The policy authorizes sharing of contact information and inquiry details with real estate professionals when users initiate or receive contact through the platform, characterizing this as consent-based sharing.
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 a consent-based data sharing mechanism with real estate professionals that is operationally central to Zillow's business model and relevant to users' expectations about who receives their contact and transaction inquiry information.
Interpretive note: The policy characterizes use of the platform to contact professionals as consent to data sharing; whether this constitutes valid affirmative consent under CCPA/CPRA or applicable state law may depend on the prominence and clarity of the disclosure at the point of contact.
Removed automatic sharing with 'other real estate professionals who may be able to assist,' downgraded to conditional 'may share,' and added explicit consent language; severity decreased from high to low.
View full change record →Under this clause, users who initiate contact with or are contacted by agents, lenders, or other professionals through Zillow's platform consent to sharing of their contact information and inquiry details with those professionals; this sharing occurs as part of the platform's core matching functionality.
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"If you contact or are contacted by a real estate agent, lender, or other real estate professional through our services, we may share your contact information and inquiry details with that professional. By initiating contact or requesting information through our platform, you consent to this sharing.— Excerpt from Zillow's Zillow Privacy Notice
1. REGULATORY LANDSCAPE: Sharing of personal information with real estate professionals may engage state real estate licensing laws, RESPA (Real Estate Settlement Procedures Act) for referral and lead-sharing arrangements involving mortgage services, and applicable state privacy laws. RESPA, enforced by the CFPB, prohibits certain kickback and referral fee arrangements that may be relevant to lead-sharing relationships between Zillow and affiliated professionals. 2. GOVERNANCE EXPOSURE: Medium. The characterization of platform use as consent to sharing contact and inquiry data with professionals should be assessed against applicable state law definitions of valid consent and against CCPA/CPRA's specific consent requirements for sharing sensitive information. The breadth of professionals who may receive this data warrants review. 3. JURISDICTION FLAGS: California residents' rights to know and delete may extend to data shared with real estate professionals; compliance teams should confirm that deletion requests can be fulfilled for data shared in this context. RESPA-related concerns are federal in scope. 4. CONTRACT AND VENDOR IMPLICATIONS: Agreements with real estate professionals receiving lead and inquiry data should include data use restrictions consistent with Zillow's privacy policy representations and applicable law. 5. COMPLIANCE CONSIDERATIONS: The implied consent model for professional data sharing should be reviewed against CCPA/CPRA's affirmative consent requirements for sensitive data categories. Disclosure of the categories of professionals who may receive user data should be verified for accuracy.
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This provision establishes a consent-based data sharing mechanism with real estate professionals that is operationally central to Zillow's business model and relevant to users' expectations about who receives their contact and transaction inquiry information.
Under this clause, users who initiate contact with or are contacted by agents, lenders, or other professionals through Zillow's platform consent to sharing of their contact information and inquiry details with those professionals; this sharing occurs as part of the platform's core matching functionality.
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