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Verizon states that it uses CPNI, which includes call records, location, and technical network usage information, to provide telecommunications services and to inform customers about other Verizon service offerings. Federal law governs CPNI use, and Verizon discloses this framework as part of its privacy policy.
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 identifies the federal CPNI regulatory framework applicable to Verizon as a telecommunications carrier and establishes the stated basis for using network data in service delivery and marketing contexts. The intersection of CPNI obligations with the Custom Experience advertising programs described elsewhere in the policy is a material compliance consideration.
Current version removes explicit mention of marketing as a use case, adds emphasis on federal law governance, and reframes CPNI use as providing information about services rather than marketing additional services.
View full change record →This provision discloses that federal CPNI regulations apply to certain network-derived data Verizon holds, including call records, location, and technical usage information, and that Verizon uses this data both for service delivery and to offer customers information about other Verizon services. Customers have the right to restrict use of CPNI for marketing purposes.
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"Federal law governs how we use certain information that we obtain in providing our telecommunications services. This information, referred to as Customer Proprietary Network Information or CPNI, includes information related to the quantity, technical configuration, type, destination, location, and amount of use of telecommunications services. We use this information to provide you with telecommunications services and to provide you with information about other services we offer.Excerpt from Verizon's Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly engages the FCC's CPNI regulations under the Communications Act, which impose specific use restrictions and consent requirements on telecommunications carriers. The FCC is the primary enforcement authority. State telecommunications regulators may also have authority in certain jurisdictions. 2. GOVERNANCE EXPOSURE: High. CPNI is a federally protected data category with specific consent and use restrictions that go beyond general consumer privacy law. Any use of CPNI for advertising or marketing purposes beyond the core telecommunications service requires evaluation for compliance with FCC rules. 3. JURISDICTION FLAGS: CPNI obligations apply nationally as a matter of federal telecommunications law. State-level telecommunications privacy statutes in California and other states may impose additional restrictions on network-derived data use. 4. CONTRACT AND VENDOR IMPLICATIONS: Business customers purchasing Verizon telecommunications services should assess whether CPNI protections apply to their account data and whether any data sharing arrangements they have with Verizon adequately address CPNI obligations. Vendor contracts involving Verizon network data should reference CPNI compliance requirements. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should map which data categories in Verizon's possession qualify as CPNI and confirm that the opt-out mechanisms and consent frameworks applied to those categories meet FCC standards. The policy should be evaluated to confirm that CPNI is not being used in advertising programs in a manner inconsistent with FCC guidance.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision identifies the federal CPNI regulatory framework applicable to Verizon as a telecommunications carrier and establishes the stated basis for using network data in service delivery and marketing contexts. The intersection of CPNI obligations with the Custom Experience advertising programs described elsewhere in the policy is a material compliance consideration.
This provision discloses that federal CPNI regulations apply to certain network-derived data Verizon holds, including call records, location, and technical usage information, and that Verizon uses this data both for service delivery and to offer customers information about other Verizon services. Customers have the right to restrict use of CPNI for marketing purposes.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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