Chase may collect your real-time GPS or device location with your permission and use it to offer location-based services or targeted offers.
This analysis describes what Chase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Real-time location data is among the most sensitive categories of personal information, and its collection for marketing offers goes beyond what is strictly necessary to deliver core banking services.
This provision permits Chase to collect your real-time geographic location from your mobile device and use it to deliver targeted offers, meaning your physical movements may inform the marketing content you receive from Chase.
How other platforms handle this
We collect information about your location, such as data from your device's GPS or IP address, when you use our products.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If we collect health information from these integrations (such as heart rate), we will not sell or use it for advertising or other similar purposes; we do not disclose it to third parties without your prior consent; and we will only use it for the specific purposes described in this Policy.
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"With your permission, we may collect your real-time location information from your mobile device. We may use this information to provide you with location-based services and offers.— Excerpt from Chase's Chase Privacy Notice
REGULATORY LANDSCAPE: Real-time location data collection engages FTC guidance on mobile privacy and sensitive data categories, as well as state comprehensive privacy laws that designate precise geolocation as a sensitive data category requiring heightened protections or explicit consent. California's CPRA classifies precise geolocation data as sensitive personal information, providing consumers the right to limit its use and disclosure. Several other state privacy laws, including those in Virginia, Colorado, and Connecticut, similarly treat precise geolocation as sensitive. GOVERNANCE EXPOSURE: Medium. The policy conditions location collection on user permission, which aligns with standard mobile platform consent mechanisms. However, the use of location data for targeted marketing offers rather than solely for fraud prevention or service delivery creates exposure under state laws that require separate opt-in consent for sensitive data processing beyond core service purposes. JURISDICTION FLAGS: California residents have CPRA rights to limit the use and disclosure of precise geolocation as sensitive personal information. Illinois, Virginia, Colorado, Connecticut, and Texas treat precise geolocation as sensitive under their respective privacy laws, potentially requiring opt-in consent or limiting use to disclosed purposes. Teams should assess whether device-level permission is sufficient under applicable state frameworks or whether additional in-app consent flows are required. CONTRACT AND VENDOR IMPLICATIONS: If location data is shared with third-party marketing or analytics vendors, data processing agreements should confirm that use is limited to disclosed purposes and that vendors do not further sell or share precise geolocation data. Location data sharing with advertising partners may independently trigger CPRA sensitive data restrictions. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that the consent mechanism for location data collection on the Chase mobile app satisfies applicable state sensitive data consent requirements, particularly under CPRA. The policy's description of location data use for 'offers' should be reviewed to determine whether this constitutes a processing purpose that requires separate disclosure or consent beyond the general privacy policy acknowledgment.
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Real-time location data is among the most sensitive categories of personal information, and its collection for marketing offers goes beyond what is strictly necessary to deliver core banking services.
This provision permits Chase to collect your real-time geographic location from your mobile device and use it to deliver targeted offers, meaning your physical movements may inform the marketing content you receive from Chase.
ConductAtlas has identified this type of provision across 21 platforms. See the full comparison.
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