The policy discloses collection of precise geolocation data for service delivery, connection with real estate professionals, and advertising purposes, subject to user consent where required.
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
Precise geolocation is classified as sensitive personal information under CPRA and several other state privacy frameworks, triggering heightened use limitation and opt-out rights beyond those applicable to general personal information.
Interpretive note: The policy states geolocation is collected with consent or as necessary for services, but does not specify the technical mechanism for consent capture or whether advertising-related geolocation use requires separate consent.
Shifted from stating collection occurs to conditional 'may collect' language, added consent requirement, removed mention of sharing with third-party service providers, and added specific use case of connecting with real estate professionals.
View full change record →The agreement authorizes collection of precise geolocation data for listing recommendations, professional connections, and advertising; users in California and other states with sensitive data frameworks have the right to limit this collection and use.
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Geolocation Information
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If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
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"We may collect your precise geolocation data with your consent or as necessary to provide our services. We use this information to provide location-based features, to connect you with nearby real estate professionals, and to serve you with relevant listings and advertisements.— Excerpt from Zillow's Zillow Privacy Notice
1. REGULATORY LANDSCAPE: Precise geolocation is designated sensitive personal information under CPRA, with use limitation rights available to California residents. Similar categorization applies under the Virginia VCDPA, Colorado CPA, and Connecticut CTDPA. FTC guidance on mobile location data and the agency's enforcement posture on geolocation privacy are relevant. In some jurisdictions, location data collected via mobile devices may also engage state electronic communications statutes. 2. GOVERNANCE EXPOSURE: Medium. The dual use of geolocation for both service delivery and advertising creates potential tension with use limitation rights applicable to sensitive data under CPRA and analogous frameworks. Compliance teams should confirm that geolocation data is not used for advertising purposes for users who have exercised sensitive data use limitation rights. 3. JURISDICTION FLAGS: California creates the highest exposure given CPRA's sensitive data framework and the CPPA's enforcement authority. Illinois, Texas, and Washington have specific location data protections that may apply to mobile app data collection. The FTC has brought enforcement actions against companies for non-consensual location data sharing. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving geolocation data should be assessed for compliance with applicable sensitive data restrictions. Data processing agreements should prohibit unauthorized re-use of geolocation data beyond disclosed purposes. 5. COMPLIANCE CONSIDERATIONS: Consent mechanisms for geolocation collection on mobile applications should be reviewed for compliance with platform-specific requirements (iOS, Android) and state law. The policy's characterization of geolocation collection as consent-based should be verified against actual technical implementation.
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Precise geolocation is classified as sensitive personal information under CPRA and several other state privacy frameworks, triggering heightened use limitation and opt-out rights beyond those applicable to general personal information.
The agreement authorizes collection of precise geolocation data for listing recommendations, professional connections, and advertising; users in California and other states with sensitive data frameworks have the right to limit this collection and use.
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