T-Mobile collects your precise physical location using both GPS signals from your device and data from its own network towers, and may share that location with certain third parties.
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
Precise location data is among the most sensitive personal information a carrier can collect, revealing where you live, work, worship, receive medical care, and travel. Prior FCC enforcement actions against major carriers, including T-Mobile, involved unauthorized sale of this exact data type to third-party aggregators.
Interpretive note: The boundary between permissible CPNI-covered location use and uses requiring separate consumer consent under FCC rules is a live regulatory question; the policy language does not fully resolve when consent is required versus when a statutory permission applies.
Your real-time and historical location data may be collected through both your device's GPS and T-Mobile's network infrastructure, and the policy permits sharing it with third parties under defined conditions; consumers who rely on T-Mobile services have limited ability to prevent network-based location collection entirely while using the network.
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Geolocation Information
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
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"We collect precise location information. This includes GPS location when you use location-based services or features, and network-based location information that we derive from your use of our network. We may share location information with third parties such as roadside assistance providers, emergency services, and others as permitted by law or with your consent.— Excerpt from T-Mobile's T-Mobile Privacy Policy
REGULATORY LANDSCAPE: Precise geolocation data collected by carriers engages the Communications Act's CPNI provisions, enforced by the FCC, which restrict carriers' use and disclosure of location information derived from network operations. The California Privacy Rights Act classifies precise geolocation as a sensitive category requiring opt-in consent for collection in certain contexts, enforced by the California Privacy Protection Agency. The FTC Act's Section 5 is also relevant given T-Mobile's prior consent decree history regarding location data. Where the policy asserts sharing permissions, CPNI rules may impose stricter constraints than the policy language suggests. GOVERNANCE EXPOSURE: High. The collection and sharing of network-derived location data has been the subject of direct FCC enforcement against all major US carriers. The provision's reference to sharing with third parties 'as permitted by law or with your consent' creates ambiguity about when consent is required versus when the carrier may rely on a statutory permission, which is a live regulatory question under current FCC rules. JURISDICTION FLAGS: California residents have heightened rights regarding sensitive geolocation data under the CPRA. Illinois residents may have additional protections under the Biometric Information Privacy Act if location tracking intersects with biometric identifiers. Federal CPNI rules apply nationally but enforcement intensity varies. EU and UK users are not within scope of this policy. CONTRACT AND VENDOR IMPLICATIONS: Any enterprise or B2B agreement that involves employee device management on T-Mobile's network should assess whether location data flows to T-Mobile constitute employer monitoring obligations under applicable state electronic surveillance laws. Vendor agreements with T-Mobile for IoT or fleet tracking services should specifically address location data handling and retention obligations. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the list of third parties with whom location data is shared and verify that data processor agreements contain appropriate safeguards. Consent mechanism reviews should confirm that network-based location sharing disclosures satisfy FCC requirements and that CPRA opt-in mechanisms for sensitive geolocation are implemented where required. Any data mapping exercise should distinguish between GPS-derived and network-derived location data, as these may carry different legal treatment.
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Precise location data is among the most sensitive personal information a carrier can collect, revealing where you live, work, worship, receive medical care, and travel. Prior FCC enforcement actions against major carriers, including T-Mobile, involved unauthorized sale of this exact data type to third-party aggregators.
Your real-time and historical location data may be collected through both your device's GPS and T-Mobile's network infrastructure, and the policy permits sharing it with third parties under defined conditions; consumers who rely on T-Mobile services have limited ability to prevent network-based location collection entirely while using the network.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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