PRIVACY POLICY

We strongly feel that personal information you share with us is strictly for business between us. Zinnia will not disclose your personal information to unaffiliated third parties for promotional and marketing purposes.

This policy governs Zinnia's use of non-public personal customer information. Non-public personal information is defined in applicable law and generally means information that is identified with you and is not obtainable from a public source.

OBTAINING PERSONAL CUSTOMER INFORMATION
We obtain personal customer information primarily from you (for example when you subscribe to Zinnia services or fill in online survey forms on Zinnia's website). Such information may also be obtained from other sources (for example, from a mailing list for marketing purposes). If we are unable to obtain such information, we will not be able to provide you services consistent with Zinnia Service Agreement. We also maintain personal customer information resulting from your business transactions with Zinnia.

USING PERSONAL INFORMATION
We use your personal information only for legitimate business purposes in compliance with applicable laws and regulations. The following summarizes the principal ways in which such information is used.

USE WITHIN ZINNIA AND ITS AFFILIATED COMPANIES
Safeguarding your personal information is important at Zinnia. We maintain systems, policies and procedures to protect your personal information from being accessed by unauthorized persons. We limit employee access to personal customer information to those with a legitimate need to know such information.

Within Zinnia and its affiliated companies, Zinnia may use your non-public personal information:

• To protect the security of your account: For example, your personal information is used for identification purposes and to prevent unauthorized persons from accessing your accounts.

• To conduct business in a safe and sound manner: For example, Zinnia will use your personal information to contact you if it discovers any problems with your account.

• To help determine which products and services may best serve your needs.

USE WITH UNAFFILIATED THIRD PARTIES
Zinnia will not disclose your personal information to unaffiliated third parties for promotional and marketing purposes.

Zinnia and its affiliated companies will sometimes disclose your personal information to companies or entities unaffiliated with Zinnia. This might occur in the following circumstances:

• Credit Reporting Agencies: Zinnia may disclose information relating to its experience with you to credit reporting agencies and similar organizations.

• Written consent: Zinnia may disclose your personal information with your written consent, including when you give someone power of attorney or other authorization to act on your behalf.

• Business Transfers: Zinnia may disclose your personal information in connection with a proposed or actual transfer of accounts or a line of business to another company.

• Zinnia may disclose your personal information to protect your accounts against fraud and unauthorized transactions, to resolve customer disputes, and, as necessary, to Zinnia's attorneys, accountants, and auditors