Zinnia CCPA Privacy Policy

Last Updated: October 1, 2024

This CCPA Privacy Policy provides additional information for California residents. These disclosures supplement any privacy notices we previously or contemporaneously provided to you, including any employee- or other California-specific notice(s). “We”, “our” or “us” as used in this privacy policy means Zinnia Corporate Holdings and its subsidiaries but does not include Policygenius LLC. For Policygenius Privacy Policy, please visit policygenius.com .

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), guarantees certain rights to all California residents regarding the ways in which their personal information is collected, used, and/or disclosed. This privacy policy does not apply to information we gather in relation to the provision of a financial product or services for personal, family, or household use. Likewise, it does not address our collection, use, and/or disclosure of aggregate, anonymized, or deidentified information that cannot reasonably be linked to a particular individual or household. We only maintain such data in deidentified form and will not attempt to reidentify it, except to test deidentification and ensure it cannot be associated with anyone.

The right to limit use and disclosure

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers, nor do we disclose it for purposes other than those specified in section 7027(m) of CCPA regulations. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

The right to opt out of sharing

In the past twelve months, we have used data about your activities on our online properties to serve you ads on third-party sites and apps, and we’ve shared the following categories of information to advertising networks, social media networks, tag management platforms, and video sharing platforms for the same purpose:

Personal identifiers
IP address and device information
Unique advertising identifiers and cookies
Geolocation information
Session replay
Web beacons (including pixel tags)
Inference data
Characteristics of protected classifications under California or federal law
Commercial information

You can opt out of sharing by going to our “Exercising your rights including the rights to opt out of sharing or sale” section and following the instructions there.

The right to opt out of sale

We do not sell personal information, and we have no actual knowledge of selling personal information or sensitive personal information of minors under 16 years of age.

The right to delete personal information

You have the right to request the deletion of your personal information, subject to certain exceptions.

The right to correct inaccurate personal information

You have the right to request the correction of any inaccurate personal information that we maintain about you.

The right to know or access

You have the right to know what categories of personal information we have collected about you, from what sources, for what purpose, and the categories of third parties to whom we disclose it, as well as the specific pieces of personal information we have collected about you.

The right of non-retaliation and non-discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment, and Zinnia does not retaliate or discriminate against you for exercising these rights.

Exercising your rights including the rights to opt out of sharing or sale.

To exercise your rights, such as the rights to opt out of sharing or sale, please click this link “Do Not Sell or Share My Personal Information”. If you would like to modify your cookie settings, activate your Global Privacy Control (GPC) preference setting in your internet browser . To learn more about the GPC, click here.

To exercise other rights, you or your authorized agent may contact us via email at privacy@zinnia.com

Please note that to opt out, we will need to verify your identity and residency, including your name, email address, and state of residence. We will compare the information you provide for verification against our internal records, but that information will not be used for any other purpose.

You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. Zinnia may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

Contact Information

If you have questions or concerns about our privacy practices, contact us via email at privacy@zinnia.com . You can also contact us at:

Zinnia Corporate Holdings, LLC

600 Steamboat Road

Greenwich, CT 06830

Attention: Privacy Team

DATA RETENTION

Category of personal information	Sources	Reason for collection	Who receives it		Retention period
Personal identifiers, including real name, alias, postal address, a unique personal identifier, an online identifier, IP address, email address, account name, Social Security number, driver’s license or passport number, or other similar identifiers	Directly from you; indirectly from you as you navigate or use our Services; advertising networks; internet or mobile service providers; employers; insurance companies; financial institutions; third-party administrators. Job applicants only: Recruiters; providers of background checks	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you. Job applicants only: Process your application; satisfy legal obligations	Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; payment processors; video sharing platforms Job applicants only: Providers of background checks and human resources software		The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer)
Any personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, Social Security number, physical characteristics or description, address, phone number, passport number, driver’s license or state ID card number, insurance policy number, education, employment, job history; bank account, credit card, or debit card numbers; or any other financial, medical, or health insurance information.	Directly from you; employers; insurance companies; financial institutions; third-party administrators. Job applicants only: Recruiters; providers of background checks	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you. Job applicants only: Process your application; satisfy legal obligations	Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; payment processors; video sharing platforms Job applicants only: Providers of background checks and human resources software		The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer)
Characteristics of protected classifications under California or federal law	Directly from you; indirectly from you as you navigate or use our Services; advertising networks; internet or mobile service providers; employers; insurance companies; financial institutions; third-party administrators. Job applicants only: Recruiters; providers of background checks	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you; meet our legal obligations	Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; video sharing platforms Job applicants only: Providers of background checks and human resources software		The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer)
Commercial information, including records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Directly from you; indirectly from you as you navigate or use our Services; advertising networks; internet or mobile service providers; employers; insurance companies; financial institutions; third-party administrators	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you; meet our legal obligations; maintain transaction records	Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; video sharing platforms		The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer)
Internet and other electronic network activity information, including but not limited to browsing history, search history, and information about individual interactions with a website, application, or ad	Indirectly from you as you navigate or use our Services; advertising networks; internet or mobile service providers	Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; verify, maintain, improve, upgrade, or enhance a service or device that is owned or controlled by us; identify and repair errors; advertise or market to you; perform analytics		Advertising networks; social networks; technology service providers; mobile application platforms; tag management platforms; video sharing platforms	Up to one year, barring any additional retention period required by law
Geolocation data	Indirectly from you; devices you use to access our Services; advertising networks; internet or mobile service providers	Protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you		Advertising networks; social networks; technology service providers; mobile application platforms; tag management platforms; video sharing platforms	Up to one year, barring any additional retention period required by law
Professional or employment-related information	Directly from you; employers; insurance companies; financial institutions; third-party administrators. Job applicants only: Directly from you; recruiters	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; advertise or market to you. Job applicants only: Process your application		Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; Job applicants only: Providers of background checks and human resources software	The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer) Non-hired job applicants only: Up to 3 year(s) after the end of your business relationship with us, barring any additional retention period required by law
Non-public education information	Job applicants only: Directly from you; recruiters	Job applicants only: Process your application		Job applicants only: Providers of background checks and human resources software	Non-hired job applicants only: Up to 3 year(s) after the end of your business relationship with us, barring any additional retention period required by law
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Indirectly from you; devices you use to access our Services; advertising networks; internet or mobile service providers.	Advertise or market to you; perform analytics; maintain, improve, upgrade, or enhance a product or service.		Affiliates; advertising networks; social networks; technology service providers; customer relationship management providers; mobile application platforms; tag management platforms; video sharing platforms.	We keep this in line with the need to satisfy our legitimate purposes, contractual and any legal obligations barring any additional retention period by law.

Category of sensitive personal information	Sources	Reason for collection	Who receives it	Retention period
Social Security, driver’s license, state ID card, and/or passport number	Job applicants only: Recruiters; providers of background checks	Job applicants only: Process your application; satisfy legal obligations	Job applicants only: Providers of background checks and human resources software	Barring any legally required additional retention period, up to 3 years for non-hired applicants.
Account access credentials combining user names, account numbers, or card numbers with required access/security code or password	Directly from you; indirectly from you as you navigate or use our Services; internet or mobile service providers	Provide you with our Services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors	Technology service providers	The length of your business relationship with us, plus a period of time afterward as defined by the law or by us (whichever is longer)