New Registration Requirement: September 17, 2024
Subject: IMPORTANT Privacy Policy Language Requirement for 10-DLC Registrations
When submitting 10-DLC Brand Registrations, it is important that the brand URL displays language in their privacy policy that does not claim to share end-user data with third parties for marketing purposes. This page is being heavily scrutinized by vetting partners. While it's permissible for a business to share end-user data essential for business operations, the fundamental practice of sharing data to sell consumer information (leads) to third parties is a prohibited campaign type and will be rejected.
Privacy Policies are reviewed during vetting to ensure consumer data isn't transferred among various organizations. To successfully address these requirements, we recommend adopting and including a process in the Privacy Policy that demonstrates senders will refrain from sharing information consumer data.
Example: "Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties."
A2P messaging on long-codes (TF and 10-DLCs) may not be used for the following purposes:
- Third-party or affiliate lead and/or commission generation (see details below)
- Advertisements for loans
- Credit repair offers
- Debt relief
- Debt consolidation
- Debt collection
- Work from home, secret shopper, MLM, or other similar advertising campaigns
What is third-party or affiliate lead generation?
This is when the party collecting opt-in is doing so for the purpose of collecting, aggregating, converting, or selling consumer information (leads) to third parties for a fee. Typically, a consumer is driven to a website using online advertising and asked to input their information in order to receive offers for general services like payday loans, insurance products, or educational opportunities. The lead generator then either resells that consumer’s information to one or more third parties or continues to send messages to the consumer with links to offers from multiple partners to try and convert a sale.
At best, these offers can give real value to consumers by connecting them with companies that can help fulfill a need. Oftentimes, however, lead generation companies have engaged in aggressive or potentially misleading marketing campaigns, causing consumers to complain and spam blocking to occur. And it is for this reason that third-party or affiliate lead generation is prohibited.