Online Privacy Policy

Effective Date: August 31, 2026

Thank you for visiting Zonia’s online and mobile resources and for viewing this Online Privacy Policy (the “Privacy Policy” or “Policy”). This Policy serves to give you notice about the types of personal information we collect, how we use it, and who we share it with and why. We describe these matters in detail in the pages that follow. We encourage you to read this Privacy Policy carefully.

The effective date on the Privacy Policy above indicates the date on which this Privacy Policy was last updated. The English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.

Please note that use of our online and mobile resources is also governed by our Terms and Conditions of Use (“Terms of Use”), which contain a class action waiver and mandatory arbitration clause governing all privacy related complaints and disputes except those falling under the Competent Data Protection Authority (defined in Section 11). We encourage you to read the Terms of Use carefully.

2. Some Important Vocabulary

This Privacy Policy is an important document that explains how we address some of our legal obligations, and your related legal rights, involving personal information. We’ll use this section to let you know about some words that have special meanings whenever you see them in this Statement. Wherever we say “Zonia,” “Company,” “we,” “us,” or “our,” we mean Magnific Group LLC d/b/a Zonia. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 13, or otherwise have verifiable parental consent to view this page. This age requirement is discussed in more detail later in this Policy here.

When we talk about our “online and mobile resources,” we mean our website found at www.zonia.com and its subdomains, and other pages that link to this Statement, as well as any applications, portals, or other features we operate to allow you to interact with us and our systems, including any mobile apps we’ve created and distributed to let you interact with the content we provide. An “affinity action” is when you “follow” us, “like” us, or take a similar or analogous action on our external social media presence.

Finally, when we refer to “personal information,” we mean any information, data or data element, whether in electronic or other form, that, alone or in combination with other elements, can be used to distinguish, trace, or discover your identity. Certain data privacy laws include specific elements or defined terms for what they consider to be personal information (sometimes also referred to as “personal data”). Where such data privacy laws apply, then the term “personal” includes the specific elements and defined terms required by such laws.

3. When and to Whom Does This Privacy Policy Apply?

Our online and mobile resources collect personal information from visitors to, and users of, our online and mobile resources. We may also receive personal information from users who interact with our ads and content displayed on third-party sites. This Policy applies to our processing and sharing of personal information collected by those means. If we have legal obligations to other categories of data subjects, such as our employees, supply chain or business partners, or vendors, we provide them with separate legally required notices or other terms in confidential contracts, policies, and other similar documents.

4. How Do We Collect Your Personal Information?

We collect and otherwise obtain your personal information in the following ways: (a) via our online and mobile resources when you choose to give it to us by voluntary submission; (b) via our online and mobile resources through automatic collection by technical means when you visit or use our online and mobile resources; and (c) when it is provided to us by external sources such as marketing companies, advertising companies, social media companies and/or companies that provide services on our behalf who, in each case, may have previously and separately collected elements of your personal information without our involvement and then shared it with us as part of a service for which we engaged that source.

Voluntary Submission.

Here are some ways you voluntarily give us your personal information:

• Creating Accounts – If you register for an account you will provide us your name and email address along with other identifiers.
• Making Purchases – You may provide information to us when it is needed to complete your purchase.
• Signing up for Newsletters – Similar to account creation, we collect some voluntarily submitted information if you sign up to receive a newsletter or other informational or marketing material we publish.
• Registering for Events – If we host or sponsor an event or program that you register for, you will be submitting certain identifiers such as name, email address, and postal address. If the event requires a fee, we may also ask you to submit credit card or other financial information.
• Sending Emails and Texts – If you choose to send us an email from our “Contact Us” link or a similar link, you will be giving us your email address and any other personal information that may be in your message or attached to it. The same is true if you send us a text message.
• Applying to Work with Us – If you apply to work with us, you may choose to submit your resume, cover letter, list of professional references, and other information. We will use this information to process your application. Once you apply to become a candidate for a position with Zonia, you will be provided with certain separate candidate notices governing you in your capacity as a candidate.
• Using Community Features – Our online and mobile resources may offer social media-like community features letting users post messages and comments, and/or upload image or other files and materials. If you choose to make use of these features, the information you post, including your screen name and any other personal information, will be in the public domain and may not be covered/protected by this Statement.
• Other Methods – Any other means by which you voluntarily submit personal information to us.

Your use of our online and mobile resources is strictly your choice. If you prefer that we not receive the above-described voluntarily submitted personal information, please don’t submit it. This means you shouldn’t participate in the applicable activities on, or use the applicable features available from, our online and mobile resources. By not participating in features that require voluntary submission of personal information, you may limit your ability to take full advantage of our online and mobile resources, but most of the content will still be available to you and we never discriminate on the basis of how much information you provide.

Automatic Collection.

When you visit or use our online and mobile resources, basic information about your internet/electronic activity is automatically collected through your browser and through the systems used to operate, secure, and support our online and mobile resources. In addition, we use cookies and other tracking technologies, which we describe in greater detail in our Cookie Policy. Those tools and/or cookies may collect some information about your preferences for using our online and mobile resources or past actions, such as:

• your IP address and rough location;
• the type of browser and operating system you use;
• the date and time and length of your visit;
• the pages visited, graphics viewed, and any documents downloaded; and
• links to other sites you accessed from our website or used to navigate to website.

If you access our online and mobile resources from a phone or other mobile device, the mobile services provider may transmit to us certain information such as uniquely identifiable mobile device information. That, in turn, allows us to collect mobile phone numbers and associate them with the mobile device identification information.

External Sources.

We may work with companies who provide us with data, including personal information, so that we can tailor our services to audiences who have the most interest. We also may work with digital advertising and marketing companies to provide you with ads that meet your interests and that enhance your experience with us. These ads may be displayed on websites or device applications operated by third parties. These third parties collect information with their own cookies, pixels, and related tracking technology and then provide that information to us. We are not responsible for their data collection practices.

Further, we maintain a presence on one or more external social media platforms such as Facebook, Instagram, TikTok, Threads, or YouTube. We may allow the community features of our online and mobile resources to connect with, or be viewable from, that external social media presence. Similarly, our online and mobile resources may contain connections or links to such social media platforms, or other websites or apps controlled by third parties. We are not responsible for either the content on, or the privacy practices of, social media platforms, or any third-party sites or apps to which we link. Those apps, sites, and platforms are not controlled by us and therefore have their own privacy policies and terms and conditions of use. To be clear: neither this Privacy Policy nor our Terms of Use apply to our social media presence or any third-party sites or apps to which we may link. That means even if you take an affinity action on our external social media presence, and identifiers about you are automatically collected and given to us as a result, that collection and transfer is governed by the privacy policies and other terms of the applicable social media platform and are not our responsibility.

If you have questions about how those apps, sites, and platforms collect and use personal information, you should carefully read their privacy policies and contact them using the information they provide. In addition, certain coalitions of advertisers allow consumers to opt out of receiving interest-based advertising from members of those coalitions. You can visit the Digital Advertising Alliance and Network Advertising Initiative to opt out of receiving interest-based advertising from members of these coalitions. You will need to exercise these opt-outs on each browser on each device for which you wish to opt out of interest-based advertising.

5. What Types of Personal Information Do We Collect?

The categories of personal information we have collected from visitors and users of our online and mobile resources in the previous 12 months, and may collect from you, are as follows:

• General Identifiers such as a real name, alias, online identifier, Internet Protocol address, date of birth, postal address, email address, account name, or other similar identifiers.
• Personal Information such as gender.
• Customer Record Information such as transaction details.
• Commercial Information such as products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Internet Activity Data or other similar electronic network activity information, such as content browsing history, chat transcripts, search history, and information regarding your interaction with our online and mobile resources or an advertisement regardless of device type used, be it a personal computer, cell phone or other mobile device.
• Geolocation Data including geographic coordinates/physical location.
• Audio/Visual Data such as recordings of customer service phone calls, profile or account photos, or videos or other electronic recordings.
• Analytics and Inference Data drawn using the above-described personal information to create a profile reflecting your interests and preferences or to otherwise improve our marketing strategies.
• Any Other Personal Information That You Voluntarily Provide to Us

Sensitive Personal Information.

We do not intentionally collect any “sensitive personal information,” “sensitive data,” or “special category personal data” as these terms are defined by applicable law.

Deidentified Information.

We may collect deidentified data and inferences derived from the categories of personal information described in this Statement. This data does not identify you in any way. We will not reidentify, or attempt to reidentify, any deidentified information that we collect as described in this Statement.

6. How Do We Use the Personal Information We Collect?

We use the personal information we collect only in the manner and through the means allowed by applicable law. That means we determine whether we have a lawful basis or legitimate business purpose to use your personal information before doing so. Generally speaking, we collect personal data from you where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, we use personal information for the following business purposes:

• Transaction Processing – processing, completing, and maintaining records of transactions.
• Performance of Contracts – fulfilling our duties and exercising our rights under contracts we may have with you or our vendors.
• Improving our Online and Mobile Resources – using information to operate, improve, test, and support features on our online and mobile resources.
• Promotions – providing personalized promotions and special offers.
• General Marketing – providing users with information about our brand, products, and events or programs we may participate in or sponsor.
• Tailored Marketing – providing users with marketing tailored to their interests.
• Improving our Products and Services – using your information to operate, improve, and support our products and services.
• Account Servicing – facilitating and servicing your account.
• Technical Security – monitoring our networks and detecting security incidents.
• Customer Service – responding to customer inquiries, including requests for information, online support, and phone calls.
• User Experience – internal research and analytics to improve user experience on our online and mobile resources.
• Knowing our Customers – understanding the demographics and interests of our online and mobile resources visitors.
• Debugging – debugging, identifying, and repairing errors that impair existing intended functionality of our online and mobile resources.
• Detecting and Preventing Unlawful Acts – protecting against malicious or illegal activity and prosecuting those responsible.
• Verification – verifying users, when necessary, and responding to user requests.

Retaining Your Personal Information.

We store and retain your personal information in accordance with applicable law and as long as necessary to carry out the purposes described above and in accordance with our internal data retention procedures. The criteria used to determine the retention periods include:

• how long the personal information is needed in connection with the purposes for which we use it;
• the type of personal information collected; and
• whether we are subject to a legal, contractual, or similar retention obligations (e.g., mandatory data retention laws, government orders to preserve personal information relevant to an investigation, or personal information that must be retained for the purposes of litigation or disputes).

7. When/With Whom Do We Disclose or Share Personal Information?

We may disclose the categories of personal information described in this Privacy Policy with the following categories of third parties for the business purposes described below:

• Corporate Affiliates – We may share personal information with our corporate affiliates who will use such information in the same way as we can under this Privacy Policy.
• Operations Support Vendors – We may share your personal information to vendors that help us to operate and increase the efficiency of our business and our online and mobile resources.
• Customer Support Vendors – We may share your personal information with vendors that provide customer support services, such as chatbot, phone, or email support.
• Promotional or Fulfillment Vendors – In order to carry out promotions we make available to you and/or deliver our products and services, we are required to share personal information with vendors who specialize in those activities.
• Software and Technology Vendors – Our various service providers may have access to or be provided with some of your personal information in connection with the tasks they perform on our behalf such as maintaining portions of our networks or the software applications that run on them. Some of our vendors may provide us with, or support their own services with, artificial intelligence tools.
• Transaction Support Vendors / Payment Processors – We share personal information with those of our vendors and business partners that process payments on our behalf and send you confirmations and administrative messages.
• Marketing and Advertising Providers – We may share your personal information with third parties, including social media networks, who support online advertising, data co-operatives, mobile advertising, data analytics, social media engagement, and other advertising networks that support our marketing efforts.
• Analytics Providers – We may share your personal information with third-party providers who assist us in analyzing our web traffic, some of whom are characterized as “marketing analytics companies,” such as Google Analytics.
• Security and Fraud Prevention Providers – We also may disclose personal information to third party security and fraud prevention providers when we have reason to believe that someone is causing injury to or interference with our rights or property or harming or potentially harming other persons or property.
• Law Enforcement or Government Agencies – We may disclose personal information to government agencies and authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion, or otherwise as required or permitted by law, including responding to court orders and subpoenas.
• Successors for Business Sale/Purchase – If we, or any of our affiliates, sell or transfer all or substantially all of our assets, equity interests, or securities, or are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, divestiture, consolidation, or liquidation, personal information may be one of the transferred assets.

Sharing or Selling Your Personal Information.

In some jurisdictions, our transfer of information to third-party providers for marketing and advertising purposes could be defined as “selling” personal information or “sharing” personal information for “cross-context behavioral advertising.” We may transfer the following categories of information to third parties for marketing and advertising purposes: (1) persistent identifiers, such as unique device identifiers, email addresses, account information, IP addresses, information related to your browser and operating system, or any information that you provided through our online and mobile resources; and (2) user activity data, such data generated through your activities on our online and mobile resources.

8. Do Not Track and Global Privacy Control

Certain browsers and plug-ins allow users to send signals such as Do Not Track (“DNT”) or Global Privacy Control (“GPC”). While we do not respond to DNT signals, we do honor GPC signals as a valid request to opt out of the sale or sharing of your personal information where required by applicable law.

When we receive a GPC signal, we will process it in the same manner as a request to opt out of any sale or sharing of your personal information that occurs via cookies or similar tracking technologies on our online and mobile resources. Please note that this opt-out mechanism applies only to the specific browser or device on which the signal is sent, and you may need to adjust your settings on each browser or device you use.

9. Children’s Privacy

U.S. federal law imposes special restrictions and obligations on website operators who direct their sites toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously and, consistent with them, do not intend for our online and mobile resources to be used by children under the age of thirteen nor do we knowingly collect personally identifiable information from children under the age of thirteen as part of our online and mobile resources. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information.

Because we do not collect any personally identifiable information from children under the age of thirteen as part of our online and mobile resources, we also do not knowingly distribute such information to third parties. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of our online and mobile resources, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of our online and mobile resources.

10. Your Privacy Choices; Unsubscribing

SMS Messaging.

We may use your telephone number to send you text messaging (“SMS”) for marketing purposes; to share free content with you, such as articles and videos; to provide access to your dashboard and/or downloads; to promote our products and services and those of our affiliates or third-party partners, and any of their related businesses, if you have opted in to receive such messaging. Your consent is not a condition of purchase. To the extent applicable, you expressly acknowledge that you are solely responsible for all charges billed by your mobile service provider.

Messaging will be sent by Twilio automated dialing system. Your information is stored at the list server that delivers our online and mobile resources content and messaging. Your information can only be accessed by those who help manage those lists in order to deliver messaging to those who would like to receive our materials. We do not share your telephone number with third parties for the purposes of receiving marketing messages directly from third parties. For additional information regarding our SMS messaging program please read our Terms of Use (https://zonia.com/terms_use), respond HELP to any of our messages, or email us at [email protected]. If you no longer wish to receive promotional text messages reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from us.

Email Messaging.

We strictly abide by our obligations to comply with anti-SPAM laws. All emails from us will have a clear “From” field that identifies us as the sender and will contain our address for contact purposes. Additionally, all emails that are sent to you by Zonia include an unsubscribe link. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you. When we receive your request we will remove you from our distribution lists, but it may take time to do so. You may still receive materials for a period of time after you unsubscribe. When you opt in to receive messages on our Masterclass page (zonia.com/masterclass and all its other variations), you agree to receive emails from Zonia, as well as our other brands. Therefore, if you wish to stop receiving messages from Zonia and our other brands, you will have to unsubscribe from each list separately.

Social Media.

Unsubscribing or changing affinity actions or other submissions or requests made on our external social media presence will likely require that you do so directly on that applicable social media platform as we do not control their procedures.

11. Comprehensive Privacy Laws

Privacy and data protection laws vary around the world and among individual states in the U.S. Our obligations arising under the majority of the world’s privacy laws, including U.S. federal and most state laws, are satisfied by individual risk assessments that we conduct to ensure we act reasonably and responsibly when processing your personal information.

In some jurisdictions privacy laws grant you certain specific rights regarding your personal information. We refer to these types of privacy laws as “Comprehensive Privacy Laws.” Examples of Comprehensive Privacy Laws include the respective versions of the General Data Protection Regulation adopted in the European Economic Area and the United Kingdom (collectively, “GDPR”) and California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (collectively, “CCPA”).

Whether and how a particular Comprehensive Privacy Law applies to us involves a complex assessment of factors such as the degree to which we direct our business at the residents of a particular jurisdiction and the volumes of personal information we collect from that jurisdiction. At this time, we believe that the nature, scope, and locations of our business activities make us subject to the GDPR and CCPA. For purposes of this section, the words “you” and “your” mean only those data subjects protected by the Comprehensive Data Privacy Laws we currently, or may later, determine apply to us (“Applicable Comprehensive Privacy Laws”).

Your Rights under Applicable Comprehensive Privacy Laws.

You have the following rights under Applicable Comprehensive Privacy Laws. It’s important to us that you know that if you exercise these rights, we will not discriminate against you by treating you differently from other data subjects who use our online and mobile resources but do not exercise their rights.

• Right to Know. You have the right to request that we disclose the personal information that we have collected about you and identify the purposes for which such information was used, whether and to whom it was shared, and what sources it was obtained from.
• Right to Delete. You have the right to request that we delete any personal information that we maintain about you, subject to certain exceptions.
• Right to Correct. You have the right to correct any personal information that we store about you.
• The Right to Opt Out of Your Personal Information Being Sold or Shared. You may opt out of us sharing or selling your information by contacting us at [email protected] or by visiting us at https://zonia.com/opt-out.
• Right to Opt Out of Targeted Advertising. You have the right to request that we opt you out of targeted advertising.
• Right to Opt Out of Profiling or Automated Decision Making. To the extent applicable, you have the right to not be subject to profiling or automated decision making in furtherance of decisions that produce legal or similarly significant effects.
• Right to Data Portability. You have the right to request that we provide you with a copy of your personal information on file with us.
• Right to Withdraw Consent from Processing. If we have collected and processed your information based on your consent, then you can withdraw your consent at any time.
• Right Not to Receive Discriminatory Treatment. Exercising your privacy rights under this Privacy Policy will not result in any discrimination by us. We will treat you the same as any other user.
• Right to Complain. You have the right to complain to the data protection authority identified in applicable Comprehensive Data Protection Law as having competent authority (the “Competent Data Protection Authority”).
• Right to Appeal. If you make a request to exercise any of the applicable personal information access rights as detailed herein and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing us at [email protected] with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your Competent Data Protection Authority as detailed below.
• Right to Object to Processing – the right to object to the processing of your personal information under the following circumstances:
  • Legitimate Interests - if the basis for which the processing occurs is in our legitimate interests or in the performance of a task carried out in the public interest. If you object, we will stop processing your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or we require the personal information to establish, exercise or defend a legal claim.
  • Direct Marketing – if the processing is for direct marketing purposes.

How to Exercise Your Rights under Applicable Comprehensive Privacy Laws.

In order for you or an agent you may designate to exercise any of the above rights, please contact us at [email protected] or visit our data subject request page. We will confirm our receipt in the time frames prescribed by Applicable Comprehensive Privacy Laws. We may, however, be prevented from acting on your request because Applicable Comprehensive Privacy Laws only allow us to act if we can verify your identity and/or your agent’s authority to make the request. You will also need to follow our instructions in this regard, which may include asking you to fill out a request form. The identity verification steps we use may vary depending on the sensitivity of the information and whether you have an account with us. If we are unable to verify your identity, we may deny your requests to know or delete. In addition, Applicable Comprehensive Privacy Laws place limits on how often you can exercise your right to know. We will advise you if you exceed these limits and explain to you what they are.

Lodging a Complaint.

If you think we failed to follow this Privacy Statement or otherwise violated Applicable Comprehensive Privacy Laws with respect to your specific personal information, those laws give you various rights to complain about, dispute, and seek remedies. Under the GDPR, you have the specific right to complain to your local Competent Data Protection Authority. Contact information for data protection authorities can be found here and here.

International Transfers.

We may disclose your personal information for the purposes described herein to recipients (including affiliates) located in countries outside of the European Economic Area (“EEA”) or the United Kingdom, including the United States, which may not have data protection laws equivalent to those in the EEA or the United Kingdom. We have entered into EU standard contractual clauses (“Model Contracts”) for transfers of personal information. Where we transfer personal information to recipients outside of the EEA or the United Kingdom we will enter into a Model Contract with the recipient or seek assurances from the recipient that another appropriate safeguard is in place to protect the personal data transferred. You can request further details in relation to international transfers, including a copy of the Model Contracts, by contacting us at [email protected].

The contact information for our EU representative is:

12. Changes To This Privacy Policy

We reserve the right to change or update this Privacy Policy from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the Privacy Policy in place at the time of collection. We will indicate the effective/amendment date at the beginning of this Privacy Policy.

13. Contacting Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at [email protected].