Well, in theory, the data is striped across all of the drives, along with parity. If they were to run a program that tries to sift for particular file types(txt, jpeg, etc), and the file is smaller than the stripe size, they have a chance of finding the data. So technically, I'd say there is a non-zero chance of them recovering data. But do they care enough to look at your exact disk among the 100s(or 1000s) they receive ever day? If the drive is so broken you're RMAing the drive, its possible you won't be able to complete a disk wipe anyway(it'll get stuck at some point and probably not be able to continue).
If you are that worried about it you should use a zpool with encryption. Then they'd not only have to decrypt the drive, they'd also have to sift for data types. I generally just RMA the drive and don't worry about the fact that the drive had personal files on it, but I do delete the partition table(which is pretty much N/A for ZFS).
Keep in mind most people don't have a clue what ZFS is, so if some Best Buy equivalent geek got a hold of your drive somehow he'd be wondering what file system it had. When it wasn't a standard format(NTFS, FAT32, ext, etc) he'd probably give up.