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Upon opt-in, T-Mobile and its partners analyze app usage, purchase history, browsing activity, precise location, and CPNI to create audience segments and insights, which may be shared with third-party brands for targeted advertising and campaign measurement.
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 CPNI, which is subject to FCC regulatory protections under the Communications Act, is combined with precise location, browsing activity, and purchase data for advertising purposes upon opt-in, and that resulting audience segments and ad IDs may be shared with external brand partners.
Under this clause, opting into Tailored Offers and Ads authorizes T-Mobile and its partners to combine CPNI, precise location, browsing activity, and purchase information to create audience profiles that are then shared with third-party brands. Participation can be withdrawn at any time through T-Mobile's Privacy Dashboard.
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"If you opt in to Tailored Offers and Ads, we and our partners will analyze your data including app usage, purchase info, browsing activity, precise location, and CPNI for our Tailored Offers and Ads program. We or our partners will analyze this data to create groups, like 'frequent travelers,' and insights to optimize your or others' experiences. We may use or share these groups, ad IDs, and insights with other brands to provide more tailored offers and ads, enhanced experiences, and campaign measurement.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: The inclusion of CPNI in this advertising program engages FCC regulations under the Communications Act, which historically required opt-in consent for use of CPNI for marketing purposes beyond the customer's existing service. The CCPA engages regarding the use and sharing of precise location and browsing data for targeted advertising. State comprehensive privacy laws in California, Colorado, and Connecticut impose consent requirements for sensitive data processing including precise location. 2) GOVERNANCE EXPOSURE: High. Combining CPNI with precise location, browsing activity, and purchase data for third-party brand sharing in an advertising context is operationally significant. The FCC's treatment of CPNI in advertising contexts and any updated guidance from the FCC should be evaluated against the scope of this program. The sharing of audience segments and ad IDs with external brands extends data beyond T-Mobile's direct advertising relationships. 3) JURISDICTION FLAGS: California residents have heightened CCPA rights regarding the use of precise location as sensitive personal data, and the CPPA may scrutinize the sufficiency of opt-in consent for this combined data use. FCC jurisdiction applies across all US consumer accounts regarding CPNI handling. Illinois and other states with biometric or sensitive data statutes should be assessed for any overlap. 4) CONTRACT AND VENDOR IMPLICATIONS: Agreements with brand partners receiving audience segments and ad IDs should specify data use limitations, retention periods, and prohibitions on re-identification. The scope of 'other brands' as recipients is not enumerated in the notice, creating a due diligence gap for vendor inventory. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that opt-in consent mechanisms for Tailored Offers and Ads satisfy FCC CPNI consent standards and state law consent requirements for precise location. The notice should be assessed for adequacy of disclosure regarding which specific brand partners may receive shared segments. Audit of the Privacy Dashboard consent withdrawal mechanism should confirm that withdrawal effectively terminates all downstream partner data use.
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This provision establishes that CPNI, which is subject to FCC regulatory protections under the Communications Act, is combined with precise location, browsing activity, and purchase data for advertising purposes upon opt-in, and that resulting audience segments and ad IDs may be shared with external brand partners.
Under this clause, opting into Tailored Offers and Ads authorizes T-Mobile and its partners to combine CPNI, precise location, browsing activity, and purchase information to create audience profiles that are then shared with third-party brands. Participation can be withdrawn at any time through T-Mobile's Privacy Dashboard.
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