📄 Policy Information

zelle.com/legal/legal-and-privacy
November 6, 2025
Early Warning Services, LLC
7 Major US Banks

⚠️ Data Sensitivity: Tier 2 (Highly Sensitive)

Payment networks process financial data, transaction history, and bank account information across multiple financial institutions. This data requires heightened privacy protections under our methodology.

Privacy Score Breakdown

Data Collection Scope 15/100

Device info, usage data, cookies, third-party analytics (Google, Firebase, Mixpanel)

Third-Party Sharing 12/100

Shares with banks, third parties, "cross context behavioral advertising"

Consumer Protections 18/100

Reimbursement rate declined from 62% (2019) to 38% (2023) per Senate investigation

User Control 20/100

Take-it-or-leave-it consent: "do not consent... do not use the App"

Security Practices 22/100

NY AG alleges "inadequate verification safeguards" enabled $1B in fraud

⚖️ Regulatory & Legal Actions

NY Attorney General Lawsuit - $1 Billion in Fraud (August 2025)

New York Attorney General Letitia James sued Early Warning Services, LLC for inadequate security measures:

"Early Warning developed a streamlined registration process without adequate verification safeguards, enabling fraudsters to compromise legitimate user accounts and redirect funds."

Key allegations:

  • $1 billion stolen from Zelle users
  • Company was aware of fraud but failed to take "meaningful action"
  • Insufficient security measures enabled account takeovers
Source: Hunton Andrews Kurth - NY AG Lawsuit Analysis

Senate Investigation - Declining Consumer Protections (July 2024)

The Senate Permanent Subcommittee on Investigations conducted a 15-month investigation of Zelle and its owner banks:

"Zelle and the big banks who own it know that Zelle's speed and convenience makes it a target. They are well aware that every single day, some of their customers will be hurt." — Senator Richard Blumenthal

Key findings:

  • Unauthorized fraud reimbursement declined: 62% (2019) → 38% (2023)
  • $100+ million in unreimbursed disputed transactions (2021-2023)
  • In 2020: JPMorgan reimbursed 3 of 41,390 scam disputes
  • In 2020: Wells Fargo reimbursed 0 of 25,061 scam disputes
Source: Senate PSI Staff Report (July 2024)

CFPB Lawsuit (Filed 2024, Dropped March 2025)

The Consumer Financial Protection Bureau filed a similar lawsuit against Early Warning Services in 2024 but dropped it in March 2025.

Source: Hunton Andrews Kurth

📊 Data Collection Scope (Cited)

Device and Usage Tracking

Zelle automatically collects extensive device and usage information:

"Information collected automatically includes device info (IP address, device type, OS version, unique device ID), usage data (screens visited, features used, error logs), and cookies & session tracking for authentication, personalization, and analytics."
Source: Zelle privacy documentation

Third-Party Analytics Services

Zelle integrates multiple third-party tracking services:

"Third-party data sources include bank integrations (financial institutions may provide confirmation of linked accounts) and analytics services like Google Analytics, Firebase, and Mixpanel."
Source: Zelle privacy documentation

Personal Information Disclosure

Users consent to broad data sharing across the banking network:

"Users consent to disclosure of their personal information (including bank account information) to Zelle®, Service Providers, other Network Financial Institutions, and other third parties as necessary to complete payment transactions."
Source: Zelle Privacy Policy

👥 Third-Party Sharing (Cited)

Bank Consortium Data Sharing

Zelle is owned by Early Warning Services, which is co-owned by seven major US banks. Transaction data flows across this consortium:

"Early Warning is co-owned by seven major U.S. banks."

Owner banks include: Bank of America, JPMorgan Chase, Wells Fargo, Capital One, PNC, Truist, and US Bank.

Source: Hunton Andrews Kurth

Cross-Context Behavioral Advertising

Zelle explicitly acknowledges sharing data for behavioral advertising:

"We don't sell data. However, we do share data for cross context behavioral advertising. You can opt out by clicking the link above."
Source: Zelle Privacy Policy Page

Take-It-Or-Leave-It Consent

Zelle requires users to accept all data sharing or not use the service:

"If users do not consent to their access, collection, sharing or transmission of the data, they are advised not to use the App."
Source: Zelle Privacy Policy

🔒 Consumer Protection Failures (Cited)

Declining Reimbursement Rates

The Senate investigation documented sharp declines in consumer protections:

"The percentage of consumers reimbursed for transactions disputed as fraud at the Three Banks declined from 62% in 2019 to 38% in 2023."
Source: Senate PSI Staff Report

Scam Victims Left Unprotected

Banks reimbursed virtually no scam victims initially:

"In 2020: JPMorgan reimbursed 3 of 41,390 scam disputes; Wells Fargo reimbursed 0 of 25,061 scam disputes."
Source: Senate PSI Staff Report

No EFTA Liability Claimed

Early Warning Services takes the position it is not liable under consumer protection laws:

"EWS takes the legal position that it is not technically a 'financial institution' under EFTA and Regulation E. As such, EWS maintains that it is not liable to consumers who are victims of scams or fraud on the Zelle Network."
Source: Senate PSI Staff Report (PDF)

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