{
  "id": "POL-111",
  "slug": "pol-111",
  "title": "An incentivised opt-in needs a financial-incentive notice that agrees with the SMS clause",
  "statement": "Where joining the programme earns a discount or other reward, the policy must carry a CCPA Notice of Financial Incentive that does not contradict the messaging clause.",
  "rationale": "Offering ten per cent off for a phone number is a financial incentive under California law and needs its own notice, and the notice has to explain the value of the data — which is exactly the sentence that can undo a non-sharing promise if it is drafted carelessly. The offer is usually designed by marketing and the policy by someone else, so the two are rarely read together.",
  "layer": "POLICY_PAGE",
  "layerSlug": "policy-page",
  "object": "privacy policy body + opt-in offer text",
  "severity": "MEDIUM",
  "detectability": [
    "CRAWL"
  ],
  "failureClass": "TERMINAL_POLICY",
  "artifact": "privacy_policy",
  "authorities": [
    "CCPA"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Add the notice — what the incentive is, what data it relates to, how to withdraw, and a good-faith estimate of value — and state that messaging opt-in data is still never shared. Done when the two sections agree.",
  "pitfalls": [
    "The value estimate is the sentence that can contradict the non-sharing clause. Base it on the value of the customer relationship rather than on what the data would fetch if sold."
  ],
  "notes": "Conditional on the opt-in offering an incentive, which no applicability dimension expresses; the criteria pass immediately where none is offered. The terms-side twin is POL-234.",
  "phase": "approval",
  "automated": true,
  "url": "https://ekas.io/rules/10dlc/policy-page/pol-111/",
  "markdown": "https://ekas.io/rules/10dlc/policy-page/pol-111.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}