Privacy Policy

Your personal information

This privacy policy explains how we collect and process your personal data. Personal data, or personal information, means any information about an individual from which that person can be identified. This includes information that you tell us, what we learn from you using our services and the choices you make about the marketing you want us to send to you. This policy explains how we do this, what your rights are and how the law protects you.

Last updated 27 June 2025.

1. Who we are and how you can contact us

We are Zeelo. Our principal offices are: 
• Zeelo, Inc., 859 Willard Street, Suite 400, Quincy, Massachusetts, 02169.
• Zeelo Limited, Building 423 - Sky View (Ro) Argosy Road, East Midlands Airport, Derby, England, DE74 2SA.

You can contact us by email at contact@zeelo.co or by calling us on +1 716-575-2271 (US) or 0330 808 3306 (UK).

Our representative for all queries in relation to this policy and your data protection rights is Chris Hall. Our GDPR Article 27 Local Representative is Daniel Ruiz.

When we refer to our website, we mean our Website at https://zeelo.co, including https://app.zeelo.co and https://portal.zeelo.co. When we refer to our Rider App or Driver App, we mean our “Zeelo” and “Zeelo Driver” apps, respectively, which are downloadable on iOS or Android. 


2. Where we collect your personal information from

We may collect personal information about you in the following ways:

Data you give to us:

- Data you give to us when you register to use our services

- When you talk to us on the phone

- When you use our website or web chat

- In emails or letters to us

- If you take part in our competitions or promotions

- When you give us feedback

- When you use our mobile applications

Data your school or employer gives us

- Data your school or employer gives us when setting up the transit program


3. Data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data – name, username, title, date of birth.

Contact data – billing address, pick up or home address (zip codes), email addresses or telephone numbers.

Transaction data – details about payments to and from you and other details of services you have purchased from us.

Technical data - internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences.

Journey data – information about the journeys you take in relation to the services offered by Zeelo.
If you are one of our Transportation Provider’s contracted drivers, we may store your personal data such as name, email address, contact number, location data while driving a service for us, and any passenger reviews in relation to the Services provided.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature. 


4. How we use your personal information

Your privacy is protected by applicable law in your jurisdiction.

We only use personal information about you if we have a legal basis to do so, and we will tell you what that legal basis is. We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.

In some circumstances, we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.
What we use your personal information for
What personal information we collect
Our legal grounds for processing
Our legitimate interests (if applicable)
To register you as a new customer
Identity, Contact
Performance of a contract with you
To process and deliver your order
Identity, Contact, Transaction
Performance of a contract with you
To manage payments or collect and recover money owed to us
Identity, Contact, Transaction
Performance of a contract with you

To manage our relationship with you, including notifying you about changes to our terms or privacy notices
Identity, Contact, Transaction
Necessary to comply with a legal obligation

To enable you to complete a survey
Identity, Contact, Transaction
Legitimate interests
To study how customers use our services and to grow our business
To administer and protect our business and our website
Transaction, Technical, Usage
Legitimate interests
Running our business, provision of administration and IT services, network security
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity, Contact, Marketing and communications, Usage, Profile, Location, Website and app content
Legitimate interests
To study how customers use our services and to grow our business
To use data analytics to improve our website
Technical, Usage, Profile, Website and app content
Legitimate interests
To define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To register you as a driver
Identity, Contact, Transaction
Performance of a contract with you

To communicate with your employer or school
Identity, Contact
Performance of a contract with you
To respond to any queries from your employer or school
5. Who we share your personal information with

Drivers - We share your names with drivers in order to allow them to manage the boarding process.

Your employer or school - We may share your names and ride histories with your school or employer, as outlined in our contract with them, to report to them about the ridership on the service.

Sub-processors - we may share your personal information with data processing vendors for the purposes of providing the services which you have requested from us. Please see the list at zeelo.co/sub-processor.
You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request.
We require all organisations with whom we share your data to uphold the same standards as we commit to uphold to you, including data security measures, confidentiality, data breach notification, return or deletion of data upon termination, and assistance with data subject rights. We do not allow any of our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


6. Failing to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with your Sponsor and you fail to provide that data when requested, we may not be able to facilitate the provision of Services for you.

7. Third party links

Our Website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice or policy of every website you visit.


8. Transferring your personal across international borders

Our primary data processing location is in the UK and but we or suppliers we use may process data in other countries. Whenever we transfer your personal data out of your country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of your country.


9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.


10. How long do we keep your personal information

We will keep your personal information for as long as you are our Passenger.
After you stop being a Passenger, because you have stopped regularly using our services, or your school or employer has notified us that you are no longer an employee, student or other affiliated person, we may keep your personal information for up to two years for one of the following reasons:

- to respond to any questions or complaints from you or your school or employer

- to satisfy any legal or regulatory requirements


11. Marketing

We may use your personal information to tell you about relevant services and any upcoming promotions.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.

You can ask us to stop sending you marketing messages at any time – you just need to contact us, or use the opt-out/unsubscribe links on any marketing message sent to you.

We will get your express opt-in consent before we share your personal data with any company other than us for marketing purposes. You can ask a third party company to stop sending you marketing messages at any time, by adjusting your marketing preferences for that company or by using the opt-out links on any marketing message sent to you.

Opting out of receiving marketing messages will not affect any communication in connection with any transaction between you and us.


12. Your rights

Rights for US Data Subjects

You have certain rights which are set out in the applicable law relating to your personal information. These laws may include, but are not limited to, the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and other similar state-level privacy regulations, and will update our practices as new laws take effect.

Please note that Zeelo does not sell personal information.

Rights for UK/Europe Data Subjects

Getting a copy of the information we hold

You can ask us for a copy of the personal information which we hold about you. This is known as a data subject access request.

You will not have to pay a fee to access your personal data, unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances we can charge a reasonable fee or refuse to comply with your request.

We will try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month and in that case we will notify you and keep you updated.

Telling us if information we hold is incorrect

You have the right to question any information we hold about you that you think is wrong or incomplete. We will take reasonable steps to check its accuracy and, if necessary, correct it.

Telling us if you want us to stop using your personal information

You have the right to:

- object to our use of your personal information (known as the right to object); or

- ask us to delete the personal information (known as the right to erasure); or

- request the restriction of processing; or

- ask us to stop using it of there is no need for us to use it (known as the right to be forgotten). There may be legal reasons why we need to keep or use your data, which we will tell you if you exercise one of the above rights.

Withdrawing consent

You can withdraw your consent to us using your personal information at any time. If you withdraw your consent, we will not be able to provide you with any services that depend on the data you have withdrawn consent for.

Request a transfer of data

You may ask us to transfer your personal information to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Making a complaint

Please let us know if you are unhappy with how we have used your personal information by contacting us. You also have a right to complain to the Information Commissioner's Office. You can find their contact details at www.ico.org.uk. We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.To exercise any of these rights, please contact us by email at contact@zeelo.co.
What we use your personal information for
To register you as a new customer
What personal information we collect
- Identity
- Contact
Our legal grounds for processing
- Performance of a contract with you
What we use your personal information for
To process and deliver your order
What personal information we collect
- Identity
- Contact
- Transaction
Our legal grounds for processing
- Performance of a contract with you
- Legitimate interests
What we use your personal information for
To manage payments or collect and recover money owed to us
What personal information we collect
- Identity
- Contact
- Transaction
Our legal grounds for processing
- Performance of a contract with you
- Legitimate interests
Our legitimate interests (if applicable)
- To recover any debts owed to us
What we use your personal information for
To manage our relationship with you, including notifying you about changes to our terms or privacy notices
What personal information we collect
- Identity
- Contact
- Transaction
Our legal grounds for processing
- Performance of a contract with you
- Legitimate interests
- Necessary to comply with a legal obligation
Our legitimate interests (if applicable)
- To keep our records up to date
What we use your personal information for
To enable you to partake in a prize draw, competition or to complete a survey
What personal information we collect
- Identity
- Contact
- Transaction
Our legal grounds for processing
- Performance of a contract with you
- Legitimate interests
Our legitimate interests (if applicable)
- To study how customers use our services and to grow our business
What we use your personal information for
To administer and protect our business and our website
What personal information we collect
- Transaction
- Technical Usage
Our legal grounds for processing
- Legitimate interests
Our legitimate interests (if applicable)
- Running our business, provision of administration and IT services, network security
What we use your personal information for
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
What personal information we collect
- Identity
- Contact
- Marketing and communications
- Usage
- Profile
- Location
- Website and app content
Our legal grounds for processing
- Legitimate interests
Our legitimate interests (if applicable)
- To study how customers use our services and to grow our business
What we use your personal information for
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences website and app content
What personal information we collect
- Identity
- Contact
- Marketing and communications
- Usage
- Profile
- Location
Our legal grounds for processing
- Legitimate interests
Our legitimate interests (if applicable)
- To define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
What we use your personal information for
To make suggestions and recommendations to you about goods or services that may be of interest to you
What personal information we collect
- Identity
- Contact
- Marketing and communications
- Technical
- Profile Usage
- Location
Our legal grounds for processing
- Legitimate interests
Our legitimate interests (if applicable)
- To develop our services and grow our business
What we use your personal information for
To register you as a driver
Our legal grounds for processing
- Identity
- Contact
- Transaction
What personal information we collect
- Legitimate interests
Our legitimate interests (if applicable)
- To keep our records up to date
What we use your personal information for
To communicate with you in the event that we believe you have been in contact with a passenger who has covid-19
What personal information we collect
- Identity
- Contact
Our legal grounds for processing
- Legitimate interests of keeping you safe while travelling