Zelle® App Privacy Policy

Zelle® App Privacy Notice

Updated: April 22, 2022

This Privacy Notice applies to users of the Zelle^®app. If you use Zelle^®through your mobile banking app or online banking, please refer to your financial institution’s privacy notice.

As a visitor to our website, zellepay.com, our Website Privacy Notice also applies. Click here to learn more.

Thank you for using Zelle^®. We take your privacy seriously and we want you to be fully informed about how you can be in control of your personal information.

This Privacy Notice applies to the Zelle^® app (referred to as the “App” from here on out). It describes the personal information we collect, how it’s used and shared, and the choices you can make. We strive for transparency but if anything remains unclear, do not hesitate to contact us at the email address below with any questions or feedback you may have.

To make this Privacy Notice easy to find, we make it available through the App and on the zellepay.com website. You may also call 844.212.9102 (Monday through Friday, 8am to 5pm ET, excluding New Year’s Day, Thanksgiving, and Christmas) to request a copy by US mail.

By using the Zelle^® app, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Notice. In other words, please do not use the App if you do not agree with our Privacy Notice.

What do you want to learn more about?

Zelle® App Privacy Notice

1. When this Privacy Notice applies

This Privacy Notice applies to the Zelle^® app (referred to as the “App” from here on out).

If you use Zelle^® through your mobile banking app or online banking, please refer to your financial institution’s privacy notice.

As a visitor to our website, zellepay.com, our Website Privacy Notice also applies. Please click here to learn more.

2. What personal information is

“Personal information” means information that identifies or can be used to identify you directly or indirectly. Examples of personal information include, but are not limited to, first and last name, email address, telephone number, IP address, device information, bank account information.

3. Personal information we’ve collected and shared

If you’ve used the App in the past 12 months, we may have collected, used and/or shared the following categories of personal information about you for a business purpose(s):

Categories of personal information we’ve collected in the last 12 months:	Categories of sources from which information is collected:	Business purpose(s) for collection, use, and sharing:	Shared for business purpose(s) to the following categories of third parties:	Sold to the following categories of third parties:
Personal and online identifiers (e.g., name, email address, postal address, IP address or unique identifiers)	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None
Certain personal information (e.g., address, telephone number, financial account numbers, other financial information)	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None
Transaction information (e.g., records of transactions made through Zelle® when you use the App)	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None
Internet or other electronic network activity information (e.g., your interactions with the App)	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None
Geolocation information	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None
Other information about you that is linked to the personal information above (e.g., information you associate with your Zelle® profile like a profile photo or your contact/recipient list, call recordings if you call Zelle Customer Support)	All categories listed below in Section 4.	All purposes listed below in Section 5.	All categories listed below in Section 6.	None

4. How we collect personal information

When you use the App, we collect personal information from:

you directly when you provide it (e.g., when you enroll in the App, you provide your information to us);
your device (e.g., your mobile device shares your Unique Device ID and name of your device when you use the App);
our bank and credit union partners (e.g., when you receive money from one of their customers, they share information with us about the transaction); and
our service providers (e.g., we use service providers to help us verify your identity when you enroll in the App).

5. How we use personal information

When you use the App, we collect, use, and share personal information for the following business reasons:

to prevent, detect, and protect against security incidents, fraud, and prohibited or illegal activities;
to perform services (for us or our service providers) such as account servicing, providing customer service, fulfilling transactions, verifying consumer information, providing analytic services;
for internal research for technological improvement;
for internal operations;
to verify the existence of your financial account;
to enforce our terms and conditions;
to research and resolve issues related to transactions you sent or received;
to debug, identify and repair errors that impair existing intended functionality;
to facilitate transactions, including enabling our bank and credit union partners to complete money transfers between their customers and you;
to notify you by push notification, text or email, of a pending money transfer or a request for payment;
to facilitate your enrollment and resolve issues relating to your enrollment;
to verify your identity;
to verify changes you’ve made to your personal information;
to create and deliver marketing communications to you about Zelle^®;
to create, develop, operate, deliver, maintain, and improve our products and services;
for legal compliance;
to respond to your requests and comply with your stated communication preferences;
to provide you with a safe, efficient, and customized experience;
for authentication;
to provide other services you request; and
for other one-time uses.

6. Who we share personal information with

We may share personal information with the following categories of third parties for the business purposes we described above in Section 5.

other Zelle^®users (e.g., When another user sends you a payment, we may share your name (from your Zelle^® profile) and profile picture (if you have one) with the other user to ensure the other user intends to send a payment to you. We do not share your bank account information/debit card information with other Zelle^®users.);
the Early Warning Services, LLC corporate family (Early Warning is the parent company of Zelle^®);
our bank and credit union partners (e.g. when you send or receive money using the App, we share information with them to facilitate the transaction);
our service providers (e.g., companies that help us provide the Zelle^®service);
law enforcement, government agencies, and other authorized third parties (we may be required by law to share information);
new owners (in the event we plan to merge with or be acquired by that business entity);and
other entities with your consent.

7. Minors’ privacy

The Zelle Network® User Service Agreement defines eligibility requirements to use the App.

Our App is not intended for children under the age of 13. It does not knowingly collect personal information from children. We do not sell personal information collected from the App. Therefore, we would not sell information about minors.

For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.

8. Your choices

You can control how and when you want to receive notifications from us by following the instructions within the notices you receive from us and by updating your preferences in the App.

To opt out of marketing communications from us about Zelle^®, use the options in the communications we send (i.e. click on the unsubscribe link) or send an email request to requestoptout@earlywarning.com.

You may not opt-out of administrative emails (e.g., emails about your transactions or policy changes) for your enrolled profile.

You may request to cancel your profile and enrollment with Zelle^® by speaking to a customer service representative at 844.428.8542 (10am to 10pm EST, excluding New Year’s Day, Thanksgiving and Christmas). If you use the Zelle^® app on an iOS device, you may also close your profile by selecting “Delete Account” in the app settings on your device. However, doing so will immediately terminate your ability to use the service. Please note that simply deleting the app from your device without selecting “Delete Account” (via the app’s settings) will not result in your Zelle^®profile being closed and deleted. If you only delete the app from your device, (without changing the app’s settings) you will remain a registered user and Zelle^®will retain your data per our data retention policies.

9. Updating your personal information

You can update your personal information at any time by accessing your profile in the App. You can update your User profile and registration information, including your debit card information and email addresses.

If your mobile telephone number has changed, you will need to call customer service for assistance with your profile. Customer service representatives can be reached at 844.428.8542 (7 days a week from 10am-10pm EST, excluding New Year’s Day, Thanksgiving and Christmas).

Keeping your profile information up-to-date is very important. If this information is incomplete, inaccurate, or not current, please update your information by accessing your profile in the App.

10. Your rights regarding your personal information

We provide the Zelle^® service pursuant to the Graham-Leach-Bliley Act (“GLBA”) and are exempted from certain privacy and data security laws. Even so, we honor your data privacy rights, regardless of whether we are obligated by law and regardless of your state of residence.

You have the right to request a list of what personal information (if any) we’ve shared with third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.
- We do not share personal information with third parties for their own direct marketing purposes. Therefore, we have not shared personal information with third parties for direct marketing purposes within the last 12 months.
You have the right to know the categories and specific pieces of personal information we collect, use, share, and sell about you, our business purposes for collecting personal information, the categories of third parties that we’ve shared personal information with, the categories of sources that we’ve collected personal information from, whether we’ve shared or sold personal information for a business purpose in the preceding 12 months, and the categories of third parties with which we’ve shared or sold personal information.
- In the past 12 months, we have not shared personal information from the App in a manner that we consider a “sale.” For purposes of this Privacy Notice, “sale” means the disclosure of personal information to a third-party for monetary or other valuable consideration.
You have the right to request that we delete your personal information.
- If you use the Zelle^® app on an iOS device, you may request to delete your data and close your profile by selecting “Delete Account” in the app’s settings. However, doing so will immediately terminate your ability to use the service.
- Note: Under certain circumstances, we may not be able to delete your information because we have a legal obligation or other reason that we must retain it.
You have the right to opt out of the sale of your personal information.
- As stated above, we do not sell personal information that we’ve collected from the App.
You have the right to be free from discrimination for exercising your privacy rights.
- We will not discriminate against you for exercising your choices and rights.
You have the right to access your personal information that we’ve collected about you in the proceeding 12 months following your request

Please note the above-listed rights are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us or the security of our systems or networks. We may decline your request if we cannot verify your identity or confirm the personal information that we maintain belongs to you. If we cannot honor your request, we will let you know

11. How to exercise your data privacy rights

Please submit your request and the required verifying information by either:

Clicking here to submit your request online using your Zelle® login credentials; or
Calling us at 844.212.9102 (Monday – Friday from 10am-5pm ET, excluding Thanksgiving, Christmas Day, and New Year’s Day).

We will acknowledge receipt of your request and let you know how long we expect it will take us to complete your request (typically 45 days or less).

12. How we verify your request

For requests made online, at a minimum, your identity will be verified through your existing Zelle® password protected account and a One-Time Password (OTP) secure authorization.

For requests made by phone, at a minimum, your identity will be verified by matching certain personal information provided by you with personal information maintained by us. We may use a third-party identity verification service to assist us with verifying your identity.

We may need to request additional information from you to verify your identity or to understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.

13. Authorized agents

You may designate an authorized agent to make a request on your behalf. Your authorized agent will be required to produce a signed authorization from you and additional identity verification may be required. Authorized agent requests may be made by phone at 844.212.9102 (Monday – Friday from 10am-5pm ET, excluding Thanksgiving, Christmas Day, and New Year’s Day).

14. Our data retention practices

We generally retain information for as long as it is necessary and relevant for our operations and to comply with applicable law.

15. Links to third-party websites

Our App may contain links to other third-party websites, such as links to our bank and credit union partners’ websites. When you leave our App and visit those websites, you are bound by the privacy policies of those websites. We are not responsible for the privacy practices of these third-party websites, which are governed by their own privacy policies and practices.

16. How we protect personal information

To help us protect your personal information, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. Additionally, we use security features that are built into the hardware and software of your device to help protect your transactions, such as facial or fingerprint recognition. We do not collect or store your biometric verification information when you use the App.

It is your responsibility to make sure that your personal information is accurate and that your password(s) and profile registration information are secure and not shared with third-parties.

17. Where personal information is stored

We are located in the United States. Our services are available for eligible United States users only. Our operations use a network of computers, cloud-based services, and other infrastructure and information technology that are based in the United States. Additionally, we may use third-party service providers that may be located in and process or store your personal information in the United States, the European Union, and other countries.

18. Changes to this Privacy Notice

From time to time, we may update this Privacy Notice. We may notify you about material changes in the way we treat personal information by placing a notice on our website or in the App. You should check this Privacy Notice frequently for updates.

19. How to contact us

If your questions are not answered in this Privacy Notice, you may email us at privacyoffice@earlywarning.com, or write to us at Early Warning Services, LLC., Attn: Privacy Office, 5801 N Pima Rd, Scottsdale, AZ 85250.

If you need assistance with the Zelle^® App, please contact Consumer Services at https://www.zellepay.com/contact-us.

Zelle® Mobile App Users' Privacy Notice

Rev. November 2021

FACTS	WHAT DOES ZELLE^® DO WITH YOUR PERSONAL INFORMATION?

Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number Financial account information, including your debit card information Account transactions occurring through your use of the Zelle^®mobile application (the "Zelle^® App") Zelle^®transaction history, including information about payments requested, sent and received, occurring through your use of the Zelle^®App Payment history for transactions made through your use of the Zelle^®App Checking account information (no longer collected in the Zelle^®App as of the date of this notice) Account balances (no longer collected in the Zelle^®App as of the date f this notice) Other nonpublic information collected/transmitted by us in connection with your registration for or use of the Zelle^®App (e.g., geo-location, mobile phone number, email address, your name, payment information, passwords, passively collected information via tracking technologies such as cross-device tracking, unique device identifiers, unique device tokens, identity of your mobile device) When you are no longer our customer, we continue to share your information as described in this notice.

How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Zelle^® chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information		Does Zelle^®share?	Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your Zelle^®App Profile(s), respond to court orders and legal investigations, or report to credit bureaus.		Yes	No
For administrative purposes— such as to advise you of information regarding your Zelle^®App Profile or a transfer you have initiated or received.		Yes	No
For our marketing purposes— to offer our products and services to you		No	We don't share
For joint marketing of the Zelle^® service with other financial companies		No	We don't share
For our affiliates’ everyday business purposes— information about your transactions and experiences		Yes	No
For our affiliates’ everyday business purposes— information about your creditworthiness		No	We don't share
For our affiliates to market to you		No	We don't share
For nonaffiliates to market to you		No	We don't share

Questions?	Go to https://www.zellepay.com/privacy-policy. If your questions are not answered online, you may email us at privacyoffice@earlywarning.com, or write us at Early Warning Services, LLC. Attn: Privacy Office, 16552 N 90th Street, Scottsdale, AZ 85260.

Page 2

Who we are
Who is providing this notice?	Early Warning Services, LLC

What we do
How does Zelle^®protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration.
How does Zelle^®collect my personal information?	We collect your personal information, for example, when you provide account information, including your debit card information, or make an electronic funds transfer use your debit card tell us who receives the money, tell us where to send money¹, or when you receive money through the Zelle^® App give us your contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes—information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions
Affiliates		Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Early Warning Services, LLC, clearXchange LLC, Authentify, LLC, Early Warning Information Solutions, LLC
Nonaffiliates		Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include analytics companies, customer service providers, banks and financial institutions.
Joint marketing		A formal agreement including agreed upon rules and protocols between nonaffiliated financial companies that together market financial products or services to you. Zelle^® does not share personal information with nonaffiliated financial companies for joint marketing.
^{^[1]}Zelle® does not send nor initiate the transfer of money. Zelle® provides information to your financial institution, based upon the information you provide, directing your financial institution on where to debit or credit money
Other important information
Special Notice for California Residents: In order to comply with California law, the following applies if your account has a California mailing address. Restrict Nonpublic Personal Information Shared with Non-affiliated Third Parties Even if you do not make the privacy choice set above, we will not share information that we have about you with non-affiliated third parties, except for Everyday Business Purposes (defined below). For purposes of this notice, “Everyday Business Purposes” means any of the purposes set forth in Cal. Fin. Code § 4056. Including but not limited to: 1. When personal information is necessary to effect, administer, or enforce a transaction requested or authorized by you, or in connection with servicing or processing a financial product or service requested or authorized by you, or in connection with maintaining or servicing your account with us, or with another entity as part of a private label credit card program or other extension of credit on behalf of that entity, or in connection with a proposed or actual securitization or secondary market sale, including sales of servicing rights, or similar transactions related to a transaction of the consumer. 2. When your personal information is released with your consent or at your direction; and/or 3. When your personal information is released to: a. Protect the confidentiality or security of your records with us; and/or b. Protect against fraud, identity theft, unauthorized transactions, claims, or other liability. Restrict Nonpublic Personal Information Shared with Zelle^®Family We will not share nonpublic personal information about you within our family of companies other than for our Everyday Business Purposes unless we first provide you with further privacy choices. Restrict Nonpublic Personal Information Shared with Joint Marketing Partners We will not share information about you with joint marketing partners unless we first provided you with further privacy choices. Special Notice to Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at https://www.zellepay.com/privacy-policy. You may also email us at privacyoffice@earlywarning.com or write us at Early Warning Services, LLC. Attn: Privacy Office, 16552 N. 90^th Street, Scottsdale, AZ 85260.