California Labor Law - Floating Holidays

This is a minor issue and not a hill I'm going to die on, but I work for a private company that has its head office in Florida. I live and work in California.

As part of a job renegotiation, my manager offered an additional two floating holidays per year. I have this in writing. HR then said several months later that company policy is that I can only access those additional floating holidays when I have used all my vacation. If I don't use all my vacation first then I can't use those two days, and I lose them at the end of the year as they don't accrue.

I have in writing from my manager that when they made me the offer they were also under the impression I did not have to use my vacation before these additional two days. All employees are entitled to a floating holiday that we can use whenever we want throughout the year: the understanding was that these additional two days would be the same.

I asked HR where the company policy is documented as it is not in the employee handbook. HR ignored this request.

Also, I understand in California that floating holidays must legally accrue unless they are tied to a particular date, such as "you get your birthday off". I am wondering if my employer gets around this as they are headquartered in a different state.

Any insight would be appreciated. Just always like to be informed!