Zola, Inc. (hereafter, "Zola"), respects your concerns about privacy. This privacy policy ("Privacy Policy") describes the types of personal information we collect, how we use the information and with whom we share it. Based on the services we offer, we are both a data processor of information you provide regarding your wedding guests and only act on this information on your behalf (see our Terms of Use at https://www.zola.com/terms) and the data controller for the data you provide to access our services and make purchases.

If you have questions or concerns regarding this Privacy Policy, you should first contact Zola by emailing support@zola.com. You may also write to Zola as the address below. The phrase "personal information" refers to information by which you or the device you are using to connect to the Internet can be identified.

Zola Inc. registered in the United States with an office at 150 Broadway, 19th Floor, New York, NY 10038.

TYPES OF INFORMATION THAT WE COLLECT

You may visit our Website without providing any personal information, although we will collect certain statistical information discussed below. If you contact us to obtain information about our products or services we may collect your name, email or street address along with other information you may choose to submit. If you create a Zola account we may collect your name and email address and ask you to choose a user name and password. If you register on our Website we may also collect the name of your fiancé(e), wedding date and other information you choose to submit. If you make a purchase through our Website we may also collect your payment and shipping information as well as your telephone number. If you upload information to the Guest List or other features on the Website, we will collect the information you submit about yourself and about others. Please be aware that information or images that you post to our Website is publicly available unless you password protect it, and then it is accessible by anyone using the correct password. By providing information to us you agree to our collection and use as described in this Privacy Policy.

We also may use third-party website analytics tools that collect information about visitor traffic on our Website. The types of automated information we may obtain here include but are not limited to: (i) IP address, device type, browser and operating system type; (ii) search terms used to connect to our Website; (iii) dates and times of visits; (iv) page views and site navigation patterns; geo-location information; and (v) links and URLs that refer visitors to our Website.

USING THE INFORMATION WE COLLECT

We will only use the personal information we collect from and about you for the purposes described in this Privacy Policy and when the law allows us to do so. We will generally use your personal information on the following lawful grounds:
- Where the use of your personal information is necessary for the performance of a contract we are about to enter into or have entered into with you;
- Where the use is necessary for the purposes of our legitimate interests (or those of a third party);
- Where we need to comply with a legal or regulatory obligation; or
- Where you have provided your consent which can be withdrawn at any time.

We may use the information that you provide us or that we obtain about you for a variety of business purposes in our legitimate interests, including the following: (i) to manage and maintain your account including your use of Zola Registry and Zola Weddings features; (ii) process and track your purchases; (iii) contact you about your orders and your account, and contact individuals (i.e. guests) at your request and on your behalf; (iv) maintain a record of the purchases you make on our Website; (v) communicate with you about our Website, products, services, offers and events, provided you have given your consent if required under local law; (vi) have our customer support team respond to your questions and comments; (vii) operate, evaluate and improve our Website; (viii) send marketing communications, including email and to identify when emails sent to you have been received and track industry standard performance metrics, such as email opens and clicks ; (ix) prevent fraud, unauthorized transactions, and identify potential hackers and other unauthorized users; (x) enforce our Terms of Use; and (xi) comply with legal requirements and industry standards and our policies.

We may combine the information we collect with publicly available information and information we receive from our business partners and other third parties. We may use that 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.

HOW WE SHARE YOUR INFORMATION

We do not sell or otherwise disclose personal information that you provide us or that we obtain unless you request, consent or authorize us to do so, except as described in this Privacy Policy.

We may share the personal information that you provide to us, and the information that we collect about you to support our business interests as described above, to others, such as (i) merchant partners, fulfillment and payment processing services and customer support services to fulfill your purchase(s) and handle any issues with our services; (ii) technical service providers to keep our site running and safe as well as make our services available; (iii) third party applications such as social media that you use to log into Zola; (iv) analytics service providers to ensure site functionality and enable data-drive business decisions; (v) law enforcement and data protection authorities where we believe in good faith it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena; (vi) marketing or advertising service providers and networks to send marketing communications as well as serve you ads tailored to your interests or to tailor ads that may be served to you on our Website, as well as other websites and on social media networks. You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our advertising to users through demographic, behavioral and contextual means. These networks track your online activities over time by collecting information through automated means, including the use of cookies, web-beacons and other methods. The networks use this information to show you advertisements that are tailored to your individual interests. The information our ad network vendors collect includes information about your visit to Website as well as pages you have viewed, and the actions you have taken on the Website.

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 mailing addresses, but not email addresses) to other companies for purposes of marketing the Website or other 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 personally identifiable information (such as demographic information and past purchase history) available from our records and other sources.

We also use non-personally identifiable information in the aggregate, so that we can improve our Services and for business and administrative purposes. We may also use or share with third parties as listed above for any purpose aggregated data that contains no personally identifiable information.

INFORMATION SHARING OPTIONS

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.

Marketing Communications - You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails or by updating your preferences in your account settings You may change your email address for receipt of such communications by going to your account settings.

Data Analytics - If you do not wish to have technology used to gather information about how you interact with the Website while you are on our Website, please install the Google Analytics Opt-out Browser Add on available here: https://tools.google.com/dlpage/gaoptout and employ it at the start of each session on our Website. A cookie will be set on your browser that instructs this technology not to start for that session. Please note that the next time you access the Website the analytics will be reactivated, so you will have to disable the technology each time. If you reject the cookies and web-beacons we use, you may still use certain aspects of the Website, but you will not be maximizing the value of the Website.

Targeted Advertising - If you do not wish to have us collect, use and share information about you to deliver targeted online advertising in this manner, please click here (http://www.networkadvertising.org/choices/) and follow the instructions of how to opt-out. Please also note that most opt-out mechanisms are cookie-based and will only affect the specific computer and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. In addition, if you delete, block or otherwise restrict cookies, you will need to renew your opt-out choices to ensure that any opt-out cookies remain effective.

Cookies - Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our Websites' features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.

Do Not Track - We use technology that recognizes a "do-not-track" signal from your web browser which allows us to exclude you from any analytics that collect information about your online activities over time and across third party websites.

Third Party Data Collection - We permit limited third parties to place cookies through our Website to provide us with better insights into the use of our Website or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer's online activities over time and across different websites when he or she uses our Website.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for their direct marketing purposes. To submit your request, please email support@zola.com with the subject line "California Privacy" and your request in the body of your email.

YOUR EUROPEAN PRIVACY RIGHTS

For individuals within European Economic Area only. Under the GDPR, in certain circumstances, you have the right to: (a) request access to any personal information we hold about you and related information, (b) obtain without undue delay the rectification of any inaccurate personal information, (c) 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, (d) 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 (e) request transfer of your personal information directly to a third party where this is technically feasible.

In addition, where you believe that we have not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner's Office.

You can exercise any of these rights by contacting us at support@zola.com.

WHERE WE STORE YOUR PERSONAL INFORMATION

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.

HOW LONG WE STORE YOUR PERSONAL INFORMATION

We retain your personal data 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 data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including (without limitation) situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

You may access and update your registration information and your preferences to receive email or other communications 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 support@zola.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.

LINKS TO OTHER WEBSITES

Our Website may contain links to websites operated and maintained by third parties, over which we have no control. Privacy policies on such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk. You should always read the privacy policy of a linked website before disclosing any of your information on such website.

SECURITY

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 address so only we 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.

CHILDREN'S PRIVACY AND PARENTAL CONTROLS

We do not solicit any personal information from children. If you are not 18 or older, you are not authorized to use the 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.

PRIVACY POLICY CHANGES

If we decide to change this Privacy Policy, we will post the revised Privacy Policy here so that you will always know what information we gather, how we might use that information and whether we may disclose it to anyone. Your continued use of the Website indicates your consent to the Privacy Policy as posted.

CONTACT US

If you have any questions about this Privacy Policy, please contact us by email at support@zola.com You may also write us at:

Zola, Inc.
c/o Privacy Policy
150 Broadway, 19th Floor
New York, NY 10038

EFFECTIVE DATE

May 25, 2018