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The policy states Zillow may collect approximate location inferred from IP address automatically, and may collect precise GPS geolocation data if the user grants permission through device or browser settings. The stated purpose for precise geolocation collection is to provide property information near the user's location.
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 that Zillow collects two distinct categories of location data: approximate location derived from IP address (collected without specific user permission) and precise GPS coordinates (collected only with device-level permission). Several state privacy laws treat precise geolocation as sensitive personal data subject to heightened consent or opt-out requirements, which may interact with this provision's scope.
Under this clause, Zillow will collect approximate location from IP address during normal platform use, while precise GPS location requires affirmative user permission granted through device or browser settings. Users can withdraw permission for precise geolocation collection by adjusting location services settings in their mobile device or browser, as described in the Choices About Your Data section of the policy.
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"We may collect information about the location of your device, such as information derived from your device (e.g., based on a browser or device's IP address). We may also collect more precise geolocation (e.g., GPS latitude and longitude) of your device, if you permit us to collect this information via your device settings when you choose to share it with us through your device or browser settings for purposes of facilitating our services, such as to provide you with information about properties near you.Excerpt from Zillow's Privacy Notice
(1) REGULATORY LANDSCAPE: Precise geolocation data is classified as sensitive personal information under the CCPA/CPRA, which imposes heightened processing requirements including the right to limit use and disclosure of sensitive personal information. Several other state privacy statutes (Virginia VCDPA, Colorado CPA, Connecticut CTDPA) similarly treat precise geolocation as sensitive data requiring opt-in consent or heightened notice. The FTC has characterized precise geolocation as a sensitive data category in enforcement guidance. (2) GOVERNANCE EXPOSURE: Medium. The collection of precise GPS data with user permission and approximate location without specific permission is a common platform practice, but the sensitive data classification under multiple state statutes requires that Zillow maintain compliant consent mechanisms, purpose limitation controls, and disclosure obligations specific to this data category. The stated purpose (property information near the user) should be evaluated for consistency with any secondary uses of location data in advertising or analytics contexts. (3) JURISDICTION FLAGS: California (CCPA/CPRA) creates the most defined obligations for sensitive personal information including precise geolocation, including the right to limit use. Colorado, Connecticut, and Virginia have analogous sensitive data provisions. Illinois does not have a general comprehensive privacy statute but has specific statutes (BIPA) that could be relevant if biometric data were involved, which it is not here. (4) CONTRACT AND VENDOR IMPLICATIONS: If precise geolocation data is shared with service providers or advertising partners, those disclosures should be evaluated for consistency with sensitive data processing restrictions under applicable state statutes. Data processing agreements should reflect the sensitive data classification and applicable purpose limitations. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that device-level permission prompts for precise geolocation satisfy applicable state consent requirements for sensitive data, and that location data flows are documented in data maps with the sensitive data classification noted. The policy's statement that Zillow may still infer approximate location after a user withdraws precise geolocation permission should be reviewed for consistency with user expectations and applicable law.
This provision establishes that Zillow collects two distinct categories of location data: approximate location derived from IP address (collected without specific user permission) and precise GPS coordinates (collected only with device-level permission). Several state privacy laws treat precise geolocation as sensitive personal data subject to heightened consent or opt-out requirements, which may interact with this provision's scope.
Under this clause, Zillow will collect approximate location from IP address during normal platform use, while precise GPS location requires affirmative user permission granted through device or browser settings. Users can withdraw permission for precise geolocation collection by adjusting location services settings in their mobile device or browser, as described in the Choices About Your Data section of the policy.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Zillow.