4. Zillow — A De Facto Phone Company

Tech 101 — PSTN and VoIP

PSTN (Public Switched Telephone Network)

The PSTN (Publicly Switched Telephone Network) is the network that carries your voice calls when you call from a landline or cell phone. It refers to the worldwide network of voice-carrying telephone infrastructure, including privately-owned and government-owned infrastructure.

Think AT&T, T-Mobile, and Verizon.

Source: 🛜 PSTN (Public Switched Telephone Network)

Voice Over Internet Protocol (VoIP)

Voice Over Internet Protocol (VoIP) is a category of hardware and software that enables voice calls to be made and received over the internet.

Source: 🛜 What is VoIP (Voice Over IP)?

Think Apple FaceTime, Google Voice, and WhatsApp.

Twilio — A Communication Power Company

Introducing Twilio (NYSE: TWLO)

Chatting with customer support, receiving an appointment reminder, messaging your rideshare driver, getting a personalized coupon in your inbox, video conferencing with your doctor—all of those interactions have something in common: they’re powered by Twilio.

Source: 🛜 What is Twilio? An introduction to the leading customer engagement platform

Twilio is a toll bridge that connects PSTN and VoIP.

Twilio provides the PSTN connection to a business the way the power company provides the electricity. It is incumbent on the owner to wire the building and connect it to the power box.

Behind the walls of Follow Up Boss is the wiring, the system, that connects the professional to consumers via Twilio.

Zillow is operating as a de facto phone company for professionals using Follow Up Boss.

How it All Works

Introducing JoSH

Follow Up Boss released the phone numbers to me that Jean Scott Homes had been using. I wired JoSH in Cloudflare (its building) and connected it to Twilio. JoSH is Jean Scott Homes’ business phone service.

JoSH and Follow Up Boss are effectively the same system except in scale. JoSH is designed for Jean Scott Homes’ in-house use only. Follow Up Boss is a communications service with over 100,000 subscribers.

A consumer on T-Mobile calls Jean Scott Homes on JoSH.

Consumer T-Mobile Twilio JoSH (Cloudflare) Jean Scott Homes

Follow Up Boss

A consumer on T-Mobile calls a professional on Follow Up Boss.

Consumer T-Mobile Twilio Follow Up Boss (AWS) 100,000 Professionals

Zillow Touts its 2023 Scorecard

Over 100,000 real estate agents now use FUB

You added 87,216,632 leads to Follow Up Boss

Source: 1,691 CRM updates keeping 100k agents ahead of the game: 2023 recap & 2024 preview — “2023 scorecard” — Dated Jan. 4, 2024, Captured March 4, 2024 by Archive.org

A lead is a consumer.

Providing Phone Service for Ten Years

Follow Up Boss has been offering business phone service since at least Nov. 15, 2016.

Dan Corkill, Nov. 15, 2016

Benefits of Making the Switch — Communications

We also released a new ‘Inbox’ feature which gives you a central spot to review and respond to any texts or emails that have come in from your sales leads and clients.

We also integrated texting into the heart of the desktop and mobile app interfaces so it’s easy to start and continue conversations with leads via text and have everything be properly tracked and logged.

We also created a built-in calling feature (optional paid add-on) which includes click to call, recording, incoming calls, voicemails, etc.

Source: Follow Up Boss 2 — Our Biggest Update Ever — Dated Nov. 15, 2016, Captured Aug. 31, 2021 by Archive.org

The Scale to Nine Zeros

Jean Scott Homes used Follow Up Boss for about 3 1/2 years with an average of eight team members. The team produced 160,872 text messages and 50,502 phone calls. Combined, the average is about 7,500 per team member per year or about 21 per day.

I recognize that eight is a very small sample out of 100,000. However, Jean Scott Homes is within the norm of real estate teams regarding the number of transactions it closes per year per person. The number of phone calls and text messages the business generates per transaction is normal and ordinary.

I used conservative estimates of 5,000 communications per subscriber per year and an average of 40,000 subscribers over 10 years. That totals 2,000,000,000 individual communications. Each communication involves at least two people.

Visibility into Consumers’ Communication

As Jean Scott Homes’ Operations and Technology Manager, I have complete visibility into the real-time and historical communication between Jean Scott Homes and customers. I have access to:

• The phone numbers of all parties for every call and text.
• Date, time, and direction of calls and texts. Duration of phone calls.
• Full phone call voice recordings and verbatim transcripts.
• Full content of SMS text and MMS media messages.
• Every Microsoft 365 Business email.

Zillow has the same visibility into 100,000 of its customers’ and millions of consumers’ phone calls, text messages, and emails.

Zillow Group Policies and Terms

Note: 📒 Screenshots 💁🏻‍♀️ in this chapter were captured on March 30, 2026.

Follow Up Boss Privacy Notice Addendum

Covered in Chapter 3.1.

2. Definitions

“End Customer Data” means personal information about your End Customers (e.g., existing clients and prospects), such as your Contact List and the content of your communications (e.g., texts, phone calls, emails) with End Customers.

Source: 💁🏻‍♀️ Follow Up Boss Privacy Notice Addendum — 2. End Customer and End Customer Data Defined

4. Information We Collect Through the Services

Customer Communications: the content of messages and related data exchanged between Customers (or their Authorized Users) and End Customers through the Services, including emails, text messages, phone calls, and other communications sent or received via the Follow Up Boss platform.

Source: 💁🏻‍♀️ Follow Up Boss Privacy Notice Addendum — 4. Information We Collect

6. How We Share Information

Affiliated companies or successors as permitted by law to facilitate business transitions. In connection with a merger, acquisition, sale of assets, bankruptcy, or other corporate transaction, we may disclose or transfer some or all of your Customer Data and End Customer Data as part of the business transfer. If there is a material change in ownership or control of your Customer Data and End Customer Data, we will provide notice as set forth herein.

Source: 💁🏻‍♀️ Follow Up Boss Privacy Notice Addendum — 6. How We Share Information

Zillow Terms of Use

Covered in Chapter 3.3.

19. Consent to Communications.

We also use the Communications Service to track phone calls and text messages between you and real estate professionals so that we and the real estate professional can access certain details about the contact. As part of this process, we and the Communications Service will receive in real time, and store, data about your call or text message, including the date and time of the call or text message, your phone number, and the content of the text message. You consent to these practices by us and the Communications Service.

Source: 💁🏻‍♀️ Zillow Terms of Use — 19. Consent to Communications.

The Email-Phone Connection Question

When a consumer purportedly consents to these provisions, she is providing her name and email address to create a Zillow.com profile. It is unclear how Zillow can reliably link that email address to a phone number. Even if it could, Zillow has no way of knowing whether the person using that number on every call and text message is the same person who purportedly agreed to its terms.

State of Florida Policies and Terms

Source: 🛜 Florida Security of Communications; Surveillance Act — Fla. Stat. § 934

Fla. Stat. § 934.02 — Definitions

(3) “Intercept” means the aural or other acquisition of the contents of any wire, electronic, or oral communication through the use of any electronic, mechanical, or other device.

(5) “Person” means any employee or agent of the State of Florida or political subdivision thereof, of the United States, or of any other state or political subdivision thereof, and any individual, partnership, association, joint stock company, trust, or corporation.

(12) “Electronic communication” means any transfer of signs, signals, writing, images, sounds, data, or intelligence of any nature transmitted in whole or in part by a wire, radio, electromagnetic, photoelectronic, or photooptical system that affects intrastate, interstate, or foreign commerce...

(14) “Electronic communications system” means any wire, radio, electromagnetic, photooptical, or photoelectronic facilities for the transmission of wire or electronic communications, and any computer facilities or related electronic equipment for the electronic storage of such communications.

(15) “Electronic communication service” means any service which provides to users thereof the ability to send or receive wire or electronic communications.

Source: 🛜 Florida Security of Communications; Surveillance Act — Fla. Stat. § 934.02

Fla. Stat. § 934.03 — Interception and Disclosure of Wire, Oral, or Electronic Communications Prohibited. —

(1) Except as otherwise specifically provided in this chapter, any person who:

(a) Intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to intercept any wire, oral, or electronic communication;

(b) Intentionally uses, endeavors to use, or procures any other person to use or endeavor to use any electronic, mechanical, or other device to intercept any oral communication when:

1. Such device is affixed to, or otherwise transmits a signal through, a wire, cable, or other like connection used in wire communication; or

2. Such device transmits communications by radio or interferes with the transmission of such communication;

(c) Intentionally discloses, or endeavors to disclose, to any other person the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection;

(d) Intentionally uses, or endeavors to use, the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection;

shall be punished as provided in subsection (4).

(2)(d) It is lawful under this section and ss. 934.04 - 934.09 for a person to intercept a wire, oral, or electronic communication when all of the parties to the communication have given prior consent to such interception.

Source: 🛜 Florida Security of Communications; Surveillance Act — Fla. Stat. § 934.03

Fla. Stat. § 934.04 — Manufacture, distribution, or possession of wire, oral, or electronic communication intercepting devices prohibited. —

(1) Except as otherwise specifically provided in this chapter, any person who intentionally:

(b) Manufactures, assembles, possesses, or sells any electronic, mechanical, or other device, knowing or having reason to know that the design of such device renders it primarily useful for the purpose of the illegal interception of wire, oral, or electronic communications as specifically defined by this chapter;

shall be guilty of a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.

Source: 🛜 Florida Security of Communications; Surveillance Act — Fla. Stat. § 934.04

Fla. Stat. § 934.10 — Civil remedies. —

(1) Any person whose wire, oral, or electronic communication is intercepted, disclosed, or used in violation of ss. 934.03-934.09 shall have a civil cause of action against any person or entity who intercepts, discloses, or uses, or procures any other person or entity to intercept, disclose, or use, such communications and shall be entitled to recover from any such person or entity which engaged in that violation such relief as may be appropriate, including:

(a) Preliminary or equitable or declaratory relief as may be appropriate;

(b) Actual damages, but not less than liquidated damages computed at the rate of $100 a day for each day of violation or $1,000, whichever is higher;

(c) Punitive damages;

Source: 🛜 Florida Security of Communications; Surveillance Act — Fla. Stat. § 934.10

Getting Out of Dodge

I realize pretty quickly that Jean Scott Homes is in a precarious situation, and its customers’ privacy is at grave risk. Jean is fully aware of the peril and tells me to get us out of Dodge.

The Afterburners

I scramble and light up the afterburners.

I immediately turn off call recording and disconnect Microsoft 365 Business email from Follow Up Boss.

I need to find one or more new service providers, set up all the accounts, migrate our data, and have everyone trained by end of business, Friday, Nov. 14, 2025.

I have 26 days, counting today.

Chapter 5: The Scramble

Chapter 3.5: Zillow Home Loans