Privacy Policy

Welcome to Zello. Zello, Inc. (“Zello,” “we,” “us,” or “our”) provides push-to-talk, “walkie-talkie” services for mobile devices (such services, together with the Sites and the App, the “Services”) to individual users (“Users”). We provide the Services through our Zello applications (each an “App” and together the “Apps”) and we provide information about the Services through our website available at https://zello.com/ and other Zello websites (each a “Site” and together the “Sites”).

We value your privacy. This Privacy Policy explains what Personal Data (defined below) we collect in connection with or through the Services, how we use and share that data, and your choices concerning our data practices.

The Services also include Zello Work, which is made available to organizations (“Customers”) for use with their end users. This Privacy Policy does not apply to personal information pertaining to end users that we process on behalf of our Customers in the course of providing our Services to such Customers (“Customer Data”). We process Customer Data as instructed by our Customers, in our capacity as a service provider/data processor, in accordance with the terms of our Customer agreements. If you are an end user of such a Customer, please contact the Customer for information about the Customer’s policies pertaining to Customer Data.

Information We Collect

When you contact us or interact with the Services, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”) as follows:

User Information

If you are a User, we collect the following type of information that you provide in connection with your use of the Services. Certain information about you is also logged automatically in our systems, as described in the “Information Collected Automatically” section below.

• Account Information: When you sign up for a Zello account, we collect certain Personal Data about you, including your username, password, email address, and a device identifier generated through the App (which is separate from and not related to any advertising identifier generated by your device’s operating system). You may also choose to provide your phone number to enable us to verify your identity and mitigate spam and abuse.
• Information From Your Device: When using our Services and in accordance with the consent settings on your device, you can allow the App to access (i) your contacts, so you can invite your friends to join Zello; (ii) your camera/photos, so you can create or post a profile picture or send photos to other Users through the Services, and (iii) your location, if you would like to share it with other Users on the Services (please also read the “Information Collected Automatically” section below for further information about how we process location information). You may also grant permissions for our App to access the microphone on your device in order to transmit your audio to other Users on the App.
• Information You Provide Through Our Support Channels: If you choose to submit information regarding a problem you are experiencing with the Services to our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. We will collect the information associated with this request in order to address your problem.

Information Collected from Site Visitors

We collect information that you provide when you interact with our Sites, such as when you request content, register for an event, contact our sales team or otherwise communicate with us. Certain information about you is also logged automatically in our systems, as described in the “Information Collected Automatically” section below. The information we may collect from you is described below.

• Requesting Information or Content: We collect certain Personal Data about you if you voluntarily provide us with such information when you engage in certain activities on our Sites, such as fill out web forms to ask to be contacted by our sales team or request a demo, ask to download content (such as brochures, studies or guides), register for a webcast or other event, post comments on pages or our blog, or subscribe to emailing lists. The specific Personal Data collected during these interactions will vary based on the purpose of the form or the nature of your request, but it will generally include your name, email address and phone number (for example, we will ask you to provide your phone number if you want a member of our sales team to call you). We may also ask you for additional information to help us understand you better as a customer like your company name, or your role at your company.
• Information We Collect Through Our Social Media Pages: We maintain pages through social media services like Facebook, Twitter, YouTube, and Instagram (“Social Media Pages”). We may collect Personal Data from you when you interact with our Social Media Pages, including Facebook, LinkedIn and Twitter.

Zello Work Customers

If you are a representative of a Customer of Zello Work, we may collect certain Personal Data about you as described below. Certain information about you is also logged automatically in our systems, as described in the “Information Collected Automatically” section below. The information we may collect from you is described below.

• Account Registration: If you register with the Services through our Sites or through a separate subscription agreement with us, then as part of such registration we will ask you to provide certain Personal Data, including your name, your company name, your email address and password. If you create an account or log into the Services using third-party services, we will receive your name and email address as permitted by your profile settings on the third-party service in order to authenticate you. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with our Services.
• Paying for Our Services: When you purchase a subscription to our Services, you will provide our third-party payment processor Zuora with billing details such as credit card information, banking information and/or a billing address. If you have questions about how Zuora protects such information, please read Zuora’s services agreement and privacy policy.
• Physical Location Data: We may collect the precise location of where our Services are being used and temporarily store live location data as part of our map Services. Location data will be stored for six months if a Customer of Zello Work subscribes to our premium maps Services. Representatives of Customers of Zello Work must provide consent to gather location data from the device unless the Customer uses permissions that are automatically configured. Internet protocol (IP) addresses are saved for audit logging purposes.
• Contact our Sales Team or Customer Support Team: You may provide your Personal Data, like your contact information, to a member of our sales or customer support team when you communicate with them. If you contact our sales or customer support teams, those teams keep a record of that communication, including your contact details and other information you share during the course of the communication. We store this information to help us keep track of the inquiries we receive from you and from Customers generally so we can improve our Services and provide training to team members. This information also helps our teams manage our ongoing relationships with our Customers.

Information Collected Automatically

When you visit, use and interact with the Services, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Sites or use the App, peak hours of visits, which page(s) are visited on our Sites, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access and visit our Sites (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

• Log data: Information (“log data”) that your browser automatically sends whenever you visit the Sites. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Sites), browser type and settings, the date and time of your request, and how you interacted with the Sites.
• Cookies and similar technologies: Please see the “Cookies and Other Technologies” section below to learn more about how we use cookies and other technologies.
• Device information: Includes name/type of the device accessing the Services, operating system, browser you are using, device settings, application IDs, unique device identifiers and crash data. Information collected may depend on the type of device you use and its settings.
• Usage information: We collect information about how you use our Services, such as the features you use, the actions you take, and the time, frequency and duration of your activities. We do not monitor or access the content of Users’ private or one-to-one conversations.
• Location information: If you have enabled location services for the App on your mobile device, we may collect your precise location information based on city, state, zip code, country, latitude and longitude. We collect such location information with your consent to allow Users to share a one-time snapshot of their location. Zello does not track or store this information. We may also derive your approximate location from the IP address of your mobile device. If you want to opt-out of the collection of your location data, please adjust the settings on your mobile device to limit the App’s access to your location data.

How we use the information

We use Personal Data for the following purposes:

To provide our Users and Customers with the Services and related customer support, process transactions, manage your account and respond to your requests, including:

• To connect Users to the most geographically proximate server and provide more relevant, localized content
• To allow Users to share their location with other Users of the Services, to invite friends to join them on the Services, and to allow them to post or share photos through the Services

This processing is necessary to fulfill the contract we are about to enter into or have entered into with our Users or Customers.

As necessary for certain legitimate business interests, which include the following:

• To respond to inquiries, comments, feedback or questions
• To verify the identities of Users to mitigate spam and abuse of the Services
• To send administrative information to you, for example, information about the App or Services, and changes to our terms, conditions, and policies
• To analyze App and Site usage so we can provide, maintain and improve the content and functionality of the App and Sites and enable us to enhance and personalize the experience we offer to our Users or Customers. For example, we regularly fix bugs and User or Customer experience issues. We use cookies and similar technologies to analyze how users interact with our App and Sites. And that analysis can help us improve the App and Sites. If you are an individual in the European Economic Area or the United Kingdom, we will obtain your consent before using cookies and similar technologies for analytics purposes.

For compliance with law in accordance with our legitimate business interests, including:

• To prevent fraud, criminal activity, or misuses of our App and Sites and to ensure the security of our IT systems, architecture and networks
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, Customers, or other third parties

For marketing and advertising, including:

• To contact you by email to tell you about information we believe will be of interest to you, such as information about products and services, features, surveys, newsletters and upcoming events. If we do, where required by law, we will only send you such marketing information if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving promotional communications by following the instructions contained in each communication we send you or by contacting us as explained at the bottom of this Privacy Policy. If you opt-out from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding our Services and products and to respond to your requests.
• For interest-based advertising. We use cookies and similar technologies to engage in interest-based advertising. Please review our Cookie Policy for more information. Where required by applicable law, we will engage in interest-based advertising only with your consent.

There may be other occasions where Personal Data is processed for purposes which will be explained at that time. We will provide further notice to you of any additional processing and, if required, ask your consent to that processing.

Disclosure of Information

In certain circumstances we may disclose your Personal Data to third parties, as set forth below:

• Other Users: When you connect to a communication channel, your username will be visible to other Users connected to the same channel. We do not store the voice communications you send through the Services (except as described in the Data Retention section below), but other Users connected to channels through which you disclose voice communications may save, replay, and disclose your communications through the voice history feature of the Services.
• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to service providers, including hosting, cloud services and other information technology services providers; email communication software providers, advertising and marketing service providers; customer relationship management, customer engagement, and customer feedback services; payment processors; identity verification services; and analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We do not disclose any User voice communications to vendors or service providers.
• Advertising Partners: To assist us in marketing our products and services, we may disclose Personal Data to third-party advertising companies, including for the interest-based advertising purposes described above, that can collect information on our website through cookies and other automated technologies. Please review our Cookie Policy for more information. We do not disclose any User voice communications to our advertising partners.
• The Public: Our Sites offer publicly accessible blogs (such as https://blog.zello.com/). Please be aware that any information you provide on such Sites – including, if you have a Zello account, profile information associated with the account you use to post the information – may be read, collected, and used by any member of the public who accesses these Sites.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.

Data Retention

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer.

We do not store the voice communications Users send through the Services. If another User sends you a message while you are offline, Zello will try to redeliver the message to you for up to seven (7) days.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Children

The Sites and the Services are not directed to children who are under the age of 18. Zello does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Zello through the Sites or Services please contact us at [email protected] and we will endeavor to delete that information from our databases.

Privacy Choices

Opt Out of Marketing Communications.

You may opt out of receiving promotional communications by following the instructions contained in each communication we send you or by contacting us as explained at the bottom of this Privacy Policy. If you opt-out from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding our Services and products and to respond to your requests.

Opt Out of Online Tracking.

You can opt out of third-party cookies as described in our Cookie Policy.

Opt Out of Location Tracking.

If you want to opt out of the collection of your location data, please adjust your settings in your mobile device to limit the App’s access to your location data.

Stop Updating Your Contact List.

If you choose to sync your contacts, you can always stop updating your contact list later by disabling contact sync in your account settings page.

Privacy Rights. Subject to applicable law and depending on your location, you have the following rights in relation to your Personal Data:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we disclosed your Personal Data to others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you to whom we disclosed your Personal Data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we disclosed your data to others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you to whom we disclosed your Personal Data with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we disclosed your Personal Data to others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you to whom we disclosed your Personal Data so you can contact them directly.
• Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  – If we are relying on a legitimate interest to process your Personal Data—unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
  – If we are processing your Personal Data for direct marketing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
• Right to opt out of selling and sharing Personal Data. We use cookies and other similar technologies on our Site to help us advertise our Services on other websites or services you visit. We share information we collect on our Site, such as information about the pages you visit and the actions you take on our Site, with advertising networks and analytics partners to support our interest-based advertising, which may qualify as a sale or sharing of Personal Data, or targeted advertising, under applicable law. You can opt-out of our use or sharing of Personal Data for these purposes by using our “Your Privacy Choices” tool in the footer of our Site.
• Right to lodge a complaint with the data protection authority: Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you can report concerns about our privacy practices, including the way we handled your Personal Data, to the data protection authority that is authorized to hear those concerns.

Please contact us at [email protected] to exercise your rights.

When you exercise your privacy rights, we may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Please note that in some instances, your privacy rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided above.

Links to Other Websites or Services

The Services may contain links to other websites or services not operated or controlled by Zello (“Third Party Services”). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third-Party Services and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Services directly for information on their privacy practices and policies.

Security

You use the Services at your own risk. We deploy measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. For example, we use available technology and other techniques to implement systems like firewalls, and/or encryption to secure data transfers. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services, or e-mail. Please keep this in mind when disclosing any Personal Data to Zello via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained in the Services or third-party websites.

Changes to the Privacy Policy

The App, the Sites, the Services, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.

International Transfer

Zello is based in the United States. If you are accessing the Services from the EEA, the UK, or other regions with laws governing data collection and use, please note that we may transfer your Personal Data to the United States for the purposes described in this Privacy Policy, and the data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the Contact Us section below.

EU/UK GDPR Representation

Zello has defined GDPR representation for the EU and the UK.

EU Representative

Osano International Compliance Services Limited
ATTN: CADW
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative

Osano UK Compliance LTD
ATTN: CADW
42-46 Fountain Street
Belfast
Antrim
BT1 - 5EF

Contact Us

Responsible Entity. Zello is the data controller of the Personal Data we collect for our own businesses, as described in this Privacy Policy. Zello is the data processor of Personal Data provided or otherwise made available to us by Customers through the Services, which we process on Customers’ behalf pursuant to our contract with the applicable Customer.

How to Contact Us. If you have any questions about our Privacy Policy or the information practices of the App or the Sites, please feel free to contact us at [email protected].