# POL-111 — An incentivised opt-in needs a financial-incentive notice that agrees with the SMS clause

> 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.

- **Rule ID:** POL-111
- **Layer:** Policy pages (`POLICY_PAGE`)
- **Checks:** `privacy policy body + opt-in offer text`
- **Severity:** MEDIUM — Usually survives review, but lowers your trust score or invites manual review.
- **When it bites:** Gates approval — get this wrong and registration is refused
- **How it is detected:** AI judgement over the crawled website or policy page
- **Fix type:** Fix the privacy policy or SMS terms
- **Required by:** CCPA
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/policy-page/pol-111/

## Why this rule exists

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.

## How to fix it

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.

## Common mistakes

- 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.