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 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.

In processing any personal data which you provide to Zeelo, we shall comply with the obligations set out in General Data Protection Regulation (“GDPR”) legislation.

There may also be further changes which we will be required to make to this privacy policy based on changes in applicable laws – we will notify you every time we make a change to this policy. We may need to ask you to agree to the changes or refresh your consent to us using your personal information.

Effective as of 30/09/2022.

1. Who we are and how you can contact us

We are Zeelo, Inc. Our principal office is at 859 Willard Street, Suite 400, Quincy, Massachusetts, 02169.

You can contact us by email at [email protected] or by calling us on +1 716-575-2271.

If you need to you can write to us at Zeelo Inc., 859 Willard Street, Suite 400, Quincy, Massachusetts, 02169.Our representative for all queries in relation to this policy and your data protection rights is Sam Ryan.

When we refer to our website, we mean our Website at https://zeelo.co.


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 we collect when you use our services:

- Profile, usage and location data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies and other internet tracking software

- Trip information and statistics

- Location data of any of our drivers

Data from third parties we work with:

- Payment and transaction data

- Data from your Sponsor


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.

Financial data – bank account and payment card details.

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.

Profile data - your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage data – information about how you use our website, products and services.

Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences. This includes your registered interest in specific events.

Journey data – information about the journeys you take in relation to the services offered by Zeelo.

Location data - data about your location when running our mobile applications.

Sponsor name – information about which company you work for and use their services

If you are one of our Transportation Provider’s contracted drivers, we may store your personal data such name, email address, contact number 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. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.


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
- Legitimate interests
To manage payments or collect and recover money owed to us
- Identity
- Contact
- Transaction
- Performance of a contract with you
- Legitimate interests
- To recover any debts owed to us
To manage our relationship with you, including notifying you about changes to our terms or privacy notices
- Identity
- Contact
- Transaction
- Performance of a contract with you
- Legitimate interests
- Necessary to comply with a legal obligation
- To keep our records up to date
To enable you to partake in a prize draw, competition or to complete a survey
- Identity
- Contact
- Transaction
- Performance of a contract with you
- 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
- Transaction
- 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, products / services, marketing, customer relationships and experiences website and app content
- Technical
- Usage
- Profile
- Location
- 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 make suggestions and recommendations to you about goods or services that may be of interest to you
- Identity
- Contact
- Marketing and communications
- Technical
- Profile Usage
- Location
- Legitimate interests
- To develop our services and grow our business
To register you as a driver
- Identity
- Contact
- Transaction
- Performance of a contract with you
- Legitimate interests
- To keep our records up to date
To communicate with your Sponsor
- Identity
- Contact
- Performance of a contract with you
- Legitimate interests
- To respond to any queries from your Sponsor
5. Who we share your personal information with

We may share your personal information with any of the following organisations, for the purposes of providing the services which you have requested from us:

- Agents and advisers that we use

- Credit reference agencies

- HM Revenue & Customs and other regulators or authorities

- Referral Candy

- Stripe

- Intercom

- Hubspot

- Coach Operators who fulfil our journeys (in this instance we only provide passenger names)

- Organisations that have commissioned and pay Zeelo for services you ride e.g. your school or employer

- Bank or finance provider

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 who we share your data with to respect the security of your personal data and to treat it in accordance with the law. 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 information outside the EEA

The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA we have to tell you.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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.

- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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


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 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 Sponsor 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 Sponsor

- 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, or your Sponsor is the sponsor of the offering.

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

You have certain rights which are set out in the applicable law relating to your personal information.
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