The policy states that personal information is retained for as long as necessary to fulfill collection purposes, satisfy legal obligations, resolve disputes, and enforce agreements, with retention periods varying by data type and purpose.
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
Retention period disclosures are required under CCPA/CPRA and are relevant to consumer deletion rights; indefinite or purpose-based retention policies without specific timeframes may be subject to regulatory scrutiny in jurisdictions requiring retention limitation disclosures.
Interpretive note: The policy does not specify retention periods for individual data categories, creating uncertainty about whether the disclosure meets CPRA's specificity requirements.
Changed 'to provide our services' to 'to fulfill the purposes for which it was collected' and revised 'depends' to 'may vary,' making language slightly more conditional.
View full change record →The agreement establishes purpose-based retention without specifying fixed retention periods for most data categories; users with deletion rights under applicable state law can submit deletion requests through Zillow's privacy portal regardless of the stated retention basis.
How other platforms handle this
We retain personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention periods depend on the type of information and the purposes for which it is processed.
We keep information for as long as we need it to provide our products, comply with legal obligations, or for other legitimate purposes, such as to maintain safety, security, and integrity.
After your account is deleted, we keep data about interactions you've had on our service to prevent abuse, ban evaders and others in an effort to protect and ensure the safety and security of our service and our members.
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"We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period may vary depending on the type of information and the purpose for which it was collected.— Excerpt from Zillow's Zillow Privacy Notice
1. REGULATORY LANDSCAPE: CPRA requires businesses to disclose retention periods or the criteria used to determine them for each category of personal information collected. The policy's general purpose-based retention description may not satisfy CPRA's specificity requirements. Virginia, Colorado, and Connecticut privacy laws also impose data minimization and retention limitation obligations. FTC guidance on data retention recommends limiting retention to identified, necessary periods. 2. GOVERNANCE EXPOSURE: Medium. A general purpose-based retention statement without category-specific retention periods or criteria may be subject to challenge under CPRA's disclosure requirements. The CPPA has indicated that retention disclosures are an area of regulatory focus. 3. JURISDICTION FLAGS: California creates the highest exposure given CPRA's specific retention disclosure requirements. The CPPA's enforcement posture on retention disclosures should be monitored. The EU GDPR's storage limitation principle, while not directly applicable absent EU-specific disclosures, reflects a global trend toward retention specificity that may inform future U.S. regulatory expectations. 4. CONTRACT AND VENDOR IMPLICATIONS: Service provider agreements should specify retention obligations and deletion timelines to support Zillow's ability to fulfill consumer deletion requests that require downstream deletion from vendors. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the policy's retention disclosures meet CPRA's specificity requirements and consider adding category-specific retention periods or criteria. Deletion request fulfillment procedures should address data held by third-party service providers.
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Retention period disclosures are required under CCPA/CPRA and are relevant to consumer deletion rights; indefinite or purpose-based retention policies without specific timeframes may be subject to regulatory scrutiny in jurisdictions requiring retention limitation disclosures.
The agreement establishes purpose-based retention without specifying fixed retention periods for most data categories; users with deletion rights under applicable state law can submit deletion requests through Zillow's privacy portal regardless of the stated retention basis.
ConductAtlas has identified this type of provision across 16 platforms. See the full comparison.
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