Last Updated and Effective as of April 25, 2022
Zip is dedicated to informing you on how we will collect, store, protect, use, and share your personal information when you use our services.
For customers using the Zip Anywhere Service, your personal information and privacy rights will also be subject to the WebBank Privacy Notice, and use of such information will be consistent with that privacy notice. Please read this WebBank Privacy Notice carefully. By accessing and using the Zip Anywhere Service, you confirm that you have read and understood this Privacy Notice in its entirety. You understand and acknowledge that WebBank reserves the right to change or amend this Privacy Notice at any time.
How you can contact us about privacy questions
Collection of Personal Information
We may collect the following types of personal information in order to provide you with the use of Zip Services and to help us personalize and improve your and others' experience.
Information we collect automatically:
Information you provide to us
We collect two basic types of information from you in conjunction with your use of Zip Services (collectively your “personal information”):
- Personally identifiable information;
- and non-personally identifiable information.
Personally identifiable information is any information that can identify you.
- Examples include your name e-mail address, telephone number, postal address, device identifiers, IP address, geolocation information, and financial account information that you provide, such as credit or debit card numbers.
- We may also collect personally identifiable information about you from third parties such as data vendors.
- Aggregate and/or de-identified information is not considered personally identifiable information.
Non-personally identifiable information is information that does not identify you directly but may be linkable to you.
- Examples include demographic information and general location.
We may also collect information from or about you other than through your use of Zip Services, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with members of the Zip corporate family or other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole). Additionally, for quality and training purposes or for its own protection, Zip may monitor or record its telephone conversations with you or anyone acting on your behalf, subject to applicable law. By communicating with Zip, unless otherwise provided by applicable law, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Information from other sources
When you download or use our mobile applications or access one of our mobile-optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.
Cookies and similar technologies
When you access our website or use Zip Services, we (including companies we work with) may place small data files on your computer or another device. These data files may be cookies, pixel tags, e-tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We use these technologies to recognize you as a customer; customize Zip Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud, and to promote trust and safety across our sites and Zip Services.
How we use the personal information we collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience with Zip Services. We use your personal information to:
- Provide Zip Services and customer support.
- Process transactions and send notices about your transactions.
- Resolve disputes and collect payments and/or fees.
- Verify the accuracy of and authenticate your information.
- Detect, investigate, and prevent potentially prohibited or illegal activities, such as fraud.
- Communicate changes to our policy.
- Personalize content and experiences, including providing recommendations based on your preferences.
- Send offers or promotions for Zip Services.
- Provide advertising, including advertising based on your use of the Zip Services and their purchasing patterns.
- Conduct any other legitimate business activities not otherwise prohibited by law.
We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts, and promotions, and inform you about Zip Services and the services of our corporate family. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. To reach you as efficiently as possible, we may contact you via phone and may use auto-dialed or prerecorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We combine your personal information with information we collect from other companies and use it to improve and personalize Zip Services, content, and advertising delivered to you and other users.
How we share personal information with merchants
When transacting with merchants of goods and services (“Merchants”), we provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.
We do not share your bank account information or card account information with any Merchants.
We work with third parties, including Merchants, to enable them to accept or send payments from or to you using Zip. In doing so, a third party may share information about you with us, such as your email address or mobile phone number. We use this information to confirm that you are a Zip customer and that Zip as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a Zip customer with a third party, we will do so.
Please note that Merchants and other third parties from whom you buy or with whom you contract will have their own privacy policies, and although Zip’s User Agreement does not allow the other transacting party to use any personal information we give them for anything other than providing Zip’s Services, Zip is not responsible for their actions, including their information protection practices.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using Zip, or with the third parties that offer or use Zip Services, except with your express permission or if we are required to do so to comply with applicable credit card association rules, a subpoena, or another legal process.
How we share personal information with other third parties
We share personal information with:
- Members of the Zip corporate family, to help detect and prevent potentially illegal acts and violations of our and their policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services.
- Financial institutions that we partner with to jointly create and offer a product. These financial institutions may only use this information to market Zip-related products unless you have given consent for other uses.
- Banking partners as required by credit card association rules for inclusion on their list of terminated merchants.
- Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Zip or one of its affiliates; when we need to do so to comply with law or credit card association rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
Other unaffiliated third parties, for the following purposes:
- Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
- Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).
- Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
- Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.
We currently do not - but reserve the right in the future to - share your information with credit bureaus and collection agencies to report account information, as permitted or required by law.
If you open a Zip account directly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Zip website) will be shared with the owner of the third-party website or application. These websites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with personal information. Zip is not responsible for the content or information practices of such third parties.
How we protect and store personal information
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers, and information access authorization controls.
How you can restrict us from using/sharing your personal information
We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.
You may wish to unsubscribe from marketing emails by clicking the “Unsubscribe” link in the email footer or by contacting Zip Customer Service. However, we will still be authorized to contact you regarding servicing and account-related purposes.
You are free to decline our cookies if your browser or browser add-on permits unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and Zip Services.
In addition to session-based cookies, we utilize third-party cookies from vendors that have been thoroughly vetted for analytics and marketing purposes. These third-party cookies help us better analyze and customize our users' experience as well as deliver interest-based and retargeting advertisements on websites throughout the Internet. These third parties may collect personally identifiable information about your online activities over time and across different websites when you use Zip Services. You have the right to control behavioral and interest-based marketing. For example, some browsers can be set to notify you when you receive a cookie, giving you the chance to decide whether to accept it. In addition, you may be able to opt out of some third-party cookies by using the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.
Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed, or advertising from third parties that is not based on your interests and preferences.
Children's online privacy protection act
We comply with the requirements of the Children's Online Privacy Protection Act. We do not knowingly or intentionally collect or sell personal information from children under the age of 16. Our website, products, and services are directed to individuals who are at least 16 years of age or older.
If you learn that your child has provided us with personal information without your consent, you may contact us as set forth herein. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child's account.
How you can access or change your personal information
You may request to access or correct the personal information that you have provided to us. Depending on where you live and the type of information you have provided to Zip, you may have different rights and choices for managing your personal data. For example, certain state laws do not apply to personal data collected, processed, or disclosed by a financial institution according to federal laws, such as the Gramm-Leach-Bliley Act. Accordingly, the ability to access or correct data is not absolute and is subject to Zip's internal policies. To submit a request, email [email protected].
Provisions applicable to California consumers
California consumer privacy act
The California Consumer Privacy Act (“CCPA”) provides natural persons who are California residents (“California Consumers”) users of our Services with the right to receive, free of charge, in connection with their use of our Services, certain disclosures regarding our collection, use, sharing and processing of certain personal information, as well as the right to know/access, delete and limit sales of this personal information. To the extent that we collect such personal information subject to the CCPA, that information, our practices, and your rights are set forth below. Under the CCPA, “personal information” is defined as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household,” and we use that meaning in this section. We do not sell personal information of California Consumers, as such term is used in the CCPA.
Collection of personal information
California Consumers have the right to receive notice of the categories of personal information we collect regarding our California Consumers and the purposes for which those categories of personal information will be used. Please refer to the section above titled “Collection of Personal Information” for a description of the categories of personal information we collect regarding California Consumers, and the section above titled “How We Use the Personal Information We Collect” for a description of the purposes for which those categories of personal information may be used.
Third parties with whom personal information is shared
Zip shares California Consumers' personal information with third parties as described in the above sections titled “How We Share Personal Information with Merchants” and “How We Share Personal Information with Other Third Parties”.
In the preceding 12 months, we have disclosed the following categories of personal information about consumers for business purposes:
- Personal Identifiers. We share this information with our Service Providers to allow them to perform services on behalf of Zip. We may also share this information with our business partners so that they may provide California Consumers with information about products and services that may be of interest to such persons.
- Transaction Data. We share this information with our Service Providers to allow them to perform services on behalf of Zip.
- Internet or Other Electronic Network Activity Information. We share with or allow third parties to utilize cookies for marketing or advertising customized to users' interests or needs.
Consistent with the general statements above, including those in the section titled “Marketing”, in the preceding 12 months, we have not sold personal information of any California Consumers, including any California Consumers who are minors.
Right to know/access information
California Consumers have the right to request that we disclose to them the categories of personal information we have collected about them, the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share the personal information, the specific pieces of personal information we have collected about them, and the categories of personal information that was disclosed for a business purpose. California Consumers may request this information twice in a 12-month period. To protect our customers' personal information, we are required to verify the requestor's identity before we can act on any such request.
Right to request deletion of personal information
California Consumers have the right to request that Zip and our Service Providers delete any personal information about them that we have collected from the California Consumers. To protect our customers' personal information, we are required to verify the requestor's identity before we can act on any such request. The right of deletion may be subject to certain CCPA exceptions.
Right to equal service
Zip will not discriminate against California Consumers on the basis of the exercise or non-exercise of any rights hereunder, including, but not limited to, by:
- Denying goods or services on such basis;
- Charging differing prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, on such basis;
- Providing differing levels of quality of goods or services on such basis; or
- Suggesting that California Consumers will receive a different price or rate for goods or services or a different level or quality of goods or services.
California Consumers can submit “verifiable consumer requests” (as such term is used in the CCPA) regarding the privacy of their personal information, by sending an email to [email protected] or calling toll-free 1-888-322-5037. Zip must be able to verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request (or is the parent or legal guardian of such minor California Consumer, or is a person authorized by such a California Consumer to act on such California Consumer's behalf). Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in such a request to verify the requestor's identity. Please be prepared to provide us with your full name, your email, your date of birth, and billing zip code. You may also designate an authorized agent to make such requests on your behalf by sending us an email with your designated authorized agent's information. We reserve the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is suspect or fraudulent.