Verizon uses network data and other information to generate aggregate reports on foot traffic patterns, demographic trends, and related business intelligence, which are then shared with or sold to third-party business and government customers. The policy states that the data used is aggregated and not individually identifiable.
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 data monetization mechanism through which Verizon derives and sells aggregate insights derived from customer network behavior. The deidentification and aggregation standards applied, and whether the resulting products could permit re-identification, are material compliance considerations for assessing whether this constitutes a sale of personal information under applicable state privacy law.
Interpretive note: Whether aggregated location and behavioral reports constitute a sale or sharing of personal information under CCPA/CPRA depends on the specific deidentification standards applied, which are not fully detailed in the policy text.
Current version emphasizes that data is aggregated, restricts recipients to 'business and government customers' (removing advertisers and industry analysts), and specifies use cases like foot traffic and demographic analysis instead of general marketing purposes; severity downgraded from high to medium.
View full change record →This provision authorizes Verizon to use network-derived data about customers to create and sell aggregate business intelligence reports, including location-based foot traffic and demographic analysis, to third-party business and government customers. Customers may opt out of this program through Verizon's privacy choices page.
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Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.
We may share your personal information with our merchant and business partners, marketing partners, and other third parties for purposes such as joint marketing, cross-marketing, and to provide you with offers and promotions that may be of interest to you.
We may disclose certain information, in connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
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"Verizon's Business and Marketing Insights program uses Verizon network and other information to create aggregate business and marketing reports and insights. We share these reports and insights with business and government customers who use them for planning and analytical purposes, such as understanding foot traffic patterns or demographic trends.— Excerpt from Verizon's Verizon Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages the FTC Act and CCPA/CPRA, particularly regarding whether aggregate location and behavioral insights derived from telecommunications network data constitute a sale or sharing of personal information. FCC CPNI regulations may also apply to the extent the underlying data includes network usage records. The California Privacy Protection Agency and FTC are relevant enforcement authorities. 2. GOVERNANCE EXPOSURE: Medium. The policy asserts that data is aggregated and not individually identifiable; however, the adequacy of deidentification standards for location and behavioral data is a recognized area of regulatory scrutiny. Whether this program constitutes a sale of personal information under CCPA definitions could affect opt-out obligation framing. 3. JURISDICTION FLAGS: California residents have the right to opt out of the sale of personal information under CCPA/CPRA. If aggregated location data derived from customer records is deemed personal information under California law, the opt-out mechanism for this program requires evaluation. Illinois and other states with location data protections may also create heightened exposure. 4. CONTRACT AND VENDOR IMPLICATIONS: Business and government customers purchasing these insights should assess whether the aggregated data they receive could, in combination with other data they hold, permit re-identification of individuals. Procurement teams should evaluate data use agreements governing the Business and Marketing Insights products. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should evaluate the technical deidentification standards applied to data used in this program and confirm whether those standards meet the definitions established under CCPA, CPRA, and applicable FCC guidance. Opt-out mechanisms should be audited for accessibility and efficacy.
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This provision establishes a data monetization mechanism through which Verizon derives and sells aggregate insights derived from customer network behavior. The deidentification and aggregation standards applied, and whether the resulting products could permit re-identification, are material compliance considerations for assessing whether this constitutes a sale of personal information under applicable state privacy law.
This provision authorizes Verizon to use network-derived data about customers to create and sell aggregate business intelligence reports, including location-based foot traffic and demographic analysis, to third-party business and government customers. Customers may opt out of this program through Verizon's privacy choices page.
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