Privacy Policy

Protecting Personal Information

A. Purpose

Pomegranate Journeys recognizes the right of an individual to the protection of their personal information and the need for information management practices that adhere to national standards. We will ensure that our policies and operational guidelines, directed by the principles of the CSA Code govern the management of personal information.

B. Scope

This policy will be applied to all personal information collected, used or disclosed, about an identifiable individual during the course of commercial activities. We will ensure that any third parties that have been approved, designated or contracted to act on our behalf are aware of and in compliance with the principles set forth in our Privacy Policy.

C. Definitions

i) Personal Information – Information that can be used to identify, distinguish or contact a specific individual; including opinions, beliefs, financial information, birth date and other identifying data but does not include the name, title or business address or telephone number of an employee of an organization.

ii) Commercial Activity - Any particular transaction, act or conduct or any regular course of conduct that is of a commercial character.

iii) Consent – Voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the organization seeking consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.

D. The Privacy Principles

To guide us in protecting your privacy, Pomegranate Journeys follows these 10 principles which are based on those created by the CSA and rooted in the Personal Information and Electronic Documents Act.

1) Accountability – We recognize our responsibility for all personal information under our control.

2) Identifying Purposes – Pomegranate Journeys and those designated or contracted to act for or on our behalf, shall identify the purposes for which personal information is collected at or before the time the information is collected. We will clearly define the purpose or purposes intended for personal data before we collect the information. Any personal information in our possession will only be used for the original purpose for which it was collected. Any secondary or optional uses of information by Pomegranate Journeys will be identified and individuals will be provided with an opportunity to reject or accept such uses.

3) Consent – We must have your knowledge and consent for the collection, use, or disclosure of your personal information We will provide a clear explanation of the intended uses of your personal information. We also recognize your right to prevent your personal information from being provided to other organizations on a reciprocal basis. Hence, we will not disclose any personal information without providing an opportunity for our supporters to opt-out. Pomegranate Journeys recognizes that individuals have the right to withdraw consent to personal information use at any time.

4) Limiting Collection – The collection of personal information shall be limited to the purposes we have identified to you. We will not collect personal information in an indiscriminate manner, nor will we collect information from other individuals associated with you such as family members or friends without your consent and knowledge, and only in situations that are deemed to be most compelling.

5) Limiting Use, Disclosure and Retention – We will only use or disclose your personal information with your consent (or as required by law) for the purposes for which it was collected. We will ensure that consent for personal information use is applied only to purposes agreed to initially by the individual. Pomegranate Journeys will only keep your information as long as needed for its identified purposes.

6) Accuracy – We will keep your personal information accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. We will provide our clients the opportunity to update or correct their personal information, which is outdated or inaccurate.