Privacy Policy

LAST UPDATED: JUNE 20, 2017

Welcome!  Thank you for visiting the Zelle Network (“Zelle,” “we,” “our,” or “us”) offering. To help inform you, we are providing this notice to explain our online information practices and the choices you can make about the collection and use of information you submit or we collect through our website https://www.zellepay.com, and our other related mobile websites, services, tools, and applications (collectively, the “Site”).  The Site is owned and operated by Early Warning Services, LLC. 

Zelle provides its U.S. financial institution customers (our “Network Banks”) a service to enable a convenient way to transfer money between account holders (each, a “User”) using aliases such as email addresses or mobile phone numbers.

Contents & Summary

 

A list summarizing the contents of this privacy policy (“Privacy Policy”) appears below, followed by the policy in full. Should there be any discrepancy between the summary and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Scope and Consent - By using the Site, you expressly consent to our collection, use, disclosure, and retention of your personal information and other information as described in this Privacy Policy.  Your use of the Site is also governed by the Terms of Use.

Information Collection - We collect the following information when you use the Site.

(a) Registration and Profile Information:  When you create an account or profile on the Site, you voluntarily give us personal information.

(b) Information to Respond to Your Requests:  You may also give us your personal information to sign up for our newsletters and other communications.

(c) Information About the Friends You Invite to Join Zelle:  If you invite your friends to join Zelle, you may give us their personal information.

(d) Information From Other Sources:  We may, on occasion, combine information from outside sources to customize your experience on the Site and for authentication and identity verification purposes.

(e) Information You Post on the Site:  You may provide us with information regarding yourself by completing a profile.

(f) Mobile Information:  We may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, your device’s operating system, or the mobile carrier for your phone).

(g) Technical Usage Information:  We use tracking technologies such as cookies and other similar technologies to measure usage. 

(h) Geolocation:  By using the site you expressly consent to our use of your geolocation to respond to your requests and improve your customer experience.

Uses and Retention - Use information collected from you to operate our Site and contact you. Your information is retained for as long as we need it for our business.

Disclosure of Information - We may share your personal information and other information we collect with the following entities: (a) Early Warning Services, LLC and the rest of our corporate family; (b) our service providers; (c) Network Banks; (d) other entities with your consent; (e) legal and law enforcement; and (f) others if there is a change of control.

Your Choices - You can control how and when you want to receive notifications from Zelle on the Site or by following instructions within the notices.

Cookies and Tracking Technologies - We use tracking technologies (including cookies) to recognize you, protect your privacy, and customize your experience on the Site.

Access and Review Options - You can review and edit your personal information by accessing your profile on the Site.

California Privacy Rights - If you are a California resident, you may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals.

Third-Parties - We are not responsible for the privacy practices of third-party websites that are linked to or from our Site.

Security - We protect your personal information using security measures.

Children’s Privacy - The Site is not intended for children under the age of 18.

Notification Regarding Updates - You agree that we may notify you about material changes to this Privacy Policy by posting notices on this Site.

Contact Us - Privacy issues are covered by our PRIVACY OFFICER.  For more information about our privacy practices, please continue to our full Privacy Policy below or send an email to privacyoffice@earlywarning.com

 

1. Scope and Consent

When you use the Site, you are contracting with Early Warning Services, LLC, located at 16552 N. 90th Street, Scottsdale, AZ 85260.  By using the Site, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

2. Information We Collect

a. Registration and Account Information: We collect personal information, such as your name, date of birth, postal or email addresses, telephone, mobile numbers and financial account numbers, from you when you register as a User or when you update your information throughout our Site.  If you are a registered User and have a bank account at one of our Network Banks, we may also collect personal information from that Network Bank if it receives a notification that your bank account information in our database is inaccurate and needs to be changed.  Additionally, if you are a registered User and have a bank account at one of our Network Banks, your bank’s privacy policy may also apply to the information that we collect through our Site and to the information that your bank provides to us.  In addition, we may collect personal information from consumer reporting agencies in order to process your registration, verify your identity, verify you bank account information and protect against or prevent actual or potential fraud or unauthorized use.

You can browse the Site without telling us who you are or revealing any personal information about yourself.

You may also upload photographs for your User account/profile. 

b. Information to Respond to Your Requests: You may provide us your personal information so we can send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section headed “Your Choices” below.

c. Information About Others: From time to time you may choose to submit personal information about other people to invite them to join the Zelle community or to initiate a money transfer to or from another person.  You should receive your friends consent to your sharing of their personal information before submitting it to us.

d. Information From Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law and which will be used for authentication and identity verification purposes.

e. Content You Associate With Your Profile: We collect any information you enter into your User profile.  This includes your contact information, your bank account information, and information related to any transfers of funds you make between you and your contacts.  Also, your profile may contain a photograph or other information that identifies you. 

f. Mobile Information: We may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location).

g. Technical Usage Information: When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site (“usage information”).  We use tracking technologies (including cookies  (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, e-tags/cache browsers), unique device tokens, deterministic finger-printing technologies, probabilistic finger-printing technologies, device graph, and unique identifier header to collect usage information and we also collect your IP address. 

We may also collect password information from you when you log in, as well as computer and/or connection information.  During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

Our goal is to collect and use only that information that we think is required for our legitimate business interests, in order to authenticate and verify your identity, and to improve your experience of using the Site.  To learn more about how we use tracking technologies and cookies, see Section 7 of thisPrivacy Policy and our Cookies and Tracking Technologies Policy .

h. Geolocation Information: When you visit the Site, we may collect geo-location information to provide certain location-based services that you request (e.g., maps or Nearby functionality to identify Zelle App users near you and allow other Zelle users to be notified that you are near them), verify your identity, or any of the reasons set forth in Section 3 of this Privacy Policy. We disclose the geolocation data in the manner set forth in Section 4 of this Privacy Policy .

3. Uses and Retention

a. Operate Our Site: We use the information collected to (i) respond to your requests; (ii) enable our Network Banks to complete money transfers between their customers and you; (iii) send you an email or text message to notify you of a pending money transfer or request for payment; (iv) verify changes you have made to your personal information; (v) facilitate your registration on our Site as a User and to resolve issues relating to you registration; (vi) resolve a problem related to a transaction with our Network Banks; (vii) verify the existence of your bank account; (viii) verify your identity; (ix) provide customer service (e.g., to resolve disputes, problems with your User account/profile or the Site); (x) improve the Site; (xi) give you information about your Zelle profile; and (xii) provide you with a safe, efficient, and customized experience.

b. Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze Site and user behavior and for general business purposes, including but not limited to data analysis, audits, developing new products, enhancing our Site, identifying usage trends, and improving services.

c. Prevent Fraud: We use information from the Site to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Use.

d. Communicate With You: We use your information to contact you to maintain the Site, your Zelle profile, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications about Zelle, or contact you for other purposes authorized by law.

e. Mobile Data: When you access the Site on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy.  For example, we may use this information to provide you with location-based services. 

We retain information as long as it is necessary and relevant for our operations.

4. Disclosure

Information collected on the Site may be shared with:

a. The Early Warning Services, LLC Corporate Family: We may share the information we collect about you with the Early Warning Services, LLC corporate family, including our affiliates and subsidiaries, as well as with third-party suppliers.  The information may be disclosed to: (i) provide our services (e.g., registration, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our products, sites, applications, services, tools and communications.  Members of our corporate family will use this information to send you marketing communications about Zelle services and you will have the opportunity to opt-out in email communications.

b. Our Network Banks: We may share personal information of Users with Network Banks and affiliates for the purposes described in Section 3 of this notice.

c. Service Providers and Other Third-Parties: We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, verifying your identity, fraud investigations, site analytics and operations).

d. Other Entities with Your Consent: Other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Site, you may have opportunities to express interest in or register for other services.  If you do, we will provide information about you to those third-parties, or parties working on their behalf, to implement your request.

e. Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, our Network Banks, or any other User to legal liability.  In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law.  In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation.

f. Change of Control – New Owners: We may share your information with other business entities, should we plan to merge with or be acquired by that business entity.  Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.

g. Companies in The Mobile App Industry: If you access the Site through a mobile device, we may also share your information with carriers, operating systems and platforms.

5. Your Choices

You can control how and when you want to receive notifications from us on the Site by following instructions within the notices. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account.  You can also update your User profile and registration information, including your bank account, personal information and email addresses/mobile numbers. Keeping this information up-to-date is very important. If this information is incomplete, inaccurate or not current, please update your information by looking into your profile.

6. Cookies and Tracking Technologies

When you visit the Site, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Site, for when you later return to the Site.

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

  • We offer certain features that are available only through the use of tracking technologies.
  • We use both session and persistent tracking technologies.  Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).  You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site.  Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • We use cookies and tracking technologies with your prior consent as obtained through your use of this Site.
  • We encode and protect the tracking technologies that we set, so that only we can interpret the information stored in them.
  • You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics .
  • For more information about the use of cookies and similar technology on our Site, please review this Privacy Policy and our Cookies and Tracking Technologies Policy .

7. Accessing, Reviewing, and Changing Your Personal Information

Registered Users can review and change personal information at any time by accessing their accounts/ profiles on the Site.  You should promptly update your personal information if it changes or becomes inaccurate.  We may retain some information from closed accounts/profiles so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law.  Likewise, if your account/profile is terminated or suspended, we may maintain some information to prevent re-registration.

8. Notice to California Residents

a. How California Residents Can Request a List of Third Parties that Received Personal Information: Residents of the State of California may request a list of all third-parties to which our Site has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes.  If you are a California resident and want such a list, please contact us at privacyoffice@earlywarning.com .  For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.  In the body of your request, please provide enough information for us to determine if this applies to you.  You need to attest to the fact that you are a California resident and provide a current California address for our response.  Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

b. How We Respond to Do Not Track Signals for California Residents:  California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings.  We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.  We continue to review new technologies and may adopt a standard once one is created.

9. Third-Parties

Our Site may contain links to other third-party websites, such as Network Banks.  We are not responsible for the privacy practices or the content of these third-party sites.

10. Security

We store and process your information on our servers located in the United States.  We maintain technical, physical, and administrative security measures to protect the security of your personal information 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.  It is your responsibility to make sure that your personal information is accurate and that your password(s) and account/profile registration information are secure and not shared with third-parties.

11. Children’s Privacy

The Site is a general audience site and it is not intended for anyone under the age of 18.  We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.

12. Notification Regarding Updates

From time to time, we may update this Privacy Policy.  You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site.  You should check the Site frequently for updates.

13. Contact Us

If your questions are not answered online, you may email us at privacyoffice@earlywarning.com, or using the contact us form (https://www.zellepay.com/contact ) on the Site.