Zola, Inc. is registered in the United States with an office at 7WTC, 250 Greenwich St., 39th Floor, New York, NY 10007.
We collect your Personal Information from:
You may visit our Website without providing any Personal Information, although we will collect certain analytics information discussed below.
We may use Combined Information to enhance and personalize your shopping experience with us, to communicate with you about products, services and events that may be of interest to you, for other promotional purposes and for other purposes described in this section.
We also reserve the right to transfer Personal Information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Following such a sale, merger or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information.
Occasionally, we provide our postal mailing list (consisting of customer names and postal addresses) to other companies for purposes of marketing our Website or other Zola products or services that may be of interest to you. In order to determine the information that may be of interest to you, the information that you give us and information about your order may be combined with other Personal Information (such as demographic information and past purchase history) available from our records and other sources.
We also use non-personally identifiable information so that we can improve our products and services and for business, educational and administrative purposes. We may also use or share with third parties as listed above for any purpose anonymized data that contains no personally identifiable information.
We offer you certain choices about the collection, use and sharing of your information. Withdrawing your consent to use your Personal Information may mean that you cannot take advantage of certain offerings or Website features.
The following details the categories of Personal Information that we collect and have collected over the past twelve (12) months: Personal Identifiers, including age and date of birth; customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); Demographic Information and Protected Classification Characteristics, including protected classification characteristics under state or federal law; Information you Submitted or Posted; Commercial Information; Device Information; Location Information and Internet or Other Network Activity Information, including Geolocation Data; Customer Service Information; and Inferences.
Over the past twelve (12) months, we have disclosed the following categories of Personal Information to the third parties listed below for business purposes:
|Category of Personal Information||Types of Third Parties with Whom We Shared Personal Information a Business Purpose|
|Personal Identifiers||service providers; Special Circumstances Parties|
|Payment Information||payment processors|
|Information you Submitted or Posted for purposes of our sharing with third parties, including Vendor Network Data||service providers; other Zola users, including Vendors|
|Commercial Information||service providers; Special Circumstances Parties|
|Device Information||service providers|
|Location Information||service providers|
|Internet and Other Network Activity Information||service providers|
Based on our understanding of the term "sell" under the CCPA, we do not sell your Personal Information.
You have the right to request certain information about our collection and use of your Personal Information over the past 12 months. We will provide you with the following information:
If we have disclosed your Personal Information for a business purpose over the past 12 months, we will identify the categories of Personal Information shared with each category of third-party recipient.
You have the right to request that we delete the Personal Information that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Information to provide you with our Services, complete a transaction or other action you have requested, detect and protect against security incidents or other illegal activities, or to comply with our legal obligations. If your deletion request is subject to one of the exceptions under the CCPA, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (i) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, including by verifying the email address associated with the request, and (ii) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify you and complete your request. You do not need a Zola account to submit a Valid Request. Only you or someone legally authorized to act on your behalf (an "Authorized Agent") may submit a Valid Request. If an Authorized Agent submits a Valid Request on your behalf, we may require written proof of authorization and verification of identity directly from your Authorized Agent.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You or your Authorized Agent may submit a Valid Request using the following methods:
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may have different tiers of Services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, attributes or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.
If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Information to third parties who intend to license or sell your Personal Information. You can exercise this right by contacting us at email@example.com with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information (as sales are defined in Nevada Revised Statutes Chapter 603A).
For individuals within European Economic Area only. Under the GDPR, in certain circumstances, you have the right to: (i) request access to any Personal Information we hold about you and related information, (ii) obtain without undue delay the rectification of any inaccurate Personal Information, (iii) request that your Personal Information is deleted provided the Personal Information is not required by us for compliance with a legal obligation under European or Member State law or for the establishment, exercise or defense of a legal claim, (iv) prevent or restrict processing of your Personal Information, except to the extent processing is required for the establishment, exercise or defense of legal claims; and (v) request transfer of your Personal Information directly to a third party where this is technically feasible.
You can exercise any of these rights by contacting us at firstname.lastname@example.org.
The Personal Information that you provide to us is generally stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Information is submitted through our Website, it will be transferred to our servers in the United States, where laws regarding data protection may be less stringent than the laws in your country. By using our Website and by providing any Personal Information through our Website, all users, including without limitation users in the European Union, fully understand and unambiguously consent to the collection and processing of such Personal Information in the United States.
We retain your Personal Information while your account is in existence or as needed to provide you our services and for legitimate and essential business purposes, such as maintaining the performance of Zola, making data-driven business decisions, complying with our legal obligations, and resolving disputes. If you request, we will delete or anonymize your Personal Information so that it no longer identifies you, unless, we are legally allowed or required to maintain certain Personal Information, including (without limitation) situations such as the following:
You may access and update your registration information, preferences to receive email or other communications, and certain other data under your account settings. We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to ten business days as we process your request. If you believe other Personal Information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us at email@example.com with the subject line "Update Account Information" and your request in the body of your email. While we make efforts to accommodate requests to restrict our use of your information, we reserve the right to delete all or any portion of customer information if we are not able to reasonably accommodate a requested restriction.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, our Website uses Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and postal address so only we or our payment processors, as applicable, are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your contact information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from our Website, and you do so at your own risk.
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
We do not solicit or knowingly collect any Personal Information from children. If you are not 18 or older, you are not authorized to use our Website. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If we learn we have collected Personal Information from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided Personal Information to us, please contact us at firstname.lastname@example.org.
250 Greenwich St., 39th Floor
New York, NY 10007
October 29, 2020