Children's Personal Data Exclusion (COPPA)

What it is

The policy states Zillow's services are not directed to children under 13, that Zillow does not knowingly collect personal data from children under 13, and that upon learning such data was collected, Zillow will promptly delete it. Parents or guardians may contact Zillow to request deletion of a child's data.

Why it matters (compliance & governance perspective)

This provision establishes Zillow's stated compliance posture under the Children's Online Privacy Protection Act (COPPA), which prohibits operators of general audience websites from knowingly collecting personal data from children under 13 without verifiable parental consent. The deletion commitment upon discovery is consistent with standard COPPA compliance practice.

Consumer impact (what this means for users)

Under this clause, parents or guardians who believe a child under 13 has provided personal data to Zillow may contact Zillow to request deletion of that data. Zillow states it will promptly delete personal data upon learning it was provided by a child under 13.

What you can do

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages COPPA, enforced by the FTC, which applies to operators of websites and online services directed to children under 13 or that have actual knowledge of collecting personal data from children under 13. Zillow's characterization of its services as not directed to children is the standard general audience platform defense under COPPA. State analogues including California's Age-Appropriate Design Code (AADC, AB 2273) may impose additional obligations depending on whether minors are likely to access Zillow's services. (2) GOVERNANCE EXPOSURE: Low. This is a standard COPPA compliance disclosure. The primary governance question is whether Zillow's services might be accessible to minors in practice and whether the general audience characterization is substantiated by design choices, terms of service age gates, or other mechanisms. (3) JURISDICTION FLAGS: California's Age-Appropriate Design Code may impose additional obligations regarding minors up to age 17 if Zillow's platform is likely to be accessed by minors, beyond the COPPA threshold of 13. This is a jurisdiction-specific consideration that depends on regulatory interpretation of 'likely to be accessed.' (4) CONTRACT AND VENDOR IMPLICATIONS: Third-party service providers and advertising partners receiving data from Zillow's platforms should have contractual assurances that the data they receive does not include data from users known to be under 13 (and, where applicable, under 18 for advertising purposes, as the policy separately states it does not sell or share data of users known to be under 18 for targeted advertising). (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review whether Zillow maintains age verification or screening mechanisms beyond the policy statement, and whether the separate protection for users under 18 in the targeted advertising context is operationally implemented through account-level controls or data tagging.

Applicable agencies

Provision details

Other risks in this policy

• Business Partner Data Sharing at User Direction high
• Children Under 13 Data Collection Prohibition high
• Cross-Device Linking for Targeted Advertising high
• Interest-Based Advertising via Third Parties high
• No Automated Decision-Making with Legal Effects high
• Personal Data Disclosure in Corporate Transactions high