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The policy discloses that sharing personal information with advertising partners may qualify as a 'sale' or 'sharing' under California law, and provides opt-out mechanisms via a footer link and app settings.
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 Zillow's compliance with CCPA/CPRA opt-out obligations and operationalizes the consumer right to halt advertising-related data transfers classified as sales or sharing under California law.
Interpretive note: The classification of specific advertising partner data transfers as 'sales' or 'sharing' under CCPA/CPRA depends on the technical and contractual specifics of each partner relationship, which are not fully detailed in the policy text.
Explicitly acknowledges California privacy law definitions and provides clear opt-out mechanism, making compliance with CCPA/CPRA requirements more transparent and actionable.
View full change record →Under this clause, users can opt out of the transfer of their personal information to third-party advertising partners by using the designated link or app setting; the terms authorize continued sharing absent an opt-out.
How other platforms handle this
If you choose to reveal any personal information about yourself to other users, you do so at your own risk. We strongly encourage you to use caution in disclosing any personal information online.
When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services.
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"We may share your personal information with third-party advertising partners in ways that may constitute a 'sale' or 'sharing' of personal information under California law. You have the right to opt out of the sale or sharing of your personal information. To exercise this right, click the 'Do Not Sell or Share My Personal Information' link in the footer of our websites or in the settings of our mobile apps.Excerpt from Zillow's Privacy Notice
1. REGULATORY LANDSCAPE: This provision directly engages the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), enforced by the California Privacy Protection Agency and California Attorney General. The classification of advertising data sharing as a potential 'sale' or 'sharing' triggers mandatory opt-out notice, GPC signal recognition, and restrictions on re-use of personal information post-opt-out under CPRA. Similar opt-out rights exist under the Virginia VCDPA, Colorado CPA, and Connecticut CTDPA for targeted advertising. 2. GOVERNANCE EXPOSURE: High. The characterization of advertising partner data transfers as a potential 'sale' or 'sharing' creates ongoing compliance obligations including opt-out infrastructure maintenance, GPC signal processing, and downstream partner contractual controls. Failure to honor opt-out signals or to maintain compliant data flows post-opt-out represents a material CPPA enforcement risk. 3. JURISDICTION FLAGS: California creates the highest exposure given CPRA's enforcement framework and the CPPA's active rulemaking. Virginia, Colorado, and Connecticut residents have analogous opt-out rights for targeted advertising; compliance workflows should be verified across all four jurisdictions. Illinois and other states with pending or enacted privacy legislation may create additional obligations as frameworks mature. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partners receiving personal information under this framework should be assessed as to whether data processing agreements include CCPA/CPRA-compliant service provider or contractor terms, or whether the transfer is correctly characterized as a sale. Procurement teams should review partner contracts for opt-out honoring requirements and downstream use restrictions. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit GPC signal recognition across all Zillow Group web properties, verify that the opt-out link is present and functional in all site footers and app settings, and confirm that opt-out requests are processed within the statutory timeframes required by CCPA/CPRA and analogous state laws. Data mapping should identify all third parties receiving personal information through advertising integrations.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes Zillow's compliance with CCPA/CPRA opt-out obligations and operationalizes the consumer right to halt advertising-related data transfers classified as sales or sharing under California law.
Under this clause, users can opt out of the transfer of their personal information to third-party advertising partners by using the designated link or app setting; the terms authorize continued sharing absent an opt-out.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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