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Can I use third-party email marketing tools that collect personal information in Arizona? What are the requirements?
Using Third-Party Email Marketing Tools in Arizona
If you are using third-party email marketing tools that collect personal information in Arizona, you may be subject to certain requirements.
Customer Proprietary Network Information (CPNI)
Under Arizona law, there are specific requirements for obtaining customer approval to use, disclose, or permit access to CPNI [R14-2-2103][3.5]. CPNI includes information such as call detail records, service usage, and billing information.
If you are collecting personal information through email marketing tools, it is recommended that you review the requirements for obtaining customer approval to use, disclose, or permit access to CPNI in Arizona.
Opt-In Notice
If you are collecting personal information through email marketing tools, you may also need to provide an opt-in notice to customers [R14-2-2105][3.1]. The opt-in notice must include specific information, such as a description of CPNI and the customer’s right to limit the use, disclosure, and access to their information.
Customer Information Security Program
Additionally, if you are collecting personal information through email marketing tools, you must implement a comprehensive written customer information security program that includes administrative, technical, and physical safeguards for the protection of customer information [R20-6-2102][5.1].
Conclusion
In summary, if you are using third-party email marketing tools that collect personal information in Arizona, you may be subject to requirements related to CPNI, opt-in notices, and customer information security programs. It is recommended that you review the relevant Arizona laws and regulations and consult with a legal professional if you have any questions or concerns.
References:
- Obtaining Customer Approval to Use, Disclose, or Permit Access to CPNI to Affiliates, Joint Venture Partners and Independent Contractors Providing Communications-Related Services [R14-2-2103][3.5]
- Information Requirements for Customer CPNI Opt-In Notice [R14-2-2105][3.1]
- Customer Information Security Program [R20-6-2102][5.1]
Source(s):
- [3.1] Information Requirements for Customer CPNI Opt-In Notice
- [5.1] Customer Information Security Program
- [3.5] Obtaining Customer Approval to Use, Disclose, or Permit Access to CPNI to Affiliates, Joint Venture Partners and Independent Contractors Providing Communications- Related Services
Jurisdiction
Arizona