into contact with us.

Where you provide us with the personal information of third parties, it is your responsibility to inform them about the processing of their personal information in accordance with this Privacy Policy, and to confirm that they have given their permission.

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  1. HOW DOES PEPPER COLLECT PERSONAL INFORMATION?

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.  Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect this information when you communicate with us through our websites, by telephone, by email, through a written application or our application. In some circumstances, collection of personal information may be required by law. We may also collect personal information from a third party where it is unreasonable or impracticable to collect it directly from you, or where we are otherwise legally permitted to do so. If we collect personal information about you from a third party, we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct the information. We may generally collect your personal information when:

  1. you use or buy our products or services;
  2. you provide us, or you offer or apply to supply us, with goods or services;
  3. you request information about us, our services, programs or application;
  4. you provide feedback to us;
  5. you visit, make an inquiry, or fill in a form on the Websites;
  6. you register to be a member, donor, volunteer or partner;
  7. you submit a job application to us;
  8. conducting customer satisfaction and market research surveys;
  9. you contact us by telephone, email, social media, post or in person; and
  10. we are otherwise required or authorised by law.

How we collect information from you or third parties may also vary depending on how we interact with you, or our relationship with you. For example:

  1. For food distributor employees, we collect your personal information when we sign a contract with our customers and they set up user profiles for the employees to the relevant software platform;
  2. For restaurant employees, we collect your personal information from you directly when:
    1. you enter the information directly in our application to become a new customer of a distributor; or
    2. the distributor provides them to us, either over EDI, manually sending them to us, or by inputting them into our application;
  3. For restaurant patrons, we collect your personal information, including payment information, from the distributor or the restaurant through our application
  1. WHY AND HOW DOES PEPPER USE YOUR PERSONAL INFORMATION?

We use your Personal Information to provide, improve and personalise 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 the purposes for which we collect, hold, use and disclose your Personal Information:

  1. Providing you with our Services, including processing and communicating with you about your use of our Services, allowing you to access and use our Services, 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 identifying you and to answer any questions you may have of us, or with respect to any of your account activity.
  3. Improving and personalising 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. Performing our organisational functions and activities, in order to operate our business efficiently.
  8. Complying with our legal obligations, including assisting government and law enforcement agencies or regulators.

We may collect, use and disclose your Personal Information as otherwise permitted or required by law, provided it is necessary or relevant to our business, or as we may otherwise notify you. We will not use or disclose your personal information for any other purpose without your consent.

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  1. WHO DOES PEPPER SHARE YOUR PERSONAL INFORMATION WITH, AND WHY?

We may share your Personal Information with third parties under certain limited circumstances. We may disclose your personal information to the following third parties:

  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, personalised 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 Australia.
  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 license, share, or use anonymized, aggregated data with third parties for research, business or other purposes.
  3. 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.
  4. 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.
  5. professional service providers and advisors who perform functions on our behalf, such as lawyers and accountants;
  6. medical providers including medical and rehabilitation practitioners for assessing insurance claims; and
  7. Government, regulatory authorities or other organisations as required or authorised by law.

We may disclose your personal information with third parties for purposes including, but not limited to, the following:

  1. 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.
  2. to enable external service providers to perform services for us or on our behalf or assist us in providing our services or to administer our business;
  3. to comply with applicable law
  4. to enforce our TOS, prevent, detect, mitigate or investigate fraud or other illegal activity; and
  5. to protect our legitimate business interests.

When we disclose personal information to third parties, we take all reasonable steps to ensure that we disclose only relevant information, that it is accurate, complete and up to date, and that the third party will comply with applicable laws in relation to the use, disclosure and storage of your information.

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  1. OTHER PERMITTED DISCLOSURES

We may disclose personal information in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by under the law. These other disclosures may include where:

  1. you would reasonably expect the disclosure to occur (for example, quality assurance purposes or training);
  2. we are authorised or compelled by law to disclose;
  3. it will prevent or lessen a serious threat to someone's life, health or safety or a threat to public health or safety;
  4. it is necessary as part of the establishment or defence of a legal claim;
  5. it is requested by an enforcement agency such as the police; or
  6. it is a necessary part of an investigation following a complaint or incident.

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  1. WHAT ARE YOUR 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. These include:

  1. In general, you have the right to object to or opt out of certain uses of your Personal Information, which we describe further in this section. 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. Accessing or correcting your personal information, by contacting us at the details set out below. There may be some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date. If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons. If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.
  5. Making a complaint by contacting us at the details set out below, where you may have a complaint or concern regarding our handling of your personal information or think that your privacy has been affected. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation. If you are located in Australia and you remain unsatisfied with the way in which we have handled your privacy complaint or concern, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC). See the OAIC website for more information about how to make a complaint.
  6. Adjusting contact book preferences, including to revoke our access to your device’s contact book.
  7. Opt out of “profiling” in connection with decisions that produce legal or similarly significant effects. We do not engage in such profiling activities.

Managing use of cookies, tracking tools and your mobile device There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

  • 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 web beacons) to improve your experience by recognizing you when you visit our Services, assigning a session ID, and delivering 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 measure how visitors use our Services, for purposes such as site traffic reporting, unique visitor counts and content optimization. Although Google Analytics logs information from our Services on our behalf, we control how the data may and may not be used. If you do not wish to participate in this analysis, you can opt out at: https://tools.google.com/dlpage/gaoptout.

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  1. FOR HOW LONG DOES PEPPER KEEP YOUR PERSONAL INFORMATION?

As a general rule, where information we store is no longer required by us for any purpose for which it was collected and is no longer required by law to be retained by us, we will destroy or de-identify the information. However, 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.

  1. WHAT SECURITY MEASURES DOES PEPPER TAKE TO PROTECT YOUR PERSONAL INFORMATION?

We store most information about you in computer systems and databases operated by us or our external service providers. 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. 

We advise that there are inherent risks in transmitting information across the internet, including the risk that information sent to or from a website may be intercepted, corrupted or modified by third parties.  

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  1. HOW DOES PEPPER HANDLE INTERNATIONAL DATA TRANSFERS?

We may disclose your personal information to third party recipients located in Australia or 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 Australia.

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Individuals located in Australia  By consenting to our collection notice, you agree to the collection, use, storage and disclosure of your personal information in those countries for purposes necessary or useful in the course of operating our business, without us being responsible under the Australian Privacy Act for such collection, use, storage and disclosure (or breach) of your information by the third party recipients. Where such recipients are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information. For the avoidance of doubt, this includes the event that any overseas recipient breaches the Australian Privacy Principles. If you do not want us to disclose your information to recipients outside of Australia, please let us know.

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  1. PLEASE NOTE THAT OUR SERVICES ARE NOT INTENDED FOR CHILDREN.

‍Our Services are intended for adults. We do not knowingly collect Personal Information from individuals under the age of 16. If you are a parent or guardian and become 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 a child under 16 without verification of parental or guardian consent, we will take steps to remove that information from our servers.

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  1. 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 Policy does not apply to the privacy practices of those websites. Read the privacy policies 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.

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  1. 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 Policy or our handling of your Personal Information, please contact us at: Mailing address: Attention: Legal Pepper Pomegranate Technologies, Inc., 900 Broadway, Suite 704 New York, NY 10010 Email: help@usepepper.com