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The policy states that Zillow uses generative artificial intelligence and machine learning as part of its day-to-day business operations, including for purposes of helping users find homes and connecting them with real estate professionals, lenders, and property managers. The policy references alignment with Zillow's AI Principles but does not detail those principles within the notice itself.
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 discloses that personal data collected across Zillow's platform may be processed using generative AI and machine learning systems. The reference to external AI Principles without incorporating their substance into the privacy notice means users and compliance teams must consult a separate document to assess the scope of AI-related data processing.
Interpretive note: The substantive scope of AI and machine learning data processing is not detailed within this notice and requires review of Zillow's separately referenced AI Principles document.
Under this provision, personal data including search histories, contact information, and behavioral inferences may be processed by Zillow's generative AI and machine learning systems as part of service delivery. The specific data inputs, model types, retention practices for AI-processed data, and human review mechanisms are not described within this privacy notice.
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"Facilitate our day-to-day business operations, such as helping you find your next home, or connect with a real estate professional, lender, or property manager, including using generative artificial intelligence and machine learning in line with Our AI PrinciplesExcerpt from Zillow's Privacy Notice
(1) REGULATORY LANDSCAPE: AI use of personal data engages state privacy statutes that include automated decision-making provisions, including the CPRA (which grants California residents the right to opt out of automated decision-making in certain contexts) and analogous provisions in Colorado and Connecticut. The EU AI Act and GDPR automated decision-making provisions (Article 22) would be relevant if EU users are within scope. The FTC has issued guidance on AI and algorithmic systems in consumer-facing contexts. (2) GOVERNANCE EXPOSURE: Medium. The disclosure is brief and references external AI Principles without substantive detail within the notice. This creates uncertainty about what personal data categories are used as inputs to AI systems, how outputs are used in service delivery, and whether automated decisions affecting users (such as matching algorithms for real estate professionals) involve human review or carry opt-out rights. (3) JURISDICTION FLAGS: California (CPRA) creates the most defined obligations related to automated decision-making. Colorado (CPA) and Connecticut (CTDPA) have adopted profiling and automated decision-making provisions. EU/EEA users, if in scope, would engage GDPR Article 22 requirements for solely automated decisions producing significant effects. (4) CONTRACT AND VENDOR IMPLICATIONS: If third-party AI service providers process Zillow user data as part of generative AI or machine learning workflows, data processing agreements should reflect the scope of permissible processing, data retention for training purposes, and restrictions on secondary use. The notice does not clarify whether user data is used to train AI models, which is a material due diligence question. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should request Zillow's AI Principles document and assess whether it contains substantive commitments regarding data inputs, model governance, opt-out mechanisms, and human review. If Zillow's AI systems produce outputs that affect user experiences in material ways (such as agent matching or property recommendations), the automated decision-making opt-out obligations under applicable state statutes should be assessed.
This provision discloses that personal data collected across Zillow's platform may be processed using generative AI and machine learning systems. The reference to external AI Principles without incorporating their substance into the privacy notice means users and compliance teams must consult a separate document to assess the scope of AI-related data processing.
Under this provision, personal data including search histories, contact information, and behavioral inferences may be processed by Zillow's generative AI and machine learning systems as part of service delivery. The specific data inputs, model types, retention practices for AI-processed data, and human review mechanisms are not described within this privacy notice.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Zillow.