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The agreement states that personal data collected across all categories described in the notice may be used to train artificial intelligence models, with examples including network improvement and customer service enhancement.
This analysis describes what T-Mobile'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 AI model training as a stated purpose for personal data use across all collected data categories, without specifying which categories are excluded from AI training or what separate consent conditions, if any, apply to this use beyond those governing the underlying collection purpose.
Interpretive note: The provision does not specify which data categories are excluded from AI training use, what consent conditions apply separately to AI training, or whether Privacy Dashboard opt-outs limit AI training use, creating ambiguity about the effective scope of consumer control.
Under this clause, personal data T-Mobile collects for service delivery, advertising, and other stated purposes may also be applied to AI model training. The agreement does not specify a separate opt-out mechanism specific to AI training uses, meaning management of this use would depend on the broader Privacy Dashboard controls or data deletion requests.
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"We use personal data to provide, develop, customize, and personalize products and services, including to train artificial intelligence models (e.g., to improve our network, enhance customer service, etc.).Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: The use of personal data for AI model training engages state comprehensive privacy laws, including the CCPA and its implementing regulations, which impose purpose limitation and secondary use disclosure requirements. Emerging state AI-specific statutes and proposed federal AI governance frameworks may also interact with this provision. The FTC Act applies as a general unfair or deceptive practices framework. The California Privacy Protection Agency is the primary enforcement authority under CCPA. 2) GOVERNANCE EXPOSURE: Medium. The provision broadly authorizes AI training from all collected personal data categories without itemizing data category exclusions, training data retention periods, or model governance safeguards. The disclosure satisfies a basic notice obligation but leaves open compliance questions regarding purpose limitation under state law and whether consent obtained for service delivery is sufficient to authorize secondary AI training use. 3) JURISDICTION FLAGS: California creates heightened exposure given CCPA's purpose limitation requirements and the CPPA's active rulemaking on automated decision-making. States with enacted comprehensive privacy statutes (Virginia, Colorado, Connecticut, Texas, Oregon) may require separate analysis. EU and UK data subjects are not clearly addressed in this notice, and if T-Mobile processes EU resident data, GDPR Article 6 lawful basis and purpose limitation requirements would engage. 4) CONTRACT AND VENDOR IMPLICATIONS: If AI model training involves third-party AI infrastructure providers or cloud ML platforms, data processing agreements should specify the scope of personal data used for training, whether models trained on customer data are used only for T-Mobile's benefit, and deletion or anonymization obligations upon contract termination. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate whether the current consent and notice architecture adequately covers AI training as a secondary purpose under applicable state law. A data mapping exercise should identify which specific data categories feed AI training workflows. Review of the Privacy Dashboard opt-out scope should confirm whether exercising available opt-outs effectively removes a user's data from AI training pipelines.
This provision establishes AI model training as a stated purpose for personal data use across all collected data categories, without specifying which categories are excluded from AI training or what separate consent conditions, if any, apply to this use beyond those governing the underlying collection purpose.
Under this clause, personal data T-Mobile collects for service delivery, advertising, and other stated purposes may also be applied to AI model training. The agreement does not specify a separate opt-out mechanism specific to AI training uses, meaning management of this use would depend on the broader Privacy Dashboard controls or data deletion requests.
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