Betterment Privacy Policy

This document is Betterment's Privacy Policy governing how Betterment LLC and its affiliates collect, use, share, and protect personal information from users of its investment, cash management, and workplace retirement services, operating under applicable U.S. federal and state privacy frameworks. The policy states that Betterment collects a broad range of personal and financial data including Social Security numbers, account balances, transaction history, employment information, device identifiers, geolocation, and behavioral data from third-party sources, and the terms authorize sharing this data with service providers, financial partners, affiliates, and in connection with business transfers. Notably, the policy addresses California residents' rights under CCPA and asserts opt-out rights for the sale or sharing of personal information, though the breadth of data collected from third-party data aggregators and behavioral tracking tools such as Google Analytics and Google Tag Manager represents a meaningful surface area that may warrant evaluation under applicable state privacy statutes. As a registered investment adviser and fintech platform handling sensitive financial data including retirement accounts and banking information, Betterment's data practices engage the Gramm-Leach-Bliley Act, CCPA, and potentially SEC Regulation S-P governing the safeguarding of customer records; compliance teams should assess whether third-party analytics integrations and the use of tracking technologies on a financial services domain align with the data minimization and consent requirements under these frameworks.