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 defines the extent of Betterment's stated protection: the safeguard rests on third-party assurances rather than Betterment's own direct control over how AI providers use personal data.
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' personal information shared with generative AI providers is covered only by assurances those providers give to Betterment, not by a direct contractual right held by the user.
How other platforms handle this
We generate new information from other data we collect to derive likely preferences or other characteristics. For instance, we infer your general geographic location based on your IP address.
Microsoft also emphasizes the importance of validating AI models responsibly to enhance fairness and alignment with reality.
To achieve these processing purposes, we use algorithms to recognize patterns in Service Data, manual review of Service Data (such as when you interact directly with our billing or support teams)...
"providers of generative artificial intelligence technologies (including large language models), from which we receive assurances that your personal information is not used for the purpose of model training.Excerpt from Betterment's Privacy Policy
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The clause is consequential because it defines the extent of Betterment's stated protection: the safeguard rests on third-party assurances rather than Betterment's own direct control over how AI providers use personal data.
Users' personal information shared with generative AI providers is covered only by assurances those providers give to Betterment, not by a direct contractual right held by the user.
ConductAtlas has identified this type of provision across 216 platforms. See the full comparison.
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