Verizon uses your app usage and web browsing history on its network to personalize your experience and serve you targeted ads, and you are enrolled in this program by default.
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 program uses sensitive browsing and app activity data for advertising without requiring you to affirmatively opt in, meaning your data is being used for ad personalization unless you take action to stop it.
Interpretive note: The precise scope of CPNI applicability to app and browsing data used for advertising, and whether opt-out satisfies CPRA requirements for this data category, depends on regulatory interpretation and enforcement context.
Your app usage and browsing data on the Verizon network are used to target you with personalized advertising by default; you must actively opt out to prevent this use of your behavioral data.
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"We use information about your use of Verizon apps and browsing on our network to customize your experience with us. This includes the websites you visit and the apps you use on your mobile device. We use this information to make recommendations and provide personalized content and ads on our apps and websites, in the My Verizon app, and on your device.— Excerpt from Verizon's Verizon Privacy Policy
(1) REGULATORY LANDSCAPE: This provision implicates the FCC's CPNI rules under Section 222 of the Communications Act, which restrict use of network-derived customer data for marketing purposes without consent. The CPRA classifies behavioral advertising data as personal information that California residents have the right to opt out of sharing. The FTC Act's unfair or deceptive practices authority applies to default enrollment in data-use programs that are not clearly disclosed at point of sale. (2) GOVERNANCE EXPOSURE: High. Default enrollment in a program using network-derived browsing and app usage data for advertising sits at the intersection of FCC CPNI obligations and state privacy law opt-out requirements. The gap between what a reasonable consumer expects from a wireless carrier and what this program permits is material. (3) JURISDICTION FLAGS: California residents have CPRA opt-out rights for sharing personal information for cross-context behavioral advertising. Colorado, Connecticut, Virginia, and Texas privacy laws also provide opt-out rights for targeted advertising. FCC CPNI rules apply nationwide to telecommunications carriers. (4) CONTRACT AND VENDOR IMPLICATIONS: If Verizon shares Custom Experience-derived insights with third-party advertising partners, those sharing relationships should be documented in data processing agreements that satisfy CPRA contractor or service provider definitions, or disclosed as third-party sharing subject to opt-out. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should audit whether the opt-out mechanism for Custom Experience is prominently disclosed at the point of service enrollment, technically functional, and persistent across account changes. The program's use of network-derived browsing data should be evaluated against FCC CPNI guidance on permissible uses without customer consent.
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This program uses sensitive browsing and app activity data for advertising without requiring you to affirmatively opt in, meaning your data is being used for ad personalization unless you take action to stop it.
Your app usage and browsing data on the Verizon network are used to target you with personalized advertising by default; you must actively opt out to prevent this use of your behavioral data.
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