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The policy states that all categories of personal data Zillow collects may be disclosed to third parties during negotiation of or in connection with a corporate merger, acquisition, joint venture, asset sale, or financing transaction, and also in insolvency, bankruptcy, or receivership proceedings.
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 the full scope of Zillow-collected personal data may be transferred to acquiring or counterparty entities as part of a corporate transaction, including during the negotiation phase before any transaction is completed. This is a standard commercial provision but is operationally significant given the breadth of data categories Zillow collects, including home search histories, contact information, and geolocation data.
Under this clause, all categories of personal data Zillow holds may be disclosed to transaction counterparties in a merger, acquisition, or similar corporate event, or transferred to new owners upon completion of such a transaction. The policy does not specify notice mechanisms or user rights in the event of such a transfer beyond general policy update provisions.
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"We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose your personal data (all categories set forth in 'Our Collection and Use of Personal Data' above) to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Your personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.Excerpt from Zillow's Privacy Notice
(1) REGULATORY LANDSCAPE: Corporate transaction data disclosures engage state privacy statutes that require notice of material changes in data processing, including CCPA provisions related to changes in business ownership. The FTC has addressed data asset treatment in corporate transactions, particularly where privacy policies change following an acquisition. GLBA and FCRA carve-outs noted elsewhere in the notice may affect how financial data specifically is treated in a transaction context. (2) GOVERNANCE EXPOSURE: Low to Medium. This is a standard commercial provision, but the breadth of data categories covered (all categories set forth in the collection section) means that in a transaction scenario, sensitive data including geolocation, home search histories, and financial payment records would be in scope for disclosure. The policy does not restrict how a successor entity may use the transferred data. (3) JURISDICTION FLAGS: California (CCPA) may require notice to consumers if a business transaction results in a material change to how personal data is used. Other state statutes with similar material change notification requirements may also be implicated depending on the transaction structure. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations entering into data processing or integration agreements with Zillow should assess whether this provision affects their own data obligations if Zillow undergoes a corporate transaction and the counterparty or successor entity has different data practices. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether Zillow's policy update notification mechanisms (described in the Updates to this Privacy Notice section) are sufficient to satisfy state law notification requirements in the event of a transaction-related change in data processing.
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This provision establishes that the full scope of Zillow-collected personal data may be transferred to acquiring or counterparty entities as part of a corporate transaction, including during the negotiation phase before any transaction is completed. This is a standard commercial provision but is operationally significant given the breadth of data categories Zillow collects, including home search histories, contact information, and …
Under this clause, all categories of personal data Zillow holds may be disclosed to transaction counterparties in a merger, acquisition, or similar corporate event, or transferred to new owners upon completion of such a transaction. The policy does not specify notice mechanisms or user rights in the event of such a transfer beyond general policy update provisions.
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