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The Custom Experience program uses browsing and app usage data to personalize communications and product recommendations. Customers are enrolled by default and must actively opt out to be excluded from the program.
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 an opt-out default for a program that uses mobile device browsing and app usage data for behavioral profiling and targeted marketing, meaning customers are included unless they take affirmative action to opt out.
Under these terms, Verizon wireless customers are automatically enrolled in the Custom Experience program, which uses data about websites visited and apps used on their mobile devices for personalization and marketing. You can opt out by visiting the Verizon Your Privacy Choices page.
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"Our Custom Experience program uses information about sites you visit and apps you use on your mobile device to help us better personalize our communications with you, give you more relevant product and service recommendations, and develop plans, services, and offers that are more appealing to you. You are included in the program unless you opt out. We use only the first part of the web addresses (URLs) you visit (the part that includes the top level domain and subdomain of the URL); we do not use information past the first '/' or '?' in the URL.Excerpt from Verizon's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages the CPNI framework under the Communications Act, which governs the use of call and network usage data by telecommunications carriers. The FCC has addressed the use of broadband customer data for marketing purposes. California's CPRA imposes opt-in consent requirements for the use of sensitive personal information, which may include precise location data used by the program, creating tension with the policy's opt-out default in California. The FTC's commercial surveillance framework also applies. (2) GOVERNANCE EXPOSURE: Medium. The opt-out default for a program using behavioral browsing and app usage data is a standard practice in the telecommunications industry but creates compliance exposure in jurisdictions that require opt-in consent for behavioral profiling. The policy specifies a URL-truncation practice (top-level domain and subdomain only), which partially limits the granularity of browsing data used, but app usage data is collected without similar stated limitation. (3) JURISDICTION FLAGS: California residents may have CPRA arguments that certain data categories used in Custom Experience (precise location, if included) require opt-in consent rather than opt-out default. Colorado and Connecticut privacy laws impose opt-out rights for targeted advertising that this mechanism must satisfy. EU and UK residents are not addressed by this policy, but the provision would require opt-in consent under GDPR if applied to EEA users. (4) CONTRACT AND VENDOR IMPLICATIONS: The Custom Experience program data is used for Verizon's internal marketing and personalization and the policy states it does not disclose individually identifying information outside Verizon and its service providers for this program. No third-party data sale or sharing is disclosed for Custom Experience specifically, distinguishing it from the Custom Experience Plus and advertising programs. (5) COMPLIANCE CONSIDERATIONS: Legal teams should confirm that the opt-out mechanism satisfies state universal opt-out signal requirements, including whether the GPC signal honored by Verizon (as stated elsewhere in the policy) applies to Custom Experience enrollment. The distinction between Custom Experience (opt-out) and Custom Experience Plus (opt-in) should be reviewed to ensure the consent tier is appropriately calibrated to the sensitivity of data used in each program.
This provision establishes an opt-out default for a program that uses mobile device browsing and app usage data for behavioral profiling and targeted marketing, meaning customers are included unless they take affirmative action to opt out.
Under these terms, Verizon wireless customers are automatically enrolled in the Custom Experience program, which uses data about websites visited and apps used on their mobile devices for personalization and marketing. You can opt out by visiting the Verizon Your Privacy Choices page.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Verizon.