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The agreement provides a data sale and sharing opt-out mechanism through the Privacy Dashboard and a site-level link, recognizes the Global Privacy Control signal as a valid opt-out, and states that separate consent withdrawal through the Privacy Dashboard may be required for consumers enrolled in specific advertising programs.
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 T-Mobile engages in the sale and sharing of personal data for targeted advertising as defined under applicable state privacy law, that opt-out is available but requires multiple steps for consumers enrolled in program-specific advertising, and that GPC signal recognition satisfies California's CCPA opt-out signal requirement.
Under this clause, personal data is sold or shared for targeted advertising unless a consumer opts out through the Privacy Dashboard or the 'Do Not Share or Sell My Personal Information' link. Consumers previously enrolled in Personalized Ads and Offers or Tailored Offers and Ads must also separately withdraw program-specific consent to fully exit those advertising uses.
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"You may opt out of having your data sold or shared by us, which includes having it used for targeted advertising or for third parties to use for direct marketing or similar uses, by going to our Privacy Dashboard or using the 'Do Not Share or Sell My Personal Information' link on our websites or apps. If you've opted in to our Personalized Ads and Offers or Tailored Offers and Ads programs, you may also need to withdraw your consent via the Privacy Dashboard to be removed from those programs. We recognize the Global Privacy Control (GPC) signal broadcast from certain web browsers as an opt-out request, but we don't recognize the 'do not track' signal because there isn't a universal standard for how to apply it.Excerpt from T-Mobile's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly engages CCPA opt-out requirements for the sale and sharing of personal data for targeted advertising, including the California Attorney General and CPPA enforcement authority. The recognition of GPC as a valid opt-out signal is required under California law and assessed in other states with comprehensive privacy statutes. The FTC Act applies to the adequacy and effectiveness of opt-out mechanisms. 2) GOVERNANCE EXPOSURE: Medium. The two-step opt-out requirement for consumers enrolled in specific advertising programs creates a compliance complexity: a general Do Not Sell or Share opt-out may not be sufficient to exit program-specific consent-based sharing, requiring consumers to separately withdraw consent through the Privacy Dashboard. This structure should be assessed against state law requirements for unified opt-out mechanisms. 3) JURISDICTION FLAGS: California creates primary exposure given CCPA sale and share opt-out requirements and GPC signal recognition mandates. Colorado, Connecticut, and other states with GPC recognition requirements should be assessed. The non-recognition of the 'do not track' signal is consistent with current practice given the absence of a universal standard but should be monitored as standards evolve. 4) CONTRACT AND VENDOR IMPLICATIONS: Advertising network and social network partners receiving data for targeted advertising must be notified of opt-out signals in a timely manner consistent with applicable state law requirements. Contracts should specify the mechanism and timeline for transmitting opt-out signals to downstream partners. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that the GPC signal opt-out is technically implemented and propagated to all downstream advertising partners. The two-step opt-out structure for program-specific advertising should be assessed against CPPA guidance on the adequacy of layered opt-out mechanisms. Documentation of opt-out signal transmission timelines and partner acknowledgment should be maintained for regulatory inquiry readiness.
This provision establishes that T-Mobile engages in the sale and sharing of personal data for targeted advertising as defined under applicable state privacy law, that opt-out is available but requires multiple steps for consumers enrolled in program-specific advertising, and that GPC signal recognition satisfies California's CCPA opt-out signal requirement.
Under this clause, personal data is sold or shared for targeted advertising unless a consumer opts out through the Privacy Dashboard or the 'Do Not Share or Sell My Personal Information' link. Consumers previously enrolled in Personalized Ads and Offers or Tailored Offers and Ads must also separately withdraw program-specific consent to fully exit those advertising uses.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by T-Mobile.