This analysis describes what Betterment'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
The clause is consequential because it acknowledges that Betterment's advertising technology practices may trigger legal protections afforded to consumers under State Privacy Laws governing the sale or sharing of personal information.
The updated policy discloses a new Fully Paid Securities Lending program through Apex Clearing, under which Betterment will share customer personal information and account details with Apex if customers choose to participate. The revised terms also establish that generative AI service providers have committed that personal information will not be used for model training. For customers participating in promotional offers requiring offline fulfillment, the policy now explicitly states that personal information including mailing address may be shared with third-party partners. You can review the FPSL Program supplemental disclosures for details about the securities lending arrangement, or choose not to participate in the program.
View change record →Users of Betterment's website may have their information treated as sold or shared under applicable State Privacy Laws as a result of Betterment's advertising technology.
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Under Section 1798.83, Ancestry currently does not share any Personal Information with third parties for their own direct marketing purposes.
The types of third parties your information may be disclosed to include: our resellers and other sales and advertising partners, retailers, advertisers, ad agencies, advertising networks and platforms, information service providers, fraud monitoring and prevention providers, and publishers.
"We do use advertising technology on our website, which under some State Privacy Laws may be considered a "sale" or "share" of your information.Excerpt from Betterment's Privacy Policy
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The clause is consequential because it acknowledges that Betterment's advertising technology practices may trigger legal protections afforded to consumers under State Privacy Laws governing the sale or sharing of personal information.
Users of Betterment's website may have their information treated as sold or shared under applicable State Privacy Laws as a result of Betterment's advertising technology.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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