• Precise Location
• Developer’s Advertising or Marketing
• App Functionality
• Data is not linked to the user’s identity
• Larky does not use precise location data for tracking purposes 

Comments: for Developer’s Advertising or Marketing this really refers to the option for an FI (as the defacto Developer) to use location to trigger offers to their members.

• User ID
• Developer’s Advertising or Marketing
• Analytics
• App Functionality
• Data is not linked to the user’s identity
• Larky does not use user ID data for tracking purposes 

• Device ID
• Developer’s Advertising or Marketing
• Analytics
• App Functionality
• Data is not linked to the user’s identity
• Larky does not use device ID data for tracking purposes 

Both User ID and Device ID refer to internal Id fields used within the nudge® platform's back-end, neither of which can be tied back to an actual FI account holder's personal identity, or even referenced at all through the nudge® portal. In terms of utilizing either of these Ids for Developer's Advertising or Marketing, this is a very conservative interpretation of the declaration; an FI could request a custom report showing analytics for messages on a per-User or Device Id basis, but those still wouldn't tie back to an actual account holder's actual identity.

• Product Interaction
• Analytics
• Data is not linked to the user’s identity
• Larky does not use product interaction data for tracking purposes 

• Other Usage Data
• Analytics
• Data is not linked to the user’s identity
• Larky does not use other usage data for tracking purposes 

• Crash Data
• Analytics
• Data is not linked to the user’s identity
• Larky does not use crash data for tracking purposes