This California Privacy Notice (“Notice”) applies to California residents (also called "consumers" or "you") and supplements the information contained in ZS's Privacy Policy, Opinion Leader Notice, and, if you are a current, former, or prospective employee, the ZSer Privacy Notice.

Some terms in this Notice may have different meanings than they do in the Privacy Policy and ZSer Privacy Notice, and the meanings in this Notice reflect the definitions under the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”).

Personal information we collect

ZS may collect information that relates to a particular consumer or household ("personal information"). The following list displays the categories of data specified in the CCPA that ZS may have collected from some California residents within the last 12 months:

1. Identifiers such as name, address, online identifier, IP address, e-mail address, or other similar identifiers.
2. Any personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
3. Protected classification characteristics under California or federal law.
4. Commercial information, including records of products or services purchased.
5. Biometric information.
6. Internet or other similar network activity, including interaction with an Internet Website, application, or advertisement.
7. Geolocation data.
8. Sensory data.
9. Professional or employment-related information.
10. Education information (as defined by FERPA, 20 U.S.C. §1232g, 34 C.F.R. Part 99).
11. Sensitive Personal Information.
12. Inferences drawn from any of the information listed above.

Personal information does not include publicly available information from government records or information that you make available to the general public, de-identified or aggregated consumer information, or information excluded from the CCPA's scope, such as information covered by HIPAA, CMIA, or FCRA.

Personal information sources

ZS obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you apply for a job with us, from forms you complete, or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website, from our clients, or from other data sources such as social networks, data analytics providers, government entities, and data brokers, as well as sources such as recruiters and job search or employment Websites.

Use and retention of personal information

We may use, disclose, sell, or share the personal information listed above for one or more of the following purposes:

• To provide you with information or services you request.
• To provide services to our clients.
• To provide, support, personalize, and develop our Website, products, and services and well as for testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To personalize your Website experience and to deliver content or offerings relevant to your interests, including targeted ads through third-party sites, or via e-mail (with your consent, where required by law).
• To help maintain the security of our Website, products and services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ZS's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ZS is among the assets transferred.
• Employment purposes (including to process your job application)

ZS will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

ZS does not retain personal information for longer than is reasonably necessary for the purposes described in this notice. When we are processing your personal information, we retain that information in accordance with applicable contracts, regulatory, and legal obligations or as otherwise permitted by law.

Disclosure of personal information

ZS may disclose your personal information to a third party for a business purpose or sell or share your personal information for a commercial purpose, subject to your right to opt-out of such sharing.

We may disclose your personal information with the following categories of third parties:

• Our service providers and vendors.
• Our clients, including pharmaceutical companies.
• Our affiliates within the ZS group of companies.

In the preceding 12 months, ZS has disclosed the following categories of personal information for a business purpose:

1. Identifiers.
2. California Customer Records personal information categories.
3. Protected classification characteristics under California or federal law.
4. Commercial information.
5. Internet or other similar network activity.
6. Professional or employment-related information.
7. Sensitive information.
8. Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our service providers and vendors.
• Our clients when ZS is acting as a service provider.
• Our affiliates within the ZS group of companies.

In the preceding 12 months, ZS has sold or shared the following categories of personal information for commercial purposes:

1. Identifiers.
2. California Customer Records personal information categories.
3. Commercial information.
4. Professional or employment-related information.
5. Sensitive information.
6. Inferences drawn from other personal information.

We sell or share your personal information for commercial purposes to the following categories of third parties:

• Our clients, including pharmaceutical companies.

Your rights and choices

You may have the right to request that ZS disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purposes for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you.

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Delete: You may have the right to request that ZS delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Correct: You have the right to request we correct or amend the personal information we process.

Right to Opt-Out: You may have the right to direct us to not sell or share your personal information at any time. We do not sell or share the personal information of consumers we actually know are less than 16 years of age.

Right to Limit the Use of Your Sensitive Personal Information: Subject to certain exceptions, you have the right to limit the use of your sensitive personal information.

Right to Nondiscrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights.

Exercising your data rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

• Visiting the ZS Privacy Request Tool
• E-mailing us at dataprivacy@zs.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• 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 the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request and to review and comply with the request.

Changes

ZS reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

California Privacy Rights metrics

As required by California law, we are providing the below metrics that represent the data subject requests ZS received in 2024 from California residents. All requests in 2024 were denied because ZS did not hold or process any requester’s personal information.

Contact us

If you have any questions or comments about this notice, the ways in which ZS collects and uses your information described in this notice and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Website: https://www.zs.com/california-privacy-notice
E-mail: dataprivacy@zs.com
Postal Address:
ZS Associates, Inc.
Attn: Data Protection Team
222 Merchandise Mart Plaza Ste. 230
Chicago, IL 60654

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