The policy states that Betterment uses Socure for identity verification, which may collect facial images including selfie photographs and identification card images, as well as device information, with Socure's own privacy policy governing the use of that data.
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
This provision discloses collection of facial image data as part of account creation, a category of information that may constitute biometric data under Illinois BIPA and analogous state laws, with data governance delegated to Socure's privacy policy rather than Betterment's stated commitments.
Interpretive note: Whether facial images collected through Socure constitute biometric identifiers under BIPA or analogous statutes depends on how the data is processed (e.g., whether a biometric template is generated), which is not specified in this document.
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 →The agreement establishes that creating a Betterment account may involve collection of facial images and device information by Socure for fraud prevention and identity verification purposes, and that Socure's privacy policy, not Betterment's, governs how that biometric and device data is used.
Cross-platform context
See how other platforms handle Biometric and Identity Verification Data Collection via Socure and similar clauses.
Compare across platforms →"Betterment conducts identity verification through Socure, which may also require the collection of facial images, such as headshots from your identification card and selfie photographs. Socure also collects information about the device accessing a Betterment account to analyze the risk of fraud. By creating an account with Betterment, you acknowledge and agree that the terms of Socure's Privacy Policy will govern Socure's use of such information.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: Collection of facial images and selfie photographs may constitute biometric identifiers or biometric information under the Illinois Biometric Information Privacy Act (BIPA), as well as analogous statutes in Texas (CUBI) and Washington.
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This provision discloses collection of facial image data as part of account creation, a category of information that may constitute biometric data under Illinois BIPA and analogous state laws, with data governance delegated to Socure's privacy policy rather than Betterment's stated commitments.
The agreement establishes that creating a Betterment account may involve collection of facial images and device information by Socure for fraud prevention and identity verification purposes, and that Socure's privacy policy, not Betterment's, governs how that biometric and device data is used.
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