This Privacy Policy explains how personal data is processed
when this website is accessed or when an access request
is submitted through the website.

This website provides information about POMEGRAN 17
and enables selected parties to request access or a strategic briefing.

Privacy Principle

No cookie theater.
No tracking excess.
Controlled signal only.

POMEGRAN 17 does not rely on marketing cookies, tracking pixels,
or unnecessary behavioral profiling.

This website uses privacy-respecting analytics only to understand website usage, protect operational integrity, and improve content structure without collecting more than necessary.

1. Controller

Vyacheslav Maryevych
c/o flexdienst – #21552
Kurt-Schumacher-Straße 76
67663 Kaiserslautern
Germany

Email: privacy@pomegran17.com

POMEGRAN 17 is operated as a brand.
Unless otherwise expressly stated, the person identified above
is the controller for the processing activities described in this Privacy Policy.

2. General Processing Principles

Personal data is processed only where necessary to operate this website, maintain technical security, respond to access requests, evaluate legitimate strategic inquiries, and comply with applicable legal obligations.

Personal data is not sold.

3. Website Access and Server Logs

When this website is accessed, technical data may be processed automatically by the hosting provider or website infrastructure.

This may include:
• IP address
• date and time of access
• requested page or file
• browser type and version
• operating system
• referrer URL
• technical status codes
• similar technical information required for secure website
operation

This processing is necessary to provide the website, maintain stability, detect misuse, troubleshoot technical issues, and ensure technical security.

Legal basis:
Art. 6(1)(f) GDPR, legitimate interest in secure and reliable website operation.

4. Hosting and Website Platform

This website is created and hosted using Framer.

Provider:
Framer B.V.
Rozengracht 207B
1016 LZ Amsterdam
The Netherlands

When this website is accessed, personal data may be processed on Framer infrastructure for hosting, delivery, security, and technical operation of the website.

Where Framer processes personal data on behalf of the website operator, this processing is governed by the applicable data processing agreement, data processing addendum, or equivalent data processing terms.

Legal basis:
Art. 6(1)(f) GDPR, legitimate interest in secure, reliable, and efficient website operation.

5. Framer Analytics

This website uses Framer Analytics to understand website usage
and improve content, structure, and performance.

Framer Analytics may provide aggregated information such as page views, visitor numbers, referring sources, countries, devices, browsers, and similar usage metrics.

According to Framer, Framer Analytics does not use cookies
and does not generate persistent identifiers.

Analytics data is used only to understand whether the website structure, content, and access paths are functioning as intended.

Legal basis:
Art. 6(1)(f) GDPR, legitimate interest in privacy-respecting website analytics and content improvement.

6. Cookies and Similar Technologies

This website does not use marketing cookies or tracking pixels.

Technically necessary technologies may be used where required
to provide the website, ensure security, maintain functionality,
or deliver the service requested by the user.

Non-essential cookies, marketing technologies, behavioral tracking,
or third-party advertising pixels are not used unless explicitly disclosed and, where legally required, only after prior consent.

7. Access Requests and Contact

If you submit a request through the website, personal data provided by you will be processed.

This may include:
• name
• organization
• role
• email address
• request type
• message content
• communication history

This data is used to evaluate and respond to your request, assess whether the request matches the strategic scope of POMEGRAN 17, and conduct related communication.

Providing this data is voluntary. However, without the required contact and request information, the request may not be evaluated or answered.

Please do not submit sensitive, confidential, classified, regulated,
or unnecessary personal data relating to third parties through general access request forms.

Submitting an access request does not create any entitlement
to a response, briefing, material, or access.

Legal basis:
Art. 6(1)(b) GDPR for pre-contractual communication where the request concerns a possible briefing, evaluation, or business relationship;
Art. 6(1)(f) GDPR for legitimate interest in evaluating strategic inquiries, preventing misuse, and documenting relevant communication;
Art. 6(1)(c) GDPR where legal obligations apply.

8. Email Communication

If communication continues by email, the personal data contained in that communication may be processed for correspondence, documentation, follow-up, security, and legitimate business purposes.

Legal basis:
Art. 6(1)(b) GDPR where the communication relates to pre-contractual steps or a potential business relationship;
Art. 6(1)(f) GDPR for legitimate interest in communication, documentation, and security;
Art. 6(1)(c) GDPR where legal obligations apply.

9. Recipients and Service Providers

Personal data may be processed by service providers used to operate this website, provide analytics, process access requests, and manage communications.

Relevant service providers currently include:
• Hosting and website platform: Framer
• Analytics: Framer Analytics
• Form processing: Framer Forms
• Email processing: Infomaniak Mail
• Domain and DNS services: Infomaniak
• Fonts and website assets: Framer font system and selected web
fonts

These service providers process personal data only to the extent necessary for the respective hosting, technical operation, security, analytics, form processing, communication, domain, DNS, or content-delivery purpose.

Where a service provider processes personal data on behalf of the website operator, the processing is governed by the applicable data processing agreement or equivalent contractual terms.

10. External Links

This website may contain links to external websites, including professional and social media platforms such as LinkedIn.

If you click an external link, you leave this website.
The respective external provider may process personal data
under its own privacy policy and technical conditions.

This website does not use the LinkedIn Insight Tag, LinkedIn tracking pixels, LinkedIn advertising scripts, or LinkedIn retargeting technologies.

11. International Data Transfers

Some service providers or their sub-processors may process personal data outside the European Economic Area.

Infomaniak is based in Switzerland and states that data entrusted to its services is hosted and processed in Switzerland. Switzerland is recognized by the European Commission as providing an adequate level of data protection.

Framer may engage sub-processors and may process or transfer personal data outside the European Economic Area where necessary to provide hosting, delivery, security, analytics, form processing, or other technical services.

Where personal data is transferred to a country outside the European Economic Area that is not covered by an applicable adequacy decision, appropriate safeguards are used where legally required. These safeguards may include standard contractual clauses or other legally recognized transfer mechanisms.

12. Data Retention

Personal data is retained only as long as necessary for the respective purpose or as required by law.

Server log data is retained only as long as necessary for technical operation, security, troubleshooting, and abuse prevention.

Access requests are retained as long as necessary to evaluate and respond to the request and any subsequent legitimate communication related to that request.

Routine requests are generally reviewed for deletion after 12 months unless continued retention is required for documentation, security, legal, or legitimate business purposes.

Communication related to active strategic evaluation, legal matters, documentation, or business relationships may be retained for longer where necessary.

13. Your Rights

Under the GDPR, you have the right, where the respective legal requirements are met, to:
• request access to your personal data
• request correction of inaccurate personal data
• request deletion of your personal data
• request restriction of processing
• object to processing
• withdraw consent where processing is based on consent
• request data portability where applicable

Where processing is based on legitimate interests, you may object to the processing on grounds relating to your particular situation.

To exercise your rights, contact: privacy@pomegran17.com

14. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes applicable data protection law.

A complaint may in particular be submitted to a supervisory authority in the Member State of your habitual residence, your place of work, or the place of the alleged infringement.

15. No Automated Decision-Making

Personal data submitted through this website is not used for automated decision-making or profiling.

Access requests may be reviewed manually to determine whether they match the strategic scope of POMEGRAN 17.

16. Security

Appropriate technical and organizational measures are used, taking into account the nature, scope, context, and purposes of the processing, to protect personal data against unauthorized access, disclosure, alteration, or loss.

17. Updates

This Privacy Policy may be updated to reflect changes in the website, services, legal requirements, providers, or processing activities.

Last updated: 17 July 2026