Sharing with Advertising and Analytics Partners

What it is

The policy authorizes disclosure of personal information to advertising and analytics partners for targeted advertising, campaign measurement, and personalization, using cookies and tracking technologies across Zillow properties and third-party sites.

Why it matters (compliance & governance perspective)

This provision establishes the legal and operational basis for cross-context behavioral advertising using Zillow user data, and is directly relevant to CCPA/CPRA opt-out obligations and FTC guidance on online tracking.

Change history

Consumer impact (what this means for users)

Under this clause, personal information including browsing behavior and identifiers may be shared with advertising and analytics partners for targeted advertising purposes; users can opt out of this sharing via the mechanisms described in the policy.

What you can do

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: This provision engages CCPA/CPRA provisions governing sharing of personal information for cross-context behavioral advertising, which is subject to opt-out requirements. FTC guidance on online tracking and the FTC Act's prohibition on unfair or deceptive practices are also relevant. The use of cookies and tracking technologies may engage state wiretapping or electronic communications statutes depending on jurisdiction. 2. GOVERNANCE EXPOSURE: Medium. The use of third-party advertising technology creates risks around undisclosed data flows, particularly if advertising partners independently collect data through tracking technologies on Zillow properties. Compliance teams should assess whether advertising partners' independent collection is adequately disclosed and whether their data practices are consistent with Zillow's policy representations. 3. JURISDICTION FLAGS: California, Virginia, Colorado, and Connecticut residents have specific opt-out rights for targeted advertising. The use of session replay, pixel tracking, or similar technologies may engage California's Invasion of Privacy Act (CIPA) or similar state statutes, creating potential class action exposure. 4. CONTRACT AND VENDOR IMPLICATIONS: Advertising and analytics partner agreements should be reviewed to confirm they classify the relationship correctly (service provider vs. third party) under CCPA/CPRA, and that downstream use of shared data is contractually limited to disclosed purposes. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the full list of advertising and analytics partners, confirm that consent mechanisms and opt-out signals are technically operative, and review cookie consent banners and tracking technology disclosures for accuracy and completeness.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Sale or Sharing of Personal Information and Opt-Out medium
• Categories of Personal Information Collected medium
• State Privacy Rights (Access, Deletion, Correction, Portability, Opt-Out) low
• Geolocation Data Collection and Use medium
• Children's Privacy and Age Restrictions low
• Data Retention Practices low

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