Google to bar loan apps from accessing users’ photos, contacts in Nigeria and Kenya

Tech giant Google has stated in a recent update that apps aiming to provide or facilitate personal loans may not access user contacts or photos effective from May 31, 2023. Hitherto, loan apps in Nigeria make it compulsory for users to grant permission to access their photos and contacts. The loan apps companies have been using this to harass defaulting consumers by sending messages to the contacts, blackmailing the defaulters.

In its update, it specifies “personal loans as lending money from one individual, organization, or entity to an individual consumer on a nonrecurring basis, not for the purpose of financing purchase of a fixed asset or education.”

“Personal loan consumers require information about the quality, features, fees, repayment schedule, risks, and benefits of loan products in order to make informed decisions about whether to undertake the loan.”

Apps that provide personal loans, including but not limited to apps which offer loans directly, lead generators, and those who connect consumers with third-party lenders, must have the App Category set to “Finance” in Play Console and disclose the following information in the app metadata:

• Minimum and maximum period for repayment
• Maximum Annual Percentage Rate (APR), which generally includes interest rate plus fees and other costs for a year, or similar other rate calculated consistently with local law
• A representative example of the total cost of the loan, including the principal and all applicable fees
• A privacy policy that comprehensively discloses the access, collection, use, and sharing of personal and sensitive user data, subject to the restrictions outlined in this policy

We do not allow apps that promote personal loans which require repayment in full in 60 days or less from the date the loan is issued (we refer to these as “short-term personal loans”).

We must be able to establish a connection between your developer account and any provided licenses or documentation proving your ability to service personal loans. Additional information or documents may be requested to confirm your account is in compliance with all local laws and regulations.

Apps that provide personal loans, or have the primary purpose of facilitating access to personal loans (i.e., lead generators or facilitators), are prohibited from accessing sensitive data, such as photos and contacts. The following permissions are prohibited:

• Read_external_storage
• Read_media_images
• Read_contacts
• Access_fine_location
• Read_phone_numbers
• Read_media_videos

Additional requirements for personal loan apps in Nigeria and Kenya

1. Nigeria
   • Complete the Personal Loan App Declaration for Nigeria, and provide necessary documentation to support your declaration.
     • Digital Money Lenders (DML) must adhere to and complete the LIMITED INTERIM REGULATORY/ REGISTRATION FRAMEWORK AND GUIDELINES FOR DIGITAL LENDING, 2022 (as may be amended from time to time) by the Federal Competition and Consumer Protection Commission (FCCPC) of Nigeria and obtain a verifiable approval letter from the FCCPC.
     • Loan Aggregators must provide documentation and/or certification for digital lending services and contact details for every partnered DML.
     • You must, upon Google Play’s request, provide additional information or documents relating to your compliance with the applicable regulatory and licensing requirements.
2. Kenya
   • Complete the Personal Loan App Declaration for Kenya, and provide the necessary documentation to support your declaration.
     • Digital Credit Providers (DCP) should complete the DCP registration process and obtain a license from the Central Bank of Kenya (CBK). You must provide a copy of your license from the CBK as part of your declaration.
     • If you are not directly engaged in money lending activities and are only providing a platform to facilitate money lending by registered DCP(s) to users, you will need to accurately reflect this in the declaration and provide a copy of the DCP license of your respective partner(s).
     • Currently, we only accept declarations and licenses from entities published under the Directory of Digital Credit Providers on the official website of the CBK.

The Federal Competition and Consumer Protection Commission (FCCPC) recently released a list of 173 companies approved to provide digital lending services in Nigeria. This is the list that Google would likely use to vet digital lending companies in Nigeria.