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The agreement states that T-Mobile collects personal data from social media companies, financial institutions, credit reporting agencies, and data resellers, supplementing data collected directly from consumers and automatically through network interactions.
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 consumer profiles at T-Mobile are built in part from externally purchased or obtained data sourced from data resellers, social media companies, and credit reporting agencies, which are then combined with internally collected network, usage, and account data for uses described throughout the notice.
Under this clause, personal data obtained from data resellers, social media companies, and credit reporting agencies is combined with T-Mobile's internally collected data to supplement and update consumer profiles, including demographic and interest data used in advertising programs. The agreement also states T-Mobile may create inferences about consumers from this combined data.
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"From other sources. For example, from companies that we own, our business partners, our vendors, and other third parties. This includes social media companies, financial institutions, credit reporting agencies, and data resellers.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: Collection of data from credit reporting agencies engages the Fair Credit Reporting Act regarding permissible purposes for obtaining consumer report information. Collection from data resellers may trigger state data broker registration requirements in California, Vermont, and other states with data broker statutes. The CCPA's provisions on the right to know the sources of personal data apply to data obtained from third-party resellers. The FTC Act applies as a framework for unfair or deceptive practices in data aggregation. 2) GOVERNANCE EXPOSURE: Medium. The combination of externally sourced data from data resellers and social media companies with internally collected network, usage, and CPNI data creates an aggregated consumer profile that is more extensive than what consumers directly provide. The specific data resellers used are not identified in the notice. 3) JURISDICTION FLAGS: California's CCPA requires disclosure of the categories of sources from which personal data is collected, which this provision satisfies at a categorical level, though specific source enumeration is not provided. Vermont's data broker registration statute may apply to data resellers supplying T-Mobile. States with enacted comprehensive privacy laws requiring source transparency should be assessed. 4) CONTRACT AND VENDOR IMPLICATIONS: Contracts with data resellers should confirm that data was collected with appropriate consumer notice and consent for onward commercial use. Due diligence on data reseller practices is relevant given FTC enforcement posture on data broker sourcing practices. Credit reporting agency data use must be documented under FCRA permissible purpose requirements. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain an inventory of third-party data sources including specific data resellers and social media platform data partners, and assess whether data acquisition agreements include appropriate representations regarding the lawfulness of the underlying data collection. FCRA compliance documentation for credit reporting agency data use should be reviewed.
This provision establishes that consumer profiles at T-Mobile are built in part from externally purchased or obtained data sourced from data resellers, social media companies, and credit reporting agencies, which are then combined with internally collected network, usage, and account data for uses described throughout the notice.
Under this clause, personal data obtained from data resellers, social media companies, and credit reporting agencies is combined with T-Mobile's internally collected data to supplement and update consumer profiles, including demographic and interest data used in advertising programs. The agreement also states T-Mobile may create inferences about consumers from this combined data.
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