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T-Mobile's Relevant Ads program operates as a default, collecting app usage data, mobile advertising IDs, and purchased demographic data to build interest models and deliver targeted third-party advertising through advertising partners.
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 targeted advertising using app usage data, mobile advertising IDs, and purchased demographic data operates by default, requiring consumers to actively opt out through the Privacy Dashboard rather than opt in to participate.
Under this clause, T-Mobile delivers interest-based advertising by default using app usage patterns, mobile advertising IDs, and purchased demographic data without requiring prior opt-in. The agreement permits advertising partners to receive audience data for ad delivery in this program.
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"We collect data about which apps you use and how often you use them. This may be combined with other data that you provide to us, or that we buy, like your age or gender. We also collect your mobile advertising ID (MAID). We use this data to create models and inferences about your interests (e.g., sports lover, food enthusiast). We also use this data to measure the impact or success of certain events like advertising campaigns, or to create audiences through grouping, modeling, or scoring by interests. We and our advertising partners serve you ads about other companies tailored to your interests. Your MAID is used to deliver Relevant Ads to you.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: The default enrollment structure of the Relevant Ads program engages CCPA opt-out requirements for data sharing and sale for targeted advertising, and may engage state laws requiring opt-in consent for certain data uses. The FTC Act applies as a framework governing the adequacy of disclosure and consumer control mechanisms for default advertising programs. FCC CPNI rules are not directly implicated in this program as currently described, though CPNI is used in the Tailored Offers and Ads program. 2) GOVERNANCE EXPOSURE: Medium. The combination of internally collected app usage data with purchased demographic data from third parties for interest modeling and partner ad delivery creates a data aggregation profile that is more extensive than first-party data alone. The use of MAIDs as a delivery mechanism creates a persistent cross-context identifier linkage. 3) JURISDICTION FLAGS: California's CCPA requires that consumers be given a clear mechanism to opt out of the sale or sharing of personal data for targeted advertising, which the Privacy Dashboard and 'Do Not Share or Sell' link address. Colorado and other states with opt-out requirements for targeted advertising should be assessed. The use of purchased demographic data may trigger data broker registration requirements in certain states. 4) CONTRACT AND VENDOR IMPLICATIONS: Agreements with advertising partners receiving audience segments and MAIDs should include data use restrictions and downstream sharing prohibitions. The scope of 'our advertising partners' is not enumerated, creating a vendor inventory gap for procurement review. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the Privacy Dashboard opt-out for Relevant Ads is technically effective and that MAID-based delivery ceases upon opt-out. The purchase of demographic data from third parties should be assessed for compliance with data broker source requirements under applicable state law. Documentation of the default enrollment basis and consumer disclosure mechanism should be maintained for regulatory inquiry readiness.
This provision establishes that targeted advertising using app usage data, mobile advertising IDs, and purchased demographic data operates by default, requiring consumers to actively opt out through the Privacy Dashboard rather than opt in to participate.
Under this clause, T-Mobile delivers interest-based advertising by default using app usage patterns, mobile advertising IDs, and purchased demographic data without requiring prior opt-in. The agreement permits advertising partners to receive audience data for ad delivery in this program.
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