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The policy states Zillow retains personal data for as long as reasonably necessary for the purposes collected, accounting for account duration, legal and tax obligations, dispute resolution, litigation holds, and regulatory investigations. Upon expiration of the retention need, Zillow states it will delete or de-identify personal data, with the qualification that backup archive copies may be retained.
This analysis describes what Zillow's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes Zillow's stated retention framework but does not specify defined retention periods for any data category, leaving the operative timeframes dependent on the factors listed. The backup archive carve-out means personal data may persist beyond the primary retention period in backup systems until deletion or de-identification is operationally feasible.
Interpretive note: The policy does not specify defined retention periods for any data category, leaving operative retention timelines dependent on factors that are not quantified in the notice.
Under this clause, personal data may be retained for the duration of account activity and for additional periods required by legal, regulatory, or dispute-related obligations, without defined maximum retention timelines stated in the notice. Backup archive copies may be retained beyond the primary retention period in isolated, secure storage pending deletion or de-identification.
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"We strive to retain your personal data only for as long as is reasonably necessary to fulfill the purpose for which it was collected and in accordance with applicable laws. The following is considered in determining appropriate retention periods: The length of time you maintain a user account or use our services. Obligations with legal, tax, and/or accounting requirements set by a legislature, regulator, or other government authority. Support of dispute resolution and claims processes. Compliance with litigation holds, contractual obligations, statutes of limitations, regulatory investigations, or other laws requiring us to keep records of your transactions with us. Once retention of your personal data is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal data. We may retain copies of your personal data in backup archives.Excerpt from Zillow's Privacy Notice
(1) REGULATORY LANDSCAPE: Retention limitations are a component of CCPA/CPRA compliance, which requires that retention periods be disclosed and that data not be retained beyond what is necessary for the disclosed purpose. GDPR storage limitation principles impose similar requirements for EU users if in scope. The absence of defined retention periods for specific data categories may engage regulatory scrutiny under frameworks requiring specific and transparent retention disclosures. (2) GOVERNANCE EXPOSURE: Medium. The retention framework described is principles-based rather than defining specific periods for data categories such as geolocation data, home search histories, or payment records. This approach is common but may create compliance gaps under statutes or regulatory guidance requiring more specific disclosures. (3) JURISDICTION FLAGS: California (CPRA) requires that businesses disclose retention periods or the criteria used to determine retention, which Zillow's criteria-based approach may satisfy depending on regulatory interpretation. EU/EEA contexts under GDPR require that retention periods or criteria be disclosed for each processing purpose, which is a higher specificity standard. (4) CONTRACT AND VENDOR IMPLICATIONS: Service providers and data processors receiving Zillow data should have contractual retention obligations aligned with Zillow's framework. The backup archive carve-out should be reflected in vendor contracts to ensure backup data is handled consistently with the primary retention policy. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the criteria-based retention disclosure satisfies the specificity requirements of applicable state statutes, and whether data maps reflect the backup archive retention mechanism for all personal data categories. Litigation hold procedures referenced in the policy should be documented in internal records retention schedules.
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This provision establishes Zillow's stated retention framework but does not specify defined retention periods for any data category, leaving the operative timeframes dependent on the factors listed. The backup archive carve-out means personal data may persist beyond the primary retention period in backup systems until deletion or de-identification is operationally feasible.
Under this clause, personal data may be retained for the duration of account activity and for additional periods required by legal, regulatory, or dispute-related obligations, without defined maximum retention timelines stated in the notice. Backup archive copies may be retained beyond the primary retention period in isolated, secure storage pending deletion or de-identification.
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