Zywave Website Privacy Addendum for California Residents

Effective Date: July 31, 2025

Introduction

This Website Privacy Addendum for California Residents (the “California Privacy Addendum“) supplements the information contained in Zywave’s (“Zywave,” “we,” or “us“) Privacy Statement and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies to all (i) visitors, users of our website and (ii) employees, owners, directors, officers, or independent contractors of another company, partnership, sole proprietorship, non-profit, or government agency who reside in the State of California (collectively, “California Residents” or “you“). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA“) and any terms defined in the CCPA have the same meaning when used in this notice.

Scope of this California Privacy Addendum

This California Privacy Addendum applies to information that we collect on our Website and when you use our products or services that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information“). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CCPA) are not considered Personal Information and this California Privacy Addendum does not apply to such information.

In general, Zywave acts as a service provider on behalf of our customers, including where we offer to our customers various products and services through which our customers (or us on their behalf): (i) manage and request information in regard to health benefit plans and technology solutions for the insurance industry; (ii) sell or offer their own products, services and health benefit plan solutions; (iii) send electronic communications to other individuals; or (iv) otherwise collect, use, share, or process personal information via our products and services. To this end, if not stated otherwise in this California Privacy Addendum, our Privacy Statement, or in a separate disclosure, we are a processor and process your Personal Information in the role of a vendor, business associate, or service provider on behalf of a customer (and/or its affiliates) who is the responsible business for your Personal Information. When acting as a vendor, business associate, or service provider, we will only collect, use, and otherwise process your Personal Information as directed by our customers and as otherwise permitted by the CCPA and applicable law.

If your data has been submitted to us by or on behalf of a Zywave customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the Zywave customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe. For detailed privacy information related to our collection and use of your data on behalf of a Zywave customer who uses our products and services, please reach out to the respective customer directly. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this California Addendum and our Privacy Statement.

Further, this California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals (“Personnel“). Please contact your local human resources department if you are part of our California Personnel and would like additional information about how we process your Personal Information.

This California Privacy Addendum also does not apply to certain Personal Information that is excluded from the scope of the CCPA, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Information We Collect About You and How We Collect It

We collect, and over the prior twelve (12) months have collected, the following categories of Personal Information about California Residents:

We will not collect additional categories of Personal Information without providing you notice. As further described in To Whom Do We Sell or Share Your Personal Information, we may “sell” any categories of Personal Information for monetary or other valuable consideration and we may “share” any categories of Personal Information for cross-context behavioral advertising.

Sources of Personal Information

We collect Personal Information about you from the sources described in our Privacy Statement.

Purposes for Our Collection of Your Personal Information

We only use your Personal Information for the purposes described in our Privacy Statement.

We may use, “sell” for monetary or other valuable consideration, “share” for the purposes of cross-context behavioral advertising, or disclose the Personal Information we collect for the purposes described in our Privacy Statement. Over the prior twelve (12) months, we have used, “sold” for monetary or other valuable consideration, shared for the purpose of cross-context behavioral advertising, or disclosed the Personal Information we have collected, for the purposes described in our Privacy Statement.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Third Parties to Whom We Disclose Your Personal Information for Business Purposes

We may disclose your Personal Information to third parties for one or more business purposes.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information: identifiers, personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, and professional or employment-related information. We have disclosed such information for one or more of the business purposes described below to the following categories of third parties: Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Zywave; social media companies; and Internet cookie information recipients, such as analytics and behavioral advertising services.

We disclose your Personal Information to the categories of third parties listed above for the following business or commercial purposes:

• Helping to ensure security and integrity of our products, services, and IT infrastructure to the extent the use of the Personal Information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us. Our agreements with third parties prohibit your Personal Information from disclosure to another third-party and from using your Personal Information to build a profile about the you or otherwise alter your experience outside your current interaction with us;
• Performing services on behalf of us, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us;
• Undertaking internal research for technological development and demonstration; and
• Providing advertising and marketing services, except for cross-context behavioral advertising, to Consumers.

In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to:

• comply with federal, state, or local laws, or to comply with a court order or subpoena to provide information;
• comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
• comply with certain government agency requests for emergency access to your Personal Information if you are at risk or danger of death or serious physical injury; or
• exercise or defend legal claims.

To Whom Do We Sell or Share Your Personal Information

“Sale” of Your Personal Information for Monetary or Other Valuable Consideration

As noted in our Privacy Statement, we do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of certain third-party advertising and analytics cookies on our Website is considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA to include both monetary and other valuable consideration. Using this broad definition, our “sale” is limited to our use of certain third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Website(s). Our “sales” of your Personal Information in this matter is subject to your right to opt-out of those sales (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information).

“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising

Zywave may “share” your Personal Information for the purpose of cross-context behavioral advertising, subject to your right to opt-out of that sharing (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information). Our “sharing” for the purpose of cross-context behavioral advertising is limited to our use of Personal Information and of third-party advertising cookies and tracking technologies to provide you with cross-context behavioral advertising (i.e., advertising on other websites or in other mediums). When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure a “sale” for monetary or other valuable consideration under the CCPA.

In the preceding twelve (12) months, Zywave has “sold” for valuable consideration, and “shared” for the purpose of cross-context behavioral advertising, the following categories of Personal Information: identifiers, personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, and professional or employment-related information, to the following categories of third parties: advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Zywave; social media companies; and Internet cookie information recipients, such as analytics and behavioral advertising services.

Sale or Sharing of Personal Information of Minors Under the Age of 16

We do not have any actual knowledge that we “sell” the Personal Information of minors under the age of 16 for monetary or other valuable consideration and we do not have any actual knowledge that we “share” such Personal Information for cross-context behavioral advertising without affirmative consent as required by the CCPA.

Consumer Data Requests

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CCPA Privacy Rights.

• Right to Know. You have the right to request that Zywave disclose certain information to you about our collection and use of your Personal Information over the past 12 months (a “Right to Know” Privacy Request). This includes: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which that Personal Information came from; (c) our purposes for collecting this Personal Information; (d) the categories of third parties with whom we have shared your Personal Information; and (e) if we have “sold” or “shared” or disclosed your Personal Information, a list of categories of third parties to whom we “sold” or “shared” your Personal Information, and a separate list of the categories of third parties to whom we disclosed your Personal Information to. You must specifically describe if you are making a Right to Know request or a Data Portability Request. If you would like to make both a Right to Know Privacy Request and a Data Portability Privacy Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Privacy Request a total of two (2) times within a 12-month period at no charge.
• Access to Specific Pieces of Information (Data Portability). You also have the right to request that Zywave provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third-party about you (a “Data Portability” Privacy Request). If you make a Data Portability Privacy Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Privacy Request and a Data Portability Privacy Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. In response to a Data Portability Privacy Request, we will not disclose your social security number, driver’s license number or other government-issued identification number, financial account number, or health insurance or medical identification number. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your Personal Information, your account with Zywave, or the security of our systems or networks. If we are unable to disclose certain pieces of your Personal Information, we will describe generally the types of personal information that we were unable to disclose and provide you a description of the reason we are unable to disclose it. You may make a Right to Know or a Data Portability Privacy Request a total of two (2) times within a 12-month period at no charge.
• Correction. You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may review and correct some Personal Information about yourself by logging into the Website and visiting your “Account” page. You may also request that we correct the Personal Information we have about you as described below under Exercising Your CCPA Privacy Rights. In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Information is subject to another exception under the CCPA.
• Deletion. You have the right to request that Zywave delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Privacy Request (see Exercising Your CCPA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the CCPA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it.
• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following as a result of you exercising your CCPA rights: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Privacy Rights

To exercise the rights described above, please submit a request (a “Privacy Request“) to us by emailing us at [email protected].

If you (or your Authorized Agent) submit a Privacy Request to delete your information online, we will use a two-step process in order to confirm that you want your Personal Information deleted. This process may include verifying your request through your email address on record / calling you on your phone number on record (which may include an automated dialer) / sending you a text message and requesting that you text us a confirmation / sending you a confirmation through US mail. By making a Privacy Request, you consent to us contacting you in one or more of these ways.

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Privacy Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Privacy Requests must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent of such a person.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

We will only use Personal Information provided in a Privacy Request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale or sharing opt-out rights, see Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by providing them with written authorization or with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent“). We may request that your Authorized Agent submit proof of identity and that they have been authorized to exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information

You have the right to direct us to not sell your Personal Information for monetary or other valuable consideration. You also have the right to direct us to not share your Personal Information for the purposes of cross-context behavioral advertising.

How You May Opt-Out of Our Sale or Sharing of Your Personal Information

To exercise the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and of “sharing” your Personal Information for the purposes of cross-context behavioral advertising, please visit our Do Not Sell or Share My Personal Information page.

Browser Privacy Control Signals

You may also exercise your right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and “sharing” your Personal Information for the purposes of cross-context behavioral advertising by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

• Global Privacy Control (for more information on how to configure your browser to send this signal, please see https://globalprivacycontrol.org).

When we receive one of these privacy control signals, we will opt you out of any further “sale” or “sharing” of your Personal Information when you interact with our Website through that browser and on that device.

Personal Information Retention Periods

Zywave will only retain your personal information for as long as is needed for the purpose(s) for which it was collected and other permitted purposes, including retention of personal information pursuant to any applicable contract, law or regulation. Our retention periods vary based on business, legal and regulatory needs.

Changes to This California Privacy Addendum

Zywave reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this California Privacy Addendum, the ways in which Zywave collects and uses your information described above and in the Privacy Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: