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#2300640 - 08/19/24 11:55 AM REG P Question
Lizz Offline
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Joined: Aug 2013
Posts: 149
Dunkirk NY
We are looking into changing our current mobile banking platform to a mobile app which is supported by Apple/ Google. Would we have to make changes updating our current Privacy Policy? Looking for guidance on this one.

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General Discussion
#2300642 - 08/19/24 12:48 PM Re: REG P Question Lizz
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 84,416
Galveston, TX
What privacy disclosure is this going to impact? Would this not just be a service provider?
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#2300674 - 08/19/24 06:59 PM Re: REG P Question Lizz
InFairness, CRCM Offline
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 958
USA
It might have privacy impacts if the new app vendor collects additional data that the bank doesn't currently collect, and the customer or bank cannot control the collection through a contract or opting out. Think, for example, about location services.
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Opinions are strictly my own, and have nothing to do with my employer.

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