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Paul Zimmerman
pzimmerman@mrllp.com
(310) 564.2670

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The Ultimate Trade-Off Now Being Offered by Verizon

Verizon Wireless is offering a new reward program called Verizon Ups which allows customers to earn credits that can be redeemed for various offerings, including concert and movie tickets and smartphones. Of course, there’s a catch – being a Verizon customer isn't enough. Participants must also sign up for Verizon Selects, enabling the company to track customers and sell ads based on collected data.

By way of the Verizon Selects program, Verizon gathers and shares the following:

  1. Information about participants’ wireless devices and how they use them, including web addresses of sites visited and apps used, as well as device and advertising identifiers.
  2. Information about device location, including network data and location information transmitted by apps and sites.
  3. Participants’ postal and email addresses.
  4. Information about Verizon products and services and how participants use them (such as data and calling features, Fios service options, equipment and device types). Some of this information is CPNI (Customer Proprietary Network Information), which provides details about the quantity, type, destination, location, and amount of use of Verizon telecommunications and interconnected voice over internet protocol (VoIP) services and related billing information.
  5. Information from other companies or provided by participants (e.g., gender, age range, interests, shopping preferences, and ad responses).

The foregoing data is very valuable to Verizon, particularly as it works toward its goal of becoming an alternative to Google and Facebook for online advertisers. Verizon hopes this user information will make for an effective offering.

Some have scoffed at Verizon Selects, warning that the hidden cost of Verizon’s “free” reward program is customer data. That being said – and in a nod to transparency – Verizon is working to ensure that consumers fully understand how the program works; this in an effort to keep customers loyal, not to mention some legal requirements. Without proper disclosures, Verizon will run afoul of privacy laws together with its own privacy policies. Clearly then, to keep the FTC – and opportunistic plaintiffs – at bay, Verizon must pay heed to the necessity to provide consumers with clear disclosures.

This blog post is not offered as, and should not be relied on as, legal advice. You should consult an attorney for advice in specific situations.