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 it and with whom we share it. "Personal Information" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information", "personal information" or "personal data" under applicable data privacy laws, rules, or regulations. 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. This Privacy Policy applies to our Website, our mobile applications ("Apps") and the related Zola-branded online and offline services related thereto (the "Services"). This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage. Any capitalized terms used but not defined in this Privacy Policy will have the meaning given to them in the Terms of Use.

If you have questions or concerns regarding this Privacy Policy, you should first contact Zola by emailing privacy@zola.com. You may also write to Zola at the postal address below.

Zola, Inc. is registered in the United States with an office at 7WTC, 250 Greenwich St., 39th Floor, New York, NY 10007.

SOURCES OF PERSONAL INFORMATION

We collect your Personal Information from:

  • You:
    • when you provide such information directly to us, and
    • when your Personal Information is automatically collected in connection with your use of our Services.
  • Our subsidiaries and affiliates (together, "Affiliates"), when they provide us with your Personal Information.
  • Third parties, when they provide us with your Personal Information ("Third Parties"). Third Parties that share your Personal Information with us may include:
    • Service Providers. For example, we may use analytics service providers to analyze how you interact and engage with our Services, or third parties may help us provide you with order fulfillment or customer support.
    • Social Media Networks connected to our Services. If you provide your social media network account credentials to us or otherwise sign in to our Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted to us.
    • Other Zola Users. For example, we may receive your Personal Information from couples sharing information about their wedding guests or holiday card recipients. Vendors seeking to participate in our matching services may provide the Personal Information of Zola couples that were their clients or of fellow Vendors for purposes of being recommended to our matching services.
  • We may also combine the information we collect with publicly available information and information we receive from our business partners and other third parties ("Combined Information").

TYPES OF INFORMATION THAT WE COLLECT

You may visit our Website or use our Apps without providing any Personal Information, although we will collect certain analytics information discussed below.

  • Personal Identifiers. If you contact us to obtain information about our products or services, we may collect your name, email address and phone number along with other information you may choose to submit. If you visit our Website, we may assign you a customer identification number, and 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 use certain of our Services, we may also collect your age, date of birth, sex, signature, social security number, citizenship, driver's license number or passport number and postal address.
  • Payment Information. If you make a purchase through our Website or Apps or redeem cash registry funds, we may collect your telephone number, postal address, email address, payment type, bank account number, credit or debit card number, verification number and expiration date. Your bank account number and credit and debit card numbers are managed by our payment processor partners; we do not handle or store this data.
  • Information you Submit or Post. We will collect the information you submit to us about yourself and about others, including but not limited to any information submitted to us through ratings and reviews, our chat feature, our wedding planning tools or through other uses of our Services. Please be aware that any information, including images, that you post to a public-facing portion of our Website (e.g. your wedding registry or wedding 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.
    • Wedding Website and Planning Tools. If you use Zola's wedding website services and other wedding planning tools, we will collect all information regarding yourself and others that you add to your wedding website or other wedding planning tools, such as the name of your fiancé(e) and your wedding date; this includes all information that you add onto your wedding website regardless of whether you've published your wedding website.
    • Registry Services. If you use Zola's registry services, we may collect certain information in the process of building a registry, receiving gifts, shipping gifts or transferring cash funds. Such information may include but is not limited to: preferences about your registry and style; items you've added to your registry; personal notes you've added to any items on your registry; standard order information about gifts purchased from your registry; if you have a cash registry, Payment Information to enable us to transfer the gift; and which gifts from your registry you have or haven't taken action on (such as shipping, transferring, or exchanging a gift).
    • Honeymoons. If you use Zola's Honeymoons services, we may collect various data to determine a traveler's travel preferences, including preferences around trips, budget, hotels, and other travel needs, such as your abilities as they relate to certain excursions and activities or dietary restrictions. We may also collect certain Personal Identifiers and Payment Information needed to book your travel, including your age, date of birth, citizenship and driver's license number or passport number.
    • Invitations and Paper Goods. We collect information that you provide to us in the process of drafting and printing paper goods, including Personal Identifiers such as names and postal addresses, as well as any information added to a draft for the purpose of being printed on a card, envelope, or other item and the number of drafts you've created, edited, or printed.
    • Matching Services. If you use Zola's matching services, we may collect your budget information, guest count, wedding date and location, information about your preferences and characteristics, photos you save or favorite as inspiration, information about Vendors that you have selected, information about Vendors you've inquired about and/or received responses from, preferences about Vendors, your criteria for potential Vendors, and other information that you choose to submit about yourself in connection with Zola's matching services ("Match Data"). We may also collect Personal Identifiers and other information of Vendors for the purposes of recommending them for our matching services.
  • Commercial Information. We may collect information about the products or services purchased, obtained or considered, as well as other purchasing or consuming histories or tendencies.
  • Demographic Information and Protected Classification Characteristics. We may collect certain information of the following information, including through surveys of our customers and users: sex, race, ancestry/national origin, religion, marital status, sexual orientation and educational level. We may also collect your age, date of birth, gender and zip code.
  • Device Information. We may collect and/or use third-party website analytics tools that collect information about visitor traffic on our Website and Apps, including IP address, unique personal identifiers, device ID, device type, browser and operating system type and mobile ad identifiers.
  • Location Information and Internet or other Network Activity Information. We also may use third-party website analytics tools, including cookies, web beacons and pixels, that collect information about visitor traffic on our Website and Apps. The types of automated information we may obtain using these tools include but are not limited to (i) search terms used to connect to our Website and search within our Website; (ii) dates and times of visits; (iii) page views and site navigation patterns; (iv) geolocation data; (v) links and URLs that refer visitors to our Website and Apps and (vi) other information regarding your interaction with our Website and Apps.
  • Customer Service Information. We collect the communications that we exchange with you through online forms, by email, over the phone or by post, and summaries or voice recordings of your interactions with our customer service team.
  • Inferences. Based on the Personal Information described above, we may make certain inferences regarding your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

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 to: (i) manage and maintain your account including your use of our registry and other wedding planning tools; (ii) process and track your purchases; (iii) contact you about your orders and your account, and contact individuals and entities (i.e. guests, couples, Vendors, and other Zola users, as well as vendors without Zola accounts) at your request and on your behalf; (iv) maintain a record of the purchases you make on our Website or Apps; (v) communicate with you about our Website, Apps, 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 Services, including our Website and Apps, as well as develop new products and offerings; (viii) send marketing communications, including email, and identify when emails sent to you have been received and track industry standard performance metrics, such as email opens and clicks; (ix) administer entries into sweepstakes, contests, promotions or surveys; (x) prevent fraud and unauthorized transactions and identify potential hackers and other unauthorized users; (xi) enforce our Terms of Use; (xii) comply with legal requirements, industry standards and our policies; and (xiii) otherwise provide our Services to you.

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.

HOW WE SHARE YOUR INFORMATION

We may share the Personal Information that you provide to us (which may include Personal Information within Match Data), and the information that we collect about you to support our business interests as described above, with others, such as (i) merchant partners so that they might provide 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 Website and Apps running and safe as well as make our Services available; (iii) third party applications such as social media applications that you use to log into our Website or Apps; (iv) analytics service providers to ensure site functionality and enable data-driven business decisions; (v) 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 or Apps, as well as other on websites and on social media networks; (vi) other Zola users (including Vendors) in order to make introductions or referrals as requested or directed by you; or (vii) as may be required in order to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our agreements or to protect our rights, property or safety or the rights, property or safety of our users or others. You may see certain of our 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 visits to our Website or Apps as well as pages you have viewed and the actions you have taken on our Website or Apps.

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, Apps 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.

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 our 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 our 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 our Website, but you will not be maximizing the value of our 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 Website's 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 that consumer uses our Website.
  • Zola's Matching Services. You may choose not to provide certain Personal Information as Match Data, but you agree and acknowledge that may restrict your ability to participate in our matching services or otherwise affect and limit the relevance of the potential Vendors that we match you with through Zola's matching services.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, under California law, including the California Consumer Privacy Act (CCPA), you have the rights outlined in this section. Please see the "Exercising Your Rights" section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@zola.com.

For purposes of exercising your rights below, please note the following regarding how we collect and use your Personal Information as described in this Privacy Policy:

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 service providers or other parties for business purposes: Personal Identifiers; Payment Information, Information you Submitted or Posted for purposes of our sharing with third parties, such as information needed to book your honeymoon or Match Data needed to match you with a Vendor; Commercial Information; Device Information; and Location Information and Internet or other Network Activity Information.

Based on our understanding of the term "sell" under the CCPA, we do not sell your Personal Information.

Access

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:

  • The categories of Personal Information that we have collected about you.
  • The categories of sources from which that Personal Information was collected.
  • The business or commercial purpose for collecting or selling your Personal Information.
  • The categories of third parties with whom we have shared your Personal Information.
  • The specific pieces of Personal Information that we have collected about you.

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.

Deletion

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 or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, 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, 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.

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 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.

NEVADA RESIDENTS

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 privacy@zola.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).

YOUR EUROPEAN PRIVACY RIGHTS

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.

In addition, where you believe that we have not complied with our obligations 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 privacy@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 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:

  • 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 Information until the issue is resolved;
  • Where we are required to retain the Personal Information for our legal, tax, audit, and accounting obligations, we will retain the necessary Personal Information 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, 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 privacy@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 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.

CHILDREN'S PRIVACY AND PARENTAL CONTROLS

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 privacy@zola.com.

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 our Website and/or our Apps 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 privacy@zola.com. You may also write us at:

Zola, Inc.
c/o Privacy Policy
7WTC
250 Greenwich St., 39th Floor
New York, NY 10007

LAST UPDATED

December 16, 2019