Centre for Internet & Society

Financial apps may appear to be free but before you install them, read their privacy policies to know what you may be signing away.

The article by Shaikh Zoaib Saleem was published in Livemint on June 8, 2017. Pranesh Prakash was quoted.

With the increasing usage of smartphones and other smart devices, our use of and dependence on mobile applications also increases. These apps, while being installed on your device, ask for a lot of permissions. Most users do not take a detailed look at all the permissions being granted to any particular app’s publisher. Moreover, even fewer users look at the privacy policies and terms of use of apps, which detail how the publisher intends to utilize the data you share.

In most cases, the data collected is analysed and used for targeted marketing campaigns by the apps’ publishers, based on the users’ profiles and habits. Read more about it here: bit.ly/2q3ByA3. While this phenomena is spread across the board for all categories of apps, we take a look at the privacy policies and terms of use of the top 10 Android financial apps in India (top 10 as of June 1, according to App Annie, a mobile apps market research company based in California). The 10 apps are: PhonePe, BHIM, SBI Anywhere Personal, Kotak – 811 and Mobile Banking, JioMoney Wallet, Money View Money Manager, State Bank Buddy, Bank Balance Check, All Bank Balance Enquiry, iMobile by ICICI Bank.

Collecting information

The common theme across privacy policies of these apps is that the information is collected to enhance customer experience while using an app, respond to customer complaints and resolve disputes. Another theme is tracking consumer behaviour. For instance, PhonePe, in its privacy policy states, “We may automatically track certain information about you based upon your behaviour on our app. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users. This information is compiled and analysed on an aggregated basis.”

Similarly, the privacy policy of BHIM app says, “…once you give us your personal information, you are not anonymous to us. We may automatically track certain information about you based upon your behaviour on our app to the extent we deem fit.” It further adds that if you choose to transact on the app, then “we collect information about your transaction behaviour.” All the apps collect some or the other information like device IDs and location.

Sharing Information

The information gathered by the apps is not just used by these companies themselves, but also shared with third parties, subsidiaries, parent companies and agents of the companies. iMobile by ICICI Bank, for instance, in its privacy policy states that the bank will limit the collection and use of customer information only on a need-to-know basis to deliver better service to the customers. “ICICI Bank may use and share the information provided by the customers with its affiliates and third parties for providing services and any service-related activities such as collecting subscription fees for such services, and notifying or contacting the customers regarding any problem with, or the expiration of, such services. In this regard, it may be necessary to disclose the customer information to one or more agents and contractors of ICICI Bank and their sub-contractors, but such agents, contractors, and sub-contractors will be required to agree to use the information obtained from ICICI Bank only for these purposes,” the policy reads.

Similarly, PhonePe in its privacy policy has said that the company may share personal information with its other corporate entities and affiliates. “We and our affiliates will share/sell some or all of your personal information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this privacy policy with respect to your personal information,” it reads.

While installing, the Kotak app seeks your “irrevocable consent” to its privacy policy, which, among others things, states: “We may disclose the customer information to third parties for following, among other purposes, and will make reasonable efforts to bind them to obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and you hereby give your irrevocable consent for the same.”

JioMoney Wallet, while disclosing upfront that the publishing company and its affiliates do not sell or rent personal information to any third-party entities, also adds that the company “engages a number of vendors, consultants, contractors and takes support of our group companies or affiliates. We may provide our partners access to or share your personal information to enable them to provide the services subscribed by you.” Terms and conditions of the BHIM app state: “For the protection of both the parties, and as a tool to correct misunderstandings, the user understands, agrees and authorises NPCI, at its discretion, and without further prior notice to the user, to monitor and record any or all telephone conversations between the user(s) and NPCI only.”

It is imperative to note that most of these apps announce it upfront in their privacy policies that the policy could change anytime without prior information to the users. At the same time, it should be noted that sharing of some data is required for proper functioning of many apps. While most app publishers may not misuse the data being gathered, you should know exactly what data is being used.

Pranesh Prakash, policy director at the Centre for Internet and Society said that their research outputs show that laws to deal with misuse of personal data are very weak in India. “We need a strong privacy law to address these issues, of which we have proposed a citizens’ draft. Clearly, the prevailing situation shows that the industry is not taking enough initiative on self-regulation. At the same time, even the government isn’t taking much interest in consumer protection.”