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 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.
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To the extent that the rules or terms of those promotions concerning the treatment of your personal information conflict with this Privacy Policy, the rules of those promotions will control.
We require these service providers to contractually commit to security and confidentiality obligations for the Personal Data they process on our behalf.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
"you acknowledge and agree that the terms of Plaid's Privacy Policy will govern Plaid's use of such information, and you expressly agree to the terms and conditions of Plaid's Privacy Policy.Excerpt from Betterment's Privacy Policy
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The clause states: “you acknowledge and agree that the terms of Plaid's Privacy Policy will govern Plaid's use of such information, and you expressly agree to the terms and conditions of Plaid's Privacy Policy.”
ConductAtlas has identified this type of provision across 298 platforms. See the full comparison.
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