Verizon enrolls customers by default in the Custom Experience and Custom Experience Plus programs, which use network-level browsing history and app usage data to build advertising profiles used for targeted marketing across Verizon business lines. Customers must actively opt out to exit these programs.
This analysis describes what Verizon'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 a default opt-in enrollment for a program that uses network-level data, including URLs visited and app usage, for advertising profiling. Under FCC CPNI rules, telecommunications carriers have historically been subject to restrictions on using certain network usage data for marketing without affirmative customer consent, and this default enrollment structure may require evaluation against those requirements.
Interpretive note: The relationship between this default enrollment structure and FCC CPNI consent requirements is not resolved in the document, and regulatory treatment may depend on FCC enforcement posture and how 'network usage data' is classified under CPNI rules.
The new version explicitly states automatic enrollment with opt-out requirement, whereas the previous version did not clearly disclose the default enrollment status.
View full change record →Under this clause, customers' network browsing and app data are used to build advertising profiles unless the customer actively opts out of the Custom Experience Plus program through account settings or by contacting Verizon. The provision identifies the data involved as wireless network browsing activity and app usage information.
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to object to profiling activities based on our own legitimate interests
"Custom Experience uses your wireless network browsing and app data to give you a personalized experience with us. Custom Experience Plus uses your wireless network browsing and app data to provide you personalized experiences across our business lines and improves marketing so you see ads from us that are more relevant to you. You are automatically enrolled in these programs unless you opt out.Excerpt from Verizon's Privacy Policy (Summary)
1) REGULATORY LANDSCAPE: This provision directly implicates FCC Customer Proprietary Network Information rules, which restrict how telecommunications carriers may use call detail records and network usage data for marketing purposes.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
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This provision establishes a default opt-in enrollment for a program that uses network-level data, including URLs visited and app usage, for advertising profiling. Under FCC CPNI rules, telecommunications carriers have historically been subject to restrictions on using certain network usage data for marketing without affirmative customer consent, and this default enrollment structure may require evaluation against those requirements.
Under this clause, customers' network browsing and app data are used to build advertising profiles unless the customer actively opts out of the Custom Experience Plus program through account settings or by contacting Verizon. The provision identifies the data involved as wireless network browsing activity and app usage information.
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