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The policy authorizes Zillow and its third-party partners to link multiple devices belonging to a single user or household using shared account identifiers (such as hashed email addresses) or statistical modeling, and to use that linkage for interest-based advertising, personalized content, analytics, and campaign measurement. This cross-device linking is conducted both by Zillow directly and by third-party partners.
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's advertising and analytics activities may extend across all devices associated with a user or household, using both deterministic (account identifier-based) and probabilistic (statistical modeling-based) methods. Organizations assessing data minimization obligations or proportionality requirements under applicable privacy frameworks should evaluate the scope of this cross-device data processing.
Under this clause, a user's browsing activity and advertising exposure on one device may be linked to other devices they use, based on shared account identifiers or statistical inference conducted by Zillow or its partners. Users may limit some of this activity through device-level settings (iOS Limit Ad Tracking, Android Opt-Out of Interest Based Ads) or through Zillow's cookie preference controls, though the policy notes these opt-outs are browser-specific and may need to be reapplied after device changes.
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"We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We may share a common account identifier (such as a hashed email address or user ID) or work with third-party partners who use tracking technologies or statistical modeling tools to determine if two or more devices are linked to a single user or household. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices (including to improve your user experience), to perform analytics, and to measure the performance of our advertising campaigns.Excerpt from Zillow's Privacy Notice
(1) REGULATORY LANDSCAPE: Cross-device linking using hashed email addresses and statistical modeling engages CCPA/CPRA provisions governing the sharing of personal data for cross-context behavioral advertising, as well as analogous state privacy statutes. In EU/EEA contexts, GDPR proportionality and purpose limitation principles, along with ePrivacy Directive requirements for tracking technologies, would be relevant if Zillow's services are accessible to EU residents. The FTC has published guidance on cross-device tracking in the context of behavioral advertising. (2) GOVERNANCE EXPOSURE: Medium. The use of statistical modeling to probabilistically associate devices with a single user or household without that user's explicit consent to the linkage itself (as distinct from consent to advertising) may raise questions under privacy frameworks requiring purpose-specific consent or legitimate interest assessments. The involvement of third-party partners in this processing creates additional vendor oversight obligations. (3) JURISDICTION FLAGS: California (CCPA/CPRA) creates the most defined obligations, as cross-device linking used for cross-context behavioral advertising falls within the statute's sharing definition. EU/EEA users, if applicable, would engage GDPR lawful basis requirements for processing involving statistical inference. Illinois and other states with biometric or sensitive data statutes are less directly implicated by this provision unless biometric identifiers are used in the linking process, which the notice does not indicate. (4) CONTRACT AND VENDOR IMPLICATIONS: The provision discloses that third-party partners conduct statistical modeling for cross-device linking. Procurement teams should verify that data processing agreements with these partners define the scope of modeling permitted, data retention timelines for linked device graphs, and restrictions on secondary use of linked device data beyond the stated advertising and analytics purposes. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the cross-device linking disclosure is sufficiently specific to satisfy state law transparency requirements, and whether opt-out mechanisms for cross-device advertising are operationally distinct from general cookie opt-outs. Data maps should reflect the flow of account identifiers and device graphs to third-party modeling partners.
This provision establishes that Zillow's advertising and analytics activities may extend across all devices associated with a user or household, using both deterministic (account identifier-based) and probabilistic (statistical modeling-based) methods. Organizations assessing data minimization obligations or proportionality requirements under applicable privacy frameworks should evaluate the scope of this cross-device data processing.
Under this clause, a user's browsing activity and advertising exposure on one device may be linked to other devices they use, based on shared account identifiers or statistical inference conducted by Zillow or its partners. Users may limit some of this activity through device-level settings (iOS Limit Ad Tracking, Android Opt-Out of Interest Based Ads) or through Zillow's cookie preference …
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