Zelle® Mobile App Users’ Privacy Notice

Rev. December 2018

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 Checking account information and account transactions Zelle transaction history, including information about payments sent and received, occurring through your use of the Zelle mobile application (“Zelle App”) Account balances (if your bank requires you to link your Zelle profile to your bank account when using the Zelle App) Payment history for transactions made in the Zelle App Other nonpublic information collected/transmitted by us in connection with your enrollment 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 (please see below to limit the ways in which we contact you)		Yes	Yes (as described by Ad Choices)
*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		Yes	Yes (as described by Ad Choices)

To limit our sharing	To opt out of marketing in the communications we send: Use the options in the communications we send; Send an email request to requestoptout@earlywarning.com; and/or Visit Ad Choices, http://optout.aboutads.info (for targeted marketing). Please note: To learn more about limiting the collection of tracking technology/cookie data, visit Ad Choices http://optout.aboutads.info. For other types of data, if you are a new customer, we can begin sharing your information with nonaffiliated third parties for marketing purposes 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing, as described above.

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.

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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 the security of your personal information 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 (if you provide your debit card information when you enroll in the Zelle App) 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.
What happens when I limit sharing for an account I hold jointly with someone else?	N/A – Zelle App Profiles cannot be held jointly

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, marketing companies, digital advertising 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 with nonaffiliated financial companies for joint marketing.

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.