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The Business and Marketing Insights program uses postpaid and small business customer data including web browsing, device location, app usage, demographic information, and third-party data to generate aggregate insights that are disclosed to third parties; the policy states the disclosed insights do not individually identify customers.
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 that Verizon uses individual-level behavioral and location data from postpaid and small business customers as inputs to create aggregate insights that are then commercially disclosed to third parties, with the policy asserting individual identifiability is removed at the output stage.
Interpretive note: Whether aggregated insights derived from individual-level location and behavioral data constitute a sale under CCPA depends on enforcement interpretation and the specific technical de-identification method used, which is not described 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 →The agreement establishes that Verizon uses postpaid and small business customer browsing, location, app usage, and demographic data to produce aggregate commercial insights sold to third parties. The policy states insights do not individually identify customers; customers can opt out through the Your Privacy Choices page.
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Verizon has changed this document before.
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"This Verizon Wireless program for postpaid and small business customers uses Verizon and third-party information to create aggregate business and marketing insights. The information we use and the insights we develop do not identify you individually and may be disclosed to third parties. Verizon and third-party information This includes information about how you use your mobile device (such as web browsing, device location, app/feature use, and IP address or similar information), certain information about your Verizon products and services (such as device type and amount of use), and demographic and interest information you provide or we obtain from other companies (such as gender, age range and interests). We may also use point of interest and location information we obtain from others as well as information provided by business and marketing clients who want insights related to their own businesses.Excerpt from Verizon's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages the FTC Act's commercial surveillance framework, California CPRA provisions on sale and sharing of personal information, and the CCPA's definition of sale (which may apply to commercial disclosure of insights derived from personal information even in aggregate form, depending on how California authorities interpret the transaction). The FTC has addressed de-identification standards in prior enforcement guidance, noting that claimed de-identification must be robust and not reasonably re-linkable to individuals. (2) GOVERNANCE EXPOSURE: Medium. The policy asserts that insights do not individually identify customers, but the underlying input data includes precise device location and web browsing at the individual level. Whether the de-identification or aggregation process used satisfies the FTC's de-identification standard or CCPA's de-identification definition is not determinable from the policy text alone. Third-party disclosure of insights derived from location data may also engage state location data privacy statutes. (3) JURISDICTION FLAGS: California CPRA's definition of sale may apply to commercial disclosure of aggregated insights depending on whether consideration is received and whether the data retains linkability to Verizon customers. Illinois and other states with sensitive location data protections may impose requirements on the use of precise location as an input to commercially disclosed products. Small business customers may have distinct legal postures from consumer customers under applicable state privacy laws. (4) CONTRACT AND VENDOR IMPLICATIONS: The program accepts data from business and marketing clients who want insights related to their own businesses, creating an inbound third-party data flow that should be assessed for CCPA-compliant data sharing agreements and purpose limitation. Outbound disclosure of insights to third parties should be governed by contracts that specify permitted uses and re-identification prohibitions. (5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the de-identification standard applied to Business and Marketing Insights outputs satisfies FTC guidance and CCPA's technical standards for de-identification, confirm that opt-out mechanisms for this program are operationally implemented and honored, and assess whether the commercial disclosure of location-derived insights triggers state location data privacy obligations in applicable jurisdictions.
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This provision establishes that Verizon uses individual-level behavioral and location data from postpaid and small business customers as inputs to create aggregate insights that are then commercially disclosed to third parties, with the policy asserting individual identifiability is removed at the output stage.
The agreement establishes that Verizon uses postpaid and small business customer browsing, location, app usage, and demographic data to produce aggregate commercial insights sold to third parties. The policy states insights do not individually identify customers; customers can opt out through the Your Privacy Choices page.
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Verizon.