Current - Mobile Banking

"Device information: Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device's interaction with the Services. ... Biometric information. For the purpose of uniquely identifying an individual."

Current collects extensive device information including unique device identifiers and mobile network information, plus biometric data for identity purposes, which goes beyond what basic banking functionality requires.

"Geolocation Information: The location of your device, including your IP address, device language, and location of your network provider. This may include precise geolocation information. ... Precise geolocation data. Data derived from a device and that is used or intended to be used to locate you within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet."

Current collects precise geolocation data capable of pinpointing users within 1,850 feet, going beyond what's needed for basic banking services.

"We may share your information with the following categories of third parties: financial institutions, payment networks, payment card associations, credit bureaus, carrying brokers, and other entities; ... advertising partners who help us run our advertising campaigns, analyze our site, and track metrics on our behalf or in connection with the Services; companies affiliated with Current."

Current shares user data with a broad range of third parties including advertising partners, marketing partners, and receives data from data brokers and aggregators like Plaid, creating extensive data flows beyond what users might expect from a banking app.

"Identifiers such as a real name, postal address, unique personal identifiers (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers). ... 'Share' is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet."

Current collects multiple cross-tracking identifiers including cookies, pixel tags, mobile ad IDs, and probabilistic identifiers, and acknowledges sharing data for cross-site behavioral advertising targeting.

"Even after you close your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with certain criteria, such as applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable laws, regulations, legal processes, or governmental requests, to detect or prevent fraud, to collect fees owed, to resolve disputes."

Current retains user data indefinitely after account closure with no specific deletion timeline, using broad justifications like fraud prevention, fee collection, and dispute resolution.

"We may amend this Policy from time to time by posting a revised version and updating the Effective Date above. The revised version will be effective on the Effective Date listed. We will provide you with reasonable prior notice of material changes in how we use your information, which may include notification in our app or website, or by email. If you keep using the Services, you consent to any amendment of this Policy."

Current can change its privacy policy unilaterally, and continued use of the service is treated as consent to the new terms, giving users only the option to close their account if they disagree.

"Deletion. You have the right to request that we delete your personal information under certain circumstances, subject to a number of exceptions. ... If you send us a request to exercise your rights or the choices in this section, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases."

Current can charge fees for or decline deletion requests on broad grounds, and retains data after account closure indefinitely, making true data deletion difficult to achieve.