Beat the heavy cream in a large bowl until stiff peaks form, about 3 to 4 minutes.

Stir together the sweetened condensed milk, orange juice, and zest in a small bowl, then gently fold into the whipped cream until no streaks remain.

Transfer to a freezer-safe container, cover the surface directly with parchment or plastic wrap, and freeze at least 6 hours. Let soften 5 minutes at room temperature, then scoop and serve.