{
  "id": "POL-109",
  "slug": "pol-109",
  "title": "A cart-reminder programme must say how abandonment is detected",
  "statement": "Where the programme sends shopping-cart reminders, the policy must state explicitly how cart abandonment is detected.",
  "rationale": "T-Mobile asks for this in almost these words, because a cart reminder is triggered by watching what someone did rather than by anything they asked for — so the policy has to say that cookies, a plugin or an account session are doing the watching. A retailer who switched an abandoned-cart flow on inside a platform has usually never seen the mechanism, let alone described it.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy body",
  "severity": "BLOCKING",
  "detectability": [
    "CRAWL"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "T-Mobile",
    "CTIA",
    "TCR"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Add a sentence naming the mechanism — website cookies, a store plugin, a logged-in session — and what triggers the message. Done when the policy explains how the business knows a cart was left.",
  "example": "If you add items to your basket on acmecoffee.com and leave without checking out, a cookie on your browser lets us link that basket to your number so we can text you a reminder.",
  "pitfalls": [
    "The T&C has to reflect the cart programme as well (POL-110), and the opt-in disclosure has to name it (WEB-068). Fixing only the policy leaves two of the three."
  ],
  "notes": "Conditional on cart-reminder traffic, which no applicability dimension expresses — there is no cart-reminder attribute. The criteria pass immediately when nothing indicates the programme sends them. Severity divergence: T-Mobile and TCR grade it BLOCKING, CTIA SCMH Sev-2 MEDIUM. Strictest kept.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-109/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-109.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}