Under the CCPA’s broad definition of “sell,” which includes even the common flow of information in the digital analytics and advertising ecosystem, T‑Mobile does “sell” personal information. Like most companies that operate websites and apps, T‑Mobile uses online analytics to measure the ways users engage with our websites and apps. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics and facilitate online advertising, T‑Mobile uses third-parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our digital properties and on third-party digital properties. For example, T‑Mobile may request that a third-party facilitate the placement of T‑Mobile ads on a particular website after a consumer has previously visited T‑Mobile.com. The third-parties T‑Mobile uses for these purposes generally do this by placing a cookie on a user’s browser so it can identify that the same browser visited other websites. Similarly, where digital properties provide space for advertisements, these third-parties may use identifiers such as cookies for websites, or the device’s mobile Ad ID for apps, to facilitate real-time bidding by advertisers.
Under its personalized ad program, T‑Mobile uses and analyzes data from sources such as device and network diagnostic information (Android users only), apps on your device, and broadband information. This data helps T‑Mobile understand more about user interests (e.g., sports enthusiast, loves cooking, etc.). Using this information, T‑Mobile creates groups known as “audience segments,” which may be used by T‑Mobile or sold to third parties to make ads more relevant to you. When T‑Mobile sells audience segments, it does not sell information that directly identifies customers, like name, address, or email. Rather, audience segments are associated with mobile Ad IDs, which are long set of numbers and letters. For example, this might say something like "2drdn43np2cMapen084 is a sports enthusiast." Take a look at the Advertising and Analytics article and T‑Mobile’s Privacy Notice for details. T‑Mobile’s “Do Not Sell” choice applies to our personalized ad program.
Where T‑Mobile can reasonably ensure via contract that the third-parties described above can and will use a device identifier solely to provide the specific service T‑Mobile has requested, and will not use or share the data for other purposes, T‑Mobile will not deem that sharing a “sale” under the CCPA’s service provider exception.