Privacy Policy

Effective: January 1, 2023

Last Updated: December 22, 2022

Zola, Inc., our subsidiaries and our affiliates (collectively, "Zola", "us", "we", or "our") respect your concerns about privacy. This privacy policy ("Privacy Policy") describes the types of Personal Information we collect, how we use it, who we share it with, how long we keep it and your rights and choices with respect to such Personal Information. By using the Website/Services, you agree to this Privacy Policy.

This Privacy Policy applies to our websites and/or mobile applications ("Website") and any other products or services offered by Zola (including, without limitation, our wedding registry and wedding website services, Vendor Marketplace, invitation and paper goods services, inspirational content platforms, wedding forum and community ("Community"), wedding planning tools) (the "Services") or other uses of our Services where this policy is linked or provided. This Privacy Policy is intended to be read together with our Terms of Use, and any capitalized terms used but not defined in this Privacy Policy will have the meaning given to them in the Terms of Use.

Zola is a data processor of information you provide regarding other individuals and entities (e.g., guests, couples, Vendors and other Zola users) and only acts on this information on your behalf (see our Terms of Use). Zola is a data controller of information you provide to access our Services, including making purchases. Zola is registered in the United States with an office at 7WTC, 250 Greenwich St., 39th Floor, New York, NY 10007. If you have questions or concerns regarding this Privacy Policy, you should contact Zola by emailing privacy@zola.com.

If you are a California resident, please see Section VI below entitled "Information for California Residents."

PRIVACY POLICY OVERVIEW

• I. WHAT PERSONAL INFORMATION DO WE COLLECT?
• II. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?
• III. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
• IV. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
• V. WHAT ARE YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION?
• VI. INFORMATION FOR CALIFORNIA RESIDENTS
• VII. OTHER IMPORTANT INFORMATION
• VIII. DATA SECURITY
• IX. CHILDREN'S INFORMATION
• X. CONTACT US

I. WHAT PERSONAL INFORMATION DO WE COLLECT?

"Personal Information" is any information that relates to or can be used to identify you. The categories of Personal Information we collect depend on how you interact with us and our Services, as well as the requirements of applicable law. For example, we may collect different information from you depending on which of our Services you use (e.g., our wedding registry services, wedding website and planning services, invitation and paper goods services, Vendor Marketplace, inspirational content platforms or Community) or the capacity in which you use our Services or visit our Website (e.g., as a couple, guest, Vendor or other Zola user). We collect Personal Information from the sources described below.

Information You Provide to Us. We collect information when you provide it to us directly, such as when you register for an account, place an order, submit photos, videos, comments, posts or other content to our Website, engage with Vendors, participate in a sweepstakes or promotion, contact our customer support team or otherwise communicate with us. This may include information about yourself or about others (such as your partner and/or wedding guests). By providing us with the Personal Information of another person, you represent that you have obtained permission from such person to share such information with us and for us to use such information as set forth in this Privacy Policy. The types of Personal Information we may collect directly from you include:

• Contact information, such as your name, your partner's name, email address, postal address (including billing and shipping addresses) and phone number;
• Account information, such as your username and password;
• Payment information, such as your payment type, bank account number, credit or debit card number, verification number and expiration date;
• Wedding registry details, such as your preferences about your registry and style; items you've added to your registry, personal notes you've added to any items on your registry (including your cash funds); standard order information about gifts purchased from your registry; if you register for a cash fund, 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);
• Wedding event details, such as your wedding date, wedding location, guest count, budget information and wedding hashtag;
• Communications that we exchange with you, including when you contact us through the Website or Services for customer support, via social media or otherwise;
• Visual and audio information, such as photos, videos and other information or user-generated content that you upload to our Website, provide via social media or otherwise provide in connection with using our Services, as well as associated metadata;
• Demographic information you voluntarily provide to us through surveys, such as information about your sexual orientation, marital status, education, income, racial or ethnic origin and/or profession (we only use this information for the purposes disclosed at the time you provide such information);
• Information you provide to us about your preferences (including criteria for potential Vendors and other Vendors (or non-Zola vendors) you are working with, colors, places, trends and styles, as well as photos, Vendors or other items that you add to your "favorites");
• Social media or other handles, such as your Venmo username if you choose to enable Venmo contributions to your registry's cash fund; and
• Other information you choose to provide, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information Collected by Automated Means. When you access and use our Services or visit our Website, we automatically collect certain information about you so that we can personally tailor your online experience and the advertising you receive from us, as well as to analyze and measure use of our Website. To collect this information, we use third-party website analytics tools, including cookies, web beacons and pixels (collectively, "Cookies"). The types of automated information we may obtain using these tools include:

• Online identifiers, such as your IP address, cookie IDs, mobile ad identifiers, device IDs and similar identifiers;
• Information about your browser, device or operating system;
• Web pages you view and links you click on our Website;
• Whether you open the emails we send, or whether you forward them or click through to our Website;
• Search terms used to connect to our Website and search within our Website;
• Dates and times of visits;
• Geolocation data;
• Links and URLs that refer visitors to our Website; and
• Other information regarding your interactions with our Website.

Information About Your Use of Our Services. We collect commercial information about the products and services you purchase (or consider purchasing) through the Services. This may include, for example, products you purchase from our Website, the number of drafts you create, edit or print when creating invitations or paper goods, and whether or not you connect with or book a Vendor through our Vendor Marketplace.

Information We Obtain from Third Parties. We may collect information from other third-party sources, including:

• Social Media or Other Accounts Connected to Our Services. If you provide your social media or other account credentials to us or otherwise sign into our Services through a third-party website or service, you understand some content and/or information in those accounts may be transmitted to us.
• Other Zola Users. We may receive your Personal Information from couples or other Zola users sharing information about others, such as their wedding guests, couples, Vendors or recipients of invitations or other paper products. For example, Vendors using our Vendor Marketplace may provide the Personal Information of Zola couples that were their clients and/or the Personal Information of fellow vendors, and couples may provide Personal Information of the vendors they booked outside of Zola in connection with their use of Vendor Marketplace.
• Other Unaffiliated Third Parties. We may also receive your Personal Information from certain other unaffiliated third parties. For example, we may receive your Personal Information from advertising networks, media monitoring companies and publicly available sources. 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").

II. HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

Unless we have your consent, we will only use the Personal Information we collect from and about you for the purposes described in this Privacy Policy and when applicable law allows or requires us to do so. We use your Personal Information for our business and commercial purposes, including to:

• Manage and maintain your account;
• Provide, evaluate and improve our Services, including our Website;
• Develop new products, offerings and content;
• Complete the transactions you request and maintain a record of these transactions;
• Communicate with you about your orders, your account and our Services, including allowing our customer support team to respond to your questions, inquiries, comments and suggestions;
• Contact certain individuals and entities (e.g., guests, couples, Vendors and other Zola users) at your request or on your behalf;
• Prevent fraud and unauthorized transactions and identify potential hackers and other unauthorized users;
• Debug, identify and repair errors that impair the existing intended functionality of our Services;
• Maintain a record of the Services you use on our Website and monitor and analyze trends, usage and activities in connection with our Website and Services;
• Enforce our Terms of Use and other policies;
• Comply with legal requirements, contractual obligations, industry standards, and other uses as anticipated within the context of our ongoing business relationship with you;
• Administer entries into sweepstakes, contests, promotions or surveys;
• Send marketing communications (including emails) about our Website, Services, offers and events, and identify when emails sent to you have been received;
• Track industry standard performance metrics, such as email opens and clicks;
• Identify you on the Website or across the Internet so that we can advertise our Services to you and personalize our ads to you;
• Tailor our Website to you and enhance your experience to include Services, features and offers that may be of particular interest to you;
• Make certain inferences regarding your preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities and aptitude;
• Use the Combined Information to enhance and personalize your experience with our Services, to communicate with you about Services and events that may be of interest to you, for other promotional purposes and for other purposes described in this Section; and
• Otherwise provide our Services to you.

III. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We may disclose the Personal Information that you provide to us and the information that we collect about you with:

• Vendors, Consultants and Service Providers acting on Zola's behalf to perform certain of the services described above. For example, we disclose certain information to (i) merchant partners to fulfill your orders, (ii) technical service providers to keep our Website running and safe, as well as make our Services available and (iii) analytics service providers to ensure site functionality and enable data-driven business decisions. We also disclose your information to our payment processors in order to complete your transaction(s) and process your payment(s). Please note that if you save your credit or debit card information to your Zola account, we store the last four digits of your card number, the expiration date and the billing address. If you save your bank account information to your Zola account, we store the last four digits of your bank account number as well as the name of your bank. Your bank account number and credit and debit card numbers are managed by our payment processors, and except as described above, we do not handle or store this data;
• Social Media and Other Applications that you use to log on to our Website or are otherwise connected to our Services;
• Other Zola Users (Including Vendors) with your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information. We may also provide certain information to Vendors that you have identified to us as having been booked or used by you so that these Vendors can understand which Zola couples have used their services; and
• Other Individuals or Entities as we believe to be necessary or appropriate (i) under applicable law, which may include laws outside your country of residence; (ii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (iii) to enforce our Terms of Use or other agreements; (iv) in the event we reorganize, sell, merge, transfer, assign or otherwise dispose all or a portion of our business or assets, and, in each case, any due diligence relating thereto; and (v) to protect our rights, privacy, safety, or property and/or that of you or others.

We also share your Personal Information with the following third parties that provide advertising-related services to us. These companies collect information from you via Cookies on our Website, as well as when we share your email address and other information with them directly.

• Social Media Platforms. In some cases, we disclose Personal Information to social media platforms in order to show you more relevant ads on those platforms and to support our advertising and marketing efforts.
• Marketing and Advertising Partners. Our marketing and advertising partners may send you marketing communications, serve you ads tailored to your interests, or tailor ads that may be served to you on our Website, as well as on other websites and on social media networks.
• Third-Party Data Providers. 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 Services that may be of interest to you. In order to determine what 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.
• Ad Networks. You may see 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. The ad networks use this information to show you advertisements that are tailored to your individual interests. The information that our ad network vendors collect includes information about your visits to our Website and other websites, as well as pages you have viewed and the actions you have taken on our Website.

We may also de-identify, anonymize or aggregate your Personal Information so that it is no longer identifiable. We may disclose this information to the individuals or entities listed above to improve our Services and for business, educational and administrative purposes. Similarly, we may permit service providers and third parties to retain certain information in a de-identified, anonymized or aggregated format for their internal purposes, such as research and development and improvement of their services.

Please be aware that any information (including images, the name of your partner, your wedding location and your wedding date) 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. Additionally, any information that you post on Community will be publicly available, even if you delete or deactivate your Zola account.

IV. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will retain your Personal Information for as long as we reasonably consider it necessary to achieve the purposes described in this Privacy Policy, or for as long as we are required or permitted to retain it under applicable law (including to satisfy our legal, accounting or reporting obligations). To determine the appropriate retention period for Personal Information, we may consider factors such as the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and the applicable legal requirements.

V. WHAT ARE YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION?

We offer you choices about the collection, use and sharing of your Personal Information.

• Opt-out of Marketing Communications. You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails or by updating your preferences in your account settings. You may also change your email address for receipt of such communications in your account settings.
• Restricting 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. Please note that most opt-out mechanisms (including browser-based signals) 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.
• Opt-out of Google Analytics. If you do not want Google Analytics 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 we use, you can still use certain aspects of our Website, but you may not be able to take full advantage of all of our Website's features.

If you are resident of certain states in the U.S., you may also have the following rights regarding your Personal Information (each of which are subject to various exceptions and limitations):

• Right to Opt-out of Targeted Advertising and Sale/Sharing of Information for Interest-Based Advertising. As we described above, we share your Personal Information with third-party partners who provide advertising and marketing services to us. If you would like to exercise your right to opt-out of targeted advertising, as well as the sale/sharing of your Personal Information, please fill out our Opt-Out Request Form.
• Some browsers offer you the ability to opt out of Cookie-based and other online tracking, which may be considered a "sale" or "sharing" of your Personal Information. At this time, we endeavor to respond to browser-based opt-out signals sent through the Global Privacy Control: https://globalprivacycontrol.org/. We do not respond to do not track or other browser-based signals.
• Right to Access Your Personal Information. You can request, up to two times every 12 months, that we provide you with a copy of the specific pieces of Personal Information we have collected about you.
• Right to Request Correction or Deletion of Your Personal Information. You can request that we correct or delete the Personal Information we have collected about you, subject to certain exceptions permitted under applicable law.
• Right Not to Receive Discriminatory Treatment. You will not be discriminated against for exercising any of the above rights. However, please keep in mind that some of our Services cannot be provided if we do not have your Personal Information.

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 you.

You or your Authorized Agent may submit a Valid Request using the following methods:

• Fill out our Privacy Request Form (for requests relating to deletion, access or correction)
• Fill out our Opt-Out Request Form (for requests relating to opt-outs of targeted advertising and sale/sharing of information for interest-based advertising)
• Call us at: 1-833-756-1251

VI. INFORMATION FOR CALIFORNIA RESIDENTS

The information below is the information we are required to provide to California residents when we collect their Personal Information. You can find more information about (i) the Personal Information we collect and the sources of that information in the "What Information Do We Collect?" section of this Privacy Policy, (ii) the business and commercial purposes for collecting that information in the "How Do We Use The Personal Information That We Collect?" section of this Privacy Policy and (iii) the categories of third parties to whom we disclose that information in the "Who Do We Disclose Your Personal Information To?" section of this Privacy Policy.

What Category of Personal Information is Collected?	How Do We Use This Personal Information?	Do We Sell or Share This Personal Information With Third Party Advertising Partners?
Personal Identifiers	Provide and improve our Services Manage and maintain your account Process and track your purchases Connect you with Vendors in our Vendor Marketplace Respond to your questions and otherwise communicate with you Prevent fraud and comply with our legal obligations Advertise and market the Services	Yes.
Online Identifiers, Internet Activity Information and Location Information	Help us recognize you on our Website and customize your experience Advertise and market our Services	Yes.
Audio/Visual Information	Improve your customer service experience and create a record of your requests and other interactions with us Provide the Website and Services to you	No.
Demographic Information	Help us to analyze, evaluate and improve the Services	No.
Payment Information	Process your payments	No.
Commercial Information and Inferences	Understand more about you and your preferences so that we can improve and customize our Services for you Advertise and market the Services	Yes.
Other Information You Submit or Post	Provide our Services to you Improve our Services	No.

Data Retention. We will retain the categories of Personal Information set forth in the table above for as long as we reasonably consider it necessary to achieve the purposes described in this Privacy Policy, or for as long as we are required or permitted to retain it under applicable law (including to satisfy our legal, accounting or reporting obligations). For example, recordings of customer support calls will be retained for two (2) years. For more information about the factors we use to determine the appropriate retention period for your Personal Information, please see the "How Long Do We Keep Your Personal Information" section of this Privacy Policy.

Notice of Financial Incentive. We may also offer you coupons, discounts or other promotions from time to time, such as when you provide us with your email address or phone number and agree to receive marketing communications in exchange for a discount. Such offers may not be available at all times. The amount and terms of such offers will be presented to you at the time of the offer. You can terminate your participation in these offers using the rights described in this Privacy Policy. Our good faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

VII. OTHER IMPORTANT INFORMATION

Notice of Changes. If we decide to change this Privacy Policy, we will post the revised Privacy Policy here. If we make any material changes to the Privacy Policy, we will notify you either through the Website or Services or by email. Your continued use of our Website and/or Services indicates your consent to the Privacy Policy as posted.

Third-Party Sites and Services. The Website and Services may link to other websites or services that are owned and controlled by third parties. These third-party sites and services may have their own privacy policies, which you should review. We are not responsible for the terms or policies of websites or services that we do not own or control. The inclusion of a link on the Website does not imply Zola's endorsement of the linked site or service.

Jurisdictional Issues. Zola is a U.S. company. Our Website/Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. Information about you may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Website/Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

VIII. DATA SECURITY

We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of information transmitted to us. To protect the information delivered to us electronically, our Website uses Transport Layer Security (TLS). TLS encrypts your payment information, name and postal address so only 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 information, 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 create a strong password that is unique to Zola, 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.

IX. CHILDREN'S INFORMATION

We do not solicit or knowingly collect any Personal Information from children under the age of 18, and do not knowingly sell or share the Personal Information of anyone under the age of 16. If you are not 18 or older, you are not authorized to use our Website or Services. 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 such 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.

X. 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 Team
7WTC
250 Greenwich St., 39th Floor
New York, NY 10007