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.
We collect your Personal Information from:
You may visit our Website or use our Apps without providing any Personal Information, although we will collect certain analytics information discussed below.
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:
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.
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.
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.
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:
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.
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).
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.
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 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.
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.
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 privacy@zola.com.
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.
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
December 16, 2019