Privacy and cookie policy
Pomegranate Learning Services Ltd (“we, us, our”) respects the privacy of every individual who visits our website, contacts us, and works with us. We are committed to safeguarding your privacy and have written the following privacy notice to explain what information we collect and what we do with it.
Information about us
www.pomegranatelearning.com is a site operated by Pomegranate Learning Services Ltd ("we", "us" or "our"). We are a limited company registered in England & Wales under company number 16290932 and have our registered office at Foresters Hall 25-27 Westow Street, London, England, SE19 3RY
Who is the data controller and processor?
For the purposes of the personal data covered in this privacy notice, Pomegranate Learning Services Ltd could be a 'Data Controller' or a 'Data Processor'.
How do we obtain your personal information?
We have listed the ways we are likely to collect your personal information according to the relationship you have with us. We may obtain your personal information in a variety of ways, including:
Clients, Consultants, suppliers, and other business contacts:
From data you supply whilst working together during commissioned services or during new business activities and the act of commissioning new work.
From inbound enquiries to contact@pomegranatelearning.com and any other email inboxes such as individual email accounts of Pomegranate Learning Services Ltd’s Consultants.
From inbound phone calls where we see the incoming phone number, and you pass us information verbally.
From networking activities and events, for example, exchanging business cards or connecting on LinkedIn.
From recommendations or references about you from others.
From you signing up to our mailing list, webinars or other events that may be delivered via our website.
From contact and conversations with our suppliers.
Website visitors:
From visits to our websites and when resources are accessed on our websites and other platforms and technologies made available by us. We may automatically collect technical data and usage data. We may collect this data via cookies, including, where available, your IP address, operating system, and browser type, for system administration.
From website data capture forms, for example, event applications and booking forms or pdf downloads.
Website visitors:
When you first visit our website, you are asked to set your cookie preferences. If you reject all cookies, you can visit the website without any information being collected. For full details about the cookies we use and how to change your cookie preferences, see our cookie declaration here: https://www.impactinternational.com/cookie-declaration
If you choose to allow us to use cookies, Impact or our partners may collect the following information:
Technical data, including your IP address, browser type and version, and operating system.
Information about how you use the website.
Information about how you have responded to our marketing activity, including marketing emails and advertising.
Any information you supply to us through forms on the website, which may include:
Name
Email address
Phone number
Job title
Business name and address
Country
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
How is your personal information used, and what is our legal basis?
The list below shows how your personal information may be used (the purpose) and, in each case, what the legal basis is. Where legitimate interest is the legal basis, we identify what our legitimate interests are.
Category: Clients, Consultants and suppliers
Purpose:
Communicating with you as a client, consultant or supplier about new or currently commissioned projects.
Performing financial tasks, such as raising and sending invoices.
Communicating with you whilst we provide services to you as a client.
Communicating with you with regards to an event you have applied to attend or have attended (e.g. sending you logistical information about the event or sending you related follow-up content).
Legal basis for processing: Contractual fulfilment
Category: Clients, prospective clients, business contacts
Purpose:
Responding to enquiries about our services that you have sent to us.
Registering you and managing our relationship.
Contacting you to ascertain interest in our services.
Sending you e-newsletters and other relevant content regarding our services via email if you have signed up for our mailing list.
Communicating with you on LinkedIn, for example, sharing relevant content or inviting you to industry events.
Communicating with you regarding any previously agreed marketing activity, such as the production of a case study or video or entering an industry award.
Enabling you to participate in surveys.
Communicating with you with regard to an enquiry you submitted through the website.
Sending you marketing communications and proposals for working together.
Growing our business and informing our marketing strategy.
Conducting research and product development to improve our services for the benefit of our clients and others.
Keeping our records updated.
For good governance, accounting, and managing and auditing our business operations.
Legal basis for processing: Legitimate interest
Category: Website visitors
Purpose:
Ensuring the security and functionality of our website.
Keeping our website updated and relevant to develop our business and to inform our marketing strategy.
Legal basis for processing: Legitimate interest
Category: Participants
Purpose:
Providing the service contracted by your organisation.
Communicating with you whilst we provide services to you as a participant.
Legal basis for processing: Contractual fulfilment
Who is your information shared with?
Your personal data will not be sold or disclosed to anyone outside of Pomegranate Learning Services Ltd or appointed Consultants/suppliers without obtaining your prior consent - unless we are required to do so by law.
Your personal data is only shared within Pomegranate Learning Services Ltd if the receiving parties need to process that data in order to fulfil one of the purposes listed above.
Retention of your personal information
Our data retention policy is to hold data for three years after the end of the last interaction between us; this includes attendance of one of our programmes or after a software licence expires. In some cases, we may be legally required to retain the data for a longer or shorter length of time.
Your rights
As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email contact@pomegranatelearning.com
Your rights are as follows:
The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
The purposes of the processing.
The categories of personal data concerned.
The recipients to whom the personal data has been disclosed.
The retention period or envisioned retention period for that personal data.
When personal data has been collected from a third party, the source of the personal data.
If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.
The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
The right to erasure (the ‘right to be forgotten')
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
The accuracy of personal data is contested.
Processing of personal data is unlawful.
We no longer need personal data for processing but the personal data is required for part of a legal process.
The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
The right to data portability
You have the right to object to our processing of your data where:
Processing is based on legitimate interest;
Processing is for the purpose of direct marketing;
Processing is for the purposes of scientific or historic research; or
Processing involves automated decision-making and profiling.
Where we are a processor in respect of your personal data, we will inform the relevant controller of your request and assist and co-operate with the controller for them to fulfil the request.
How we protect your information
We take a range of organisational and technical measures to protect your information.
We maintain strict physical, electronic and administrative safeguards to protect your personal data from unauthorised or inappropriate access. Where appropriate, we use industry-standard encryption techniques. Regular security reviews are held by Impact to ensure that our systems and processes remain safe and secure for the protection of your personal data.
Logging personal data online / Cookies
For more information about cookies, please see our cookie declaration here: https://www.impactinternational.com/cookie-declaration.
Third-party service providers
From time to time, we may employ or engage third parties (Consultants) to help us deliver part of our services, to deliver activities that are related to our services, or to help us analyse how our services are being used and accessed. Where our requirements are such that we need to disclose personal data to these third-party service providers so that they can carry out their tasks in accordance with their agreement, we will make sure that we comply with the provisions of the GDPR as regards data security.
Changes to this privacy statement
We may update this privacy statement from time to time to reflect changes in law or changes in our data protection regime. Any changes will usually be effective immediately that an updated version of this privacy statement is issued.
Contact us
If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at contact@pomegranatelearning.com
Amendment Privacy Statement
We reserve the right to amend this privacy statement. The current version of the privacy statement is the version as published on our website.
It was last updated on 22/04/2026.
