Zelle Network® Hard Copy Forms/Offline Privacy Notice for B2B California Residents
Updated: May 31, 2024
This Privacy Notice applies to the Personal Information of B2B California residents who complete hard copy forms for the Zelle Network® (e.g., participating financial institutions) (referred to as “Form(s)” from here on out).
Pursuant to the California Consumer Privacy Act (CCPA), its implementing regulations, and as modified by the California Privacy Rights Act (CPRA), this Privacy Notice is intended to inform California residents of the Personal Information we collect, how it’s used and disclosed, and the rights you have in regard to such information.
This Privacy Notice explains our information privacy practices and the choices you can make about the collection, use, disclosure, and retention of information you submit via Forms. 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.
As a visitor to our website, our zellepay.com Website Privacy Notice also applies. Click here to learn more.
By submitting a Form(s), you agree that the information you have provided is subject to this Privacy Notice. In other words, please do not submit the Form if you do not agree with this Privacy Notice.
What do you want to learn more about?
Table of Contents
- When this Privacy Notice applies.
- What Personal Information is.
- Personal Information we’ve collected, used, and/or disclosed.
- B2B California residents’ privacy rights.
- How we protect Personal Information.
- Where Personal Information is stored.
- Where Personal Information is stored
- Changes to this Privacy Notice.
- How to contact us.
1. When this Privacy Notice applies
This Privacy Notice applies to the Personal Information of B2B California residents who complete hard copy forms for the Zelle Network® (e.g., participating financial institutions) (referred to as “Form(s)” from here on out).
As a visitor to our website, our zellepay.com Website Privacy Notice also applies. Click here to learn more.
This Privacy Notice does not apply to the Zelle® app. See the Zelle® App Privacy Notice to learn more.
2. What Personal Information is
For the purpose of this Privacy Notice, “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, your title, business email address, business telephone number, business address.
Personal Information does not include information obtained from public sources or information that is made available by federal, state, or local governments. Personal Information also does not include deidentified, anonymized, or aggregate information.
3. Personal Information we’ve collected, used, and/or disclosed
If you’ve submitted a Form(s) in the past 12 months for the Zelle Network® , we may have collected, used, and/or disclosed 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 Personal Information is collected: | Business purpose(s) for collection, use, and disclosure: | Disclosed for business purpose(s) to the following categories of third parties: | Sold or shared to the following categories of third parties: | Length of time Personal Information is intended to be retained: (unless subject to a legal hold) |
| Personal and online identifiers (e.g., name, title, company email address) | · Directly from you, or your delegate, when you submit a Form | · To support the onboarding of current or prospective Network Participants or Technical Integrators and the testing of our products and services; · To communicate with you about our products and services and related documentation; · For operations; · For business partner inquiries (B2B), to send you information about our products and services that we believe you will find beneficial and to respond to your requests/inquiries and comply with your stated communication preferences; · To provide you with a safe, efficient, and customized experience; · To provide other services you request. · To prevent, detect, and protect against security incidents, fraud, and prohibited or illegal activities; · To undertake activities to verify or maintain the quality or safety of our services; and · To perform services (for us or our service providers) such as providing analytic services | · Our customers (Network Participants, or Technical integrators)(e.g., we may disclose information with them about their users); · Our service providers; Law enforcement, government agencies and other authorized third parties (we may be required by law to disclose information for legal reasons); and · Other entities with your consent | · None In the past 12 months, we have not sold, or shared Personal Information collected from the Form. For purposes of this Privacy Notice, “sale” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration and “share” means the disclosure of Personal Information to a third party for cross-context behavioral advertising. This also means that we have not sold or shared information about minors. | · Length of Network Participant or Technical Integrators relationship, plus 10 years |
| Certain identifying Personal Information (e.g., company address, company telephone number) |
4. California business partners (B2B) privacy rights
If you are a B2B California resident and you’ve interacted with us on behalf of your company/business (e.g., you’ve registered with us to potentially become a Network Participant), the following data privacy rights are available to you:
| You have the right to… | How? | |
| Third party direct marketing | 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. |
| Be informed | Know the categories and specific pieces of Personal Information we collected about you, our business purposes for collecting Personal Information , the categories of sources that we’ve collected Personal Information from, the categories of third parties that we’ve disclosed Personal Information to, whether we’ve sold or shared Personal Information to a third party in the preceding 12 months, and the categories of third parties with which we’ve sold or shared Personal Information . Note: In the past 12 months, we have not sold or shared Personal Information from the Website. For purposes of this Privacy Notice, “sale” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration and “share” means the disclosure of Personal Information to a third party for cross-context behavioral advertising. | Review this Privacy Notice in its entirety to learn more about the Personal Information we collect, why we collect Personal Information, the sources from which we collect Personal Information from, and who we may disclose Personal Information to. CA Business Partners (B2B) Send an email to Zelleprivacy@earlywarning.com with “California B2B Data Privacy Rights Request” in the subject line. In the body of the email, please include:
|
| Correct inaccurate data | Request that we correct inaccurate Personal Information that we maintain about you. Note: To the extent required by, and in accordance with applicable law, we will use commercially reasonable efforts to correct your Personal Information as directed by you, considering the nature and the purposes of maintaining your Personal Information. Under certain circumstances, we may not be able to correct your information because we have a legal obligation or other reason in which we must retain it in its current state (e.g., the nature of the data, the source of the data, to comply with law). | |
| Delete data | Request that we delete your Personal Information. 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. | |
| Access | Access your Personal Information that we’ve collected about you in the preceding 12 months following your request. Note: You may request that we disclose the above information beyond the 12-month period for Personal Information collected on or after January 1, 2022, unless doing so proves impossible or would involve a disproportionate effort. | |
| Limit data | Limit the use of sensitive Personal Information. | Our Forms do not collect sensitive Personal Information. |
| Opt out | Opt out of the sale or sharing of your Personal Information. | As stated above, we do not sell or share Personal Information that we’ve collected from Forms with third parties. |
| Free from discrimination | Be free from discrimination for exercising your privacy rights | We will not discriminate against you for exercising your choices and rights. |
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.
Upon receipt of your “California B2B Data Privacy Rights Request” email, 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 for most requests).
When you make a request, we will attempt to verify that you are who you say you are. For example, we will attempt to match information that you provide in making your request with information that we have on file. 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.
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 sending an email to zelleprivacy@earlywarning.com.
5. Your choices
If you’ve previously expressed interest in our products and services for your company/business and you no longer wish to receive marketing communications from us, you can indicate your communication preference within the direct communication from us (e.g., using the unsubscribe link in the email you receive from us) or by emailing marketing@earlywarning.com. Please allow us a reasonable period of time in order to satisfy your request, as some communications may already be in process.
6. 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.
7. Where Personal Information is stored
We are located in the United States. 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.
8. Changes to this Privacy Notice
From time to time, we may update this Privacy Notice. You agree that we may notify you about material changes in the way we treat Personal Information by email or by placing a notice on this website.
9. How to contact us
If your questions are not answered in this Privacy Notice, you may email us at zelleprivacy@earlywarning.com, or write to us at Early Warning Services, LLC., Attn: Privacy Office, 5801 N Pima Rd, Scottsdale, AZ 85250.