Custom Experience Network Usage Advertising Program

What it is

The Custom Experience program collects data on websites visited and apps used on Verizon's mobile network, and the Custom Experience Plus program additionally incorporates location data, to personalize services and deliver targeted advertising to customers. Customers are enrolled by default and may opt out through account settings.

Why it matters (compliance & governance perspective)

This provision authorizes Verizon to use network-level behavioral data, including browsing and app usage activity, as a telecommunications carrier to deliver targeted advertising. As a common carrier, Verizon's use of CPNI-adjacent network data for advertising purposes engages FCC regulatory authority in addition to general consumer privacy frameworks.

Change history

Consumer impact (what this means for users)

Under this provision, Verizon collects information about websites visited and apps used on the Verizon mobile network and uses that data, along with location information under Custom Experience Plus, to deliver personalized advertising. Customers can opt out of both programs through My Verizon account settings.

What you can do

Institutional analysis (Compliance & governance intelligence)

1. REGULATORY LANDSCAPE: This provision implicates the FCC's Customer Proprietary Network Information regulations, which restrict how telecommunications carriers may use network-derived data. The FTC Act's unfair and deceptive practices authority and the CCPA/CPRA also apply to the extent this data use constitutes sale or sharing of personal information. The FCC and state attorneys general are the primary enforcement authorities. 2. GOVERNANCE EXPOSURE: High. The use of app usage, browsing activity, and location data by a telecommunications carrier for advertising purposes is the provision with the highest regulatory exposure in this document. The intersection of CPNI rules with advertising data use has been a subject of FCC regulatory attention, and the adequacy of opt-out rather than opt-in consent for this data use may require evaluation under applicable telecommunications law. 3. JURISDICTION FLAGS: California residents have CPRA-based rights to opt out of the sharing of personal information for cross-context behavioral advertising, which this program may implicate. Customers in states with active telecommunications privacy statutes may have additional protections. The FCC's jurisdiction applies nationally. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations purchasing Verizon business services should assess whether employee device data transmitted over Verizon's network could be collected under this program and whether that collection is consistent with their own privacy obligations to employees or customers. Vendor assessments should confirm the scope of data flowing to third-party advertising partners under this program. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm whether the opt-out mechanisms for Custom Experience and Custom Experience Plus satisfy the consent standards required under FCC CPNI rules and CPRA for sharing of personal information. Data mapping should document which data categories are collected under this program and which third parties receive advertising-related data as a result.

Applicable agencies

Applicable regulations

Provision details

Other risks in this policy

• Business and Marketing Insights Program medium
• CPNI Use and Opt-Out high
• Third-Party Data Collection and Sharing for Advertising medium
• California Consumer Rights Under CCPA/CPRA medium
• Children and Minors Data Restrictions medium
• Location Data Collection and Use high