Apple is updating its privacy policy for Apple Card to enable sharing more anonymized data with Goldman Sachs, its financial partner. Apple’s reasoning here is that this will make it able to do a better job of assigning credit to new customers.

The data is aggregate and anonymized, and there is an opt-out.

Three things are happening here:

Apple is changing the privacy policy for Apple Card with iOS to share a richer, but still anonymized set of data with Goldman Sachs in order to allow the creation of a new credit assignment model, which could expand the group of users that may be able to secure credit.

There is also a beefed up fallback method in the works that will allow users to share more personal data on an opt-in basis with Goldman Sachs if you do not at first get approved. Things like purchase history of Apple products, when you created your Apple ID and how much you spend with Apple. This has always existed and you may have seen it if the default modeling rejected your Apple Card application — but it may have a few more data points after the new modeling. It will still be very clearly opt-in with a large share button as it is now.

data on an basis with Goldman Sachs if you do not at first get approved. Things like purchase history of Apple products, when you created your Apple ID and how much you spend with Apple. This has always existed and you may have seen it if the default modeling rejected your Apple Card application — but it may have a few more data points after the new modeling. It will still be very clearly opt-in with a large share button as it is now. Apple is also finally adding detail to its internal transactions. You no longer have to wonder what that random charge labeled Apple Services is for, you’ll get detail on the Hillary Duff box set or Gambino album you purchased right in the list inside Wallet.

As a side effect of the Apple Card policy evolving here it’s also being split off from the Apple Pay privacy policy. Much of the language is either identical or nearly so, but this allows Apple to make changes like the ones above to Apple Card without having to interleave that with the Apple Pay policy — as not all Apple Pay customers are Apple Card customers.

The new policy appears in iOS 13.4 updates, but the opt-in sharing of data points will not immediately roll out for new Apple Card users and will begin appearing later.

Here is the additional language that is appearing in the Apple Card privacy notice related to data sharing, with some sections highlighted by us:

You may be eligible for certain Apple Card programs provided by Goldman Sachs based on the information provided as part of your application. Apple may know whether you receive the invitation to participate and whether you accept or decline the invitation, and may share that information with Goldman Sachs to effectuate the program. Apple will not know additional details about your participation in the program. Apple may use information about your account with Apple, such as the fact that you have Apple Card, for internal research and analytics purposes, such as financial forecasting. Apple may also use information about your relationship with Apple, such as what Apple products you have purchased, how long you have had your Apple ID, and how often you transact with Apple, to improve Apple Card by helping to identify Apple metrics that may assist Goldman Sachs in improving credit decisioning. No personally identifiable information about your relationship with Apple will be shared with Goldman Sachs to identify the relevant Apple metrics. You can opt out of this use or your Apple relationship information by emailing our privacy team at dpo@apple.com with the subject line “Apple Relationship Data and Apple Card.” Applicants and cardholders may be able to choose to share the identified metrics with Goldman Sachs for re-evaluation of their offer of credit or to increase their credit line. Apple may share information about your relationship with Apple with our service providers, who are obligated to handle the information consistent with this notice and Apple instructions, are required to use reasonable security measures to protect any personal information received, and must delete the personal information as soon as they have completed the services.

Some thoughts on all of this.

The fact that Apple is sharing a new anonymized, non-personally identifiable information (PII), customer model with Goldman likely engenders two valid responses.

First, there is more data being shared here than there was before, which is always something that should be examined closely, and all of us should be as cognizant as possible about how much information gets traded around about us. That said, your average co-branded card offer (say an airline card or retailer card) is controlled nearly entirely by the financial services side of that equation (basically the credit card companies decide what data they get and how).

Apple’s deal with Goldman Sachs is unique in a lot of ways, not the least of which is that Apple has controlled the flow of data from customers to Goldman very tightly from the beginning. Evidenced by affordances it continues to offer like skipping your March payment to Apple Card without incurring interest. This new arrangement outlined in the privacy policy does not share any PII unless there is an opt-in, and even allows an opt-out of the anonymized model share.

I cannot stress enough how rare that is in financial products, especially credit cards. Most cards take all of the above information and much more in their approval process, and they don’t do any work beyond what is required by regulatory law to inform you of that. Apple is doing more than most.

THAT SAID. I do wish that the opt-out of the anonymized data model was presented in the flow of normal signup, rather than existing as an email address in the privacy policy. I know why this is, because the model is likely to be far more effective and a lot more people will likely get approved for an Apple Card using it.

But in keeping with the stated Apple goals of protecting user privacy and making the policy as transparent as possible, I would prefer that they find a long-term solution that communicates all of those factors to the user clearly and then offers them the ability to risk non-approval by limiting data share.

The idea behind the new data sharing and eventual modeling, as well as the secondary opt-in disclosure of nine key bits of actually personal information about your purchase history and other things is that Apple will be able to offer credit to people who may be automatically rejected under the old way of doing things. And, out beyond that, it will be able to build tools that help customers manage debt and credit more accurately and transparently. Especially those new to credit.

Any time an agreement changes to enable more data to flow, my eyebrows arch. But there is a pretty straight line to be drawn here between the way that Apple transparently and aggressively helps users to not pay interest on Apple Card and the potential for more useful financial product enhancements to Apple Card down the line.

If you’ve ever looked at a credit card statement, you know that it can often be difficult to ascertain exactly how much you need to pay at any given time to avoid interest. In the Apple Card interface it’s insanely clear exactly how and when to pay so that you don’t get charged. Most of the industry follows practices that prey on behavioral norms — people will pay the minimum payment by default because that’s what seems logical, rather than paying what is most healthy for them to pay.

My hope here is that the additional modeling makes room for more of these kinds of product decisions for Apple Card down the line. But, my eyes are up and yours should be too. Check the policy, opt-out if it makes sense to you and always be aware of the data you’re sharing, who with and what they plan to use it for.