Hello!

As 2020 comes to a close we wanted to let you know what we’re working for early in 2021 so you can plan accordingly!

A key theme we are addressing right now is adherence to new requirements being put on app developers by both Google and Apple that relate to end-user privacy. Both companies have added policies around disclosure of privacy-impacting functionality within apps. Both companies have also been implementing functionality within their respective operating systems to give users more explicit control over granting access to their personal data, including location.

Larky is a big believer in privacy and data protection and applauds the iOS and Android evolution on this. Just as much as our clients and their account holders count on their mobile and digital banking platforms to protect the privacy of their most trusted financial data, we also want to extend those same protections to their location data.

Since location awareness is a key element of the Larky nudge^® platform we are enhancing our code library to comply with these new requirements, while at the same time helping our clients’ end-users recognize the value they receive by sharing their location data with their financial institution’s mobile banking app.

Check out the details below, and please feel free to reach out to me personally, if you have any questions, or would like to discuss this further in person.

Sincerely,
Kurt Schaldenbrand

New Google Play submission requirement

Google has implemented a new requirement when submitting apps to the Google Play store that request location in the background. This would include any app that includes the Larky nudge® code library and may also be required for ATM or branch location functionality in your mobile banking app/. You can read the full details here but in general there is a new Location permissions declaration form that must be completed as part of the process. Beginning March 29, 2021, any apps originally published to Google Play on or before April 16, 2020 will need to be approved through this new policy.

As your partner we are committed to helping you with this process. We are in the final stages of completing a guide that will walk you through the process and provide you with the details you will need when submitting the form.

One of the requirements is to display a prominent in-app disclosure “of your data access, collection, use, and sharing,“ to the user, prior to requesting access to location information. While you could accomplish this now with coding around your call to initialize the nudge® code library, we will be updating the library itself to display the required prompt, with configurable language and branding options. See below for more information.

Apple App Privacy details

Not to be outdone by Google, Apple has its own new policy regarding submitting apps to their App Store. This is a simpler process, however, and merely requires you to enter responses on a form in App Store Connect. You are required to identify all data your app collects directly, as well as from third-party partners, like Larky. For more information, see this article from Apple.

Similar to the guide we are finalizing for the Google Play process described above, we will also release a guide for this process shortly. Watch for more information from us on this soon.

nudge® code library update

As mentioned in the previous section, we are updating the nudge® code library to display a prominent in-app disclosure regarding privacy details and benefits to the user before prompting them to grant access to location information. While this is required now on Android for inclusion in the Google Play store, it is also simply best-practice on either OS platform. It also increases the likelihood of having the user grant access to location information, delivering better adoption and engagement for our financial institution clients as a result. Finally, this capability helps mitigate changes to how background location access can be granted in Android 11 (API level 30). This is now a more involved process for the end-user, and providing some guidance on the prominent disclosure dialog can help.

Given all of these contributing factors, we strongly encourage you to plan on implementing this nudge® library update on both the Android and iPhone versions of your mobile banking applications when it becomes available early next year.

We will provide generic text for both the prominent disclosure dialog as well as any OS-based dialogs that are part of the overall process. While the provided language should cover most use-cases, it will be configurable such that you could customize it uniquely for each institution.

Should you choose to implement your own in-app disclosure dialog, you will be able to disable the one provided within the nudge® code library.

Coming later in 2021

Driven by client demand, we are continuing to build out capabilities within the nudge® portal around segmentation and increased campaign management functionality. The foundations for this are intrinsically tied with the platforms delivered by our mobile and digital banking application partners. We’re excited to continue working with you to deliver this important functionality to our clients, and create greater product value for all of us. 

We are already in process with several partners to build this integration, and look forward to beginning discussions with other partners very soon. Feel free to contact us if you have a client who requires this capability right away.

We are also exploring several fraud management and prevention opportunities tied to the core nudge® geolocation functionality. Look for more details on this as we move forward into 2021, or reach out today to schedule a discussion if you already have an immediate use-case in mind!