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The agreement states that device usage, app behavior, demographic, and ad interaction data is aggregated and that resulting aggregate reports may be sold to third-party companies, with an opt-out available through the Privacy Dashboard.
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 that aggregate behavioral and demographic reports derived from consumer device and network usage data may be commercially sold to external companies, representing an outbound commercial data product derived from subscriber activity.
Under this clause, T-Mobile aggregates device usage, app behavior, demographic, and ad interaction data into reports that may be sold to other companies. Consumers may opt out of inclusion in the Analytics and Reporting program through T-Mobile's Privacy Dashboard.
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"We collect data about how you use your T-Mobile device, such as network diagnostic information, app usage data like how long the apps are open and how often you open an app. We may use other data you provide to us, like your age range, gender, etc. We may use data we receive from third parties or business partners, including your demographics or if you clicked on an ad. We aggregate this data to look for patterns to better understand your interests, behaviors, and trends. Aggregate reports may be used by T-Mobile or sold to other companies.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: The sale of aggregate reports derived from subscriber device and network usage data engages FCC regulations regarding the use of CPNI for commercial purposes and CCPA provisions regarding the sale of personal data or data derived from personal data. The FTC Act applies as a general framework for commercial data product sales practices. Where aggregate reports incorporate data that is not fully de-identified, CCPA obligations regarding sale and opt-out may attach. 2) GOVERNANCE EXPOSURE: Medium. The commercial sale of aggregate reports is a disclosed revenue activity. The degree to which aggregate reports are derived from individually linked data before aggregation, and whether that intermediate processing constitutes a CCPA-covered processing activity, should be assessed. The opt-out mechanism through the Privacy Dashboard should be verified as technically effective at excluding opted-out consumers from the data pool used in sold reports. 3) JURISDICTION FLAGS: California's CCPA applies to commercial data sales and may require assessment of whether sold aggregate reports incorporate data that retains individual linkability at any stage. FCC jurisdiction applies if CPNI is included in the data underlying aggregate reports. 4) CONTRACT AND VENDOR IMPLICATIONS: Agreements with companies purchasing aggregate reports should specify that reports are derived from de-identified data and prohibit re-identification. The legal basis and data source documentation for sold reports should be maintained for regulatory inquiry readiness. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the Analytics and Reporting opt-out is technically implemented to exclude opted-out consumers from all stages of data aggregation used in commercially sold reports, not just from final report delivery. De-identification standards applied to sold reports should be documented and assessed against applicable regulatory frameworks.
This provision establishes that aggregate behavioral and demographic reports derived from consumer device and network usage data may be commercially sold to external companies, representing an outbound commercial data product derived from subscriber activity.
Under this clause, T-Mobile aggregates device usage, app behavior, demographic, and ad interaction data into reports that may be sold to other companies. Consumers may opt out of inclusion in the Analytics and Reporting program through T-Mobile's Privacy Dashboard.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by T-Mobile.