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T-Mobile compiles fraud indicators from account status, SIM change history, call and text history, URL interaction data, and risk scores, and shares these indicators with third-party companies where a consumer holds accounts, 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 SIM change history, call and text history, and risk scores derived from network behavior may be shared with external companies outside T-Mobile for fraud prevention purposes, creating a third-party data sharing relationship that consumers can opt out of through the Privacy Dashboard.
Under this clause, account status, SIM change history, certain call and text history, and risk scores may be shared with third-party companies where a consumer holds accounts as part of T-Mobile's fraud prevention program. Consumers can opt out of this sharing through the 'Sharing for Fraud and Identity Theft Protection' controls in the Privacy Dashboard.
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"We may collect personal data like your name, address, phone number, account status, SIM change history, certain call and text history, interactions with potentially malicious URLs, account data, network data, and risk scores based on that information. To help spot and protect against potential fraud or identity theft, we use personal data to create indicators of potential fraud. We or our partners share these indicators with other companies, like companies you've created an account with, to help them spot and protect you from things like fraudulent transactions and others' attempts to access your accounts. You can opt out of this fraud prevention data sharing by using the 'Sharing for Fraud and Identity Theft Protection' controls described in the Your choices section of this notice.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: Sharing of call and text history and SIM change data with third-party companies engages FCC CPNI regulations under the Communications Act, which restrict the use and disclosure of CPNI. The CCPA's sale and sharing definitions may apply to fraud indicator sharing depending on whether consideration or benefit is exchanged. The FTC Act applies as a general framework for data sharing practices. State privacy laws governing data broker activities may apply to third-party recipients of shared fraud indicators. 2) GOVERNANCE EXPOSURE: Medium. The provision creates an outbound data sharing relationship with an open category of third-party companies defined only as companies where the consumer holds accounts. The specific companies receiving fraud indicators are not enumerated, and the data categories shared include call and text history and risk scores derived from network behavior, which carry sensitivity beyond basic account identifiers. 3) JURISDICTION FLAGS: FCC jurisdiction applies across all US consumer accounts regarding CPNI disclosure to third parties. California's CCPA may classify fraud indicator sharing as a sale or share if the recipient companies derive commercial benefit. States with comprehensive privacy laws requiring data sharing disclosures may require more specific enumeration of recipient categories. 4) CONTRACT AND VENDOR IMPLICATIONS: Agreements with third-party companies receiving fraud indicators should specify the permissible uses of shared data, prohibit secondary disclosure, and define retention limits. The basis on which T-Mobile determines which companies qualify as recipients should be documented for regulatory inquiry readiness. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the opt-out mechanism for fraud prevention data sharing satisfies applicable state law requirements and whether the CPNI regulatory framework permits disclosure of call and text history to non-affiliated third parties under this program's structure. The specific categories of call and text history shared should be mapped against CPNI regulatory definitions to confirm compliance.
This provision establishes that SIM change history, call and text history, and risk scores derived from network behavior may be shared with external companies outside T-Mobile for fraud prevention purposes, creating a third-party data sharing relationship that consumers can opt out of through the Privacy Dashboard.
Under this clause, account status, SIM change history, certain call and text history, and risk scores may be shared with third-party companies where a consumer holds accounts as part of T-Mobile's fraud prevention program. Consumers can opt out of this sharing through the 'Sharing for Fraud and Identity Theft Protection' controls in the Privacy Dashboard.
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