Betterment says it takes steps to protect your personal information, but explicitly acknowledges that it cannot guarantee your data will always be secure.
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
Despite holding extremely sensitive financial data including SSNs and bank account numbers, Betterment's policy includes a standard disclaimer that no security system is impenetrable, which is standard but relevant given the sensitivity of the data involved.
This provision means that while Betterment maintains security measures, it limits its liability if your sensitive financial data is compromised, and users should be aware that no security guarantee is provided.
How other platforms handle this
If you would like to opt out of the disclosure of your personal information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" or processing for purposes of targeted advertising, please visit the following link, which is also available in the...
Zendesk complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. When Zendesk transfers personal data from the EU, UK, or Switzerland to the United ...
Client Deletion Requests. In connection with separate regulatory recordkeeping obligations imposed on Wealthfront, we generally must maintain and cannot delete Personal Information associated with our Clients.
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"We implement technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and we cannot guarantee that your personal information will be secure in all circumstances.— Excerpt from Betterment's Betterment Privacy Policy
1) REGULATORY LANDSCAPE: GLBA and SEC Regulation S-P require registered investment advisers and financial institutions to maintain written information security programs with specific safeguards. The FTC Safeguards Rule, as amended, requires nonbank financial companies to implement administrative, technical, and physical safeguards. State breach notification laws require prompt notification of affected consumers if a data breach occurs. Betterment's disclaimer that it cannot guarantee security does not limit its statutory obligations under these frameworks. 2) GOVERNANCE EXPOSURE: Medium. The provision's disclaimer language is standard across the industry but does not reduce Betterment's regulatory obligations under GLBA, the FTC Safeguards Rule, or SEC Regulation S-P. Regulators assess whether reasonable safeguards were in place regardless of contractual disclaimers. 3) JURISDICTION FLAGS: All 50 states require notification to affected consumers and relevant regulators in the event of a breach involving specified categories of personal information including SSNs and financial account numbers. New York's SHIELD Act and California's data breach notification law impose relatively stringent requirements. Financial regulators including SEC and FINRA have additional notification obligations for registered entities. 4) CONTRACT AND VENDOR IMPLICATIONS: Service providers handling Betterment's data must also maintain appropriate security safeguards, and Betterment retains responsibility under GLBA for service provider oversight. Vendor contracts should include security standards, audit rights, and breach notification obligations with timelines consistent with statutory requirements. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that Betterment's information security program satisfies the FTC Safeguards Rule's specific requirements as amended in 2023, including a written risk assessment, access controls, encryption in transit and at rest, and a designated qualified individual responsible for the information security program. Incident response plans should address all applicable state and federal notification timelines.
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Despite holding extremely sensitive financial data including SSNs and bank account numbers, Betterment's policy includes a standard disclaimer that no security system is impenetrable, which is standard but relevant given the sensitivity of the data involved.
This provision means that while Betterment maintains security measures, it limits its liability if your sensitive financial data is compromised, and users should be aware that no security guarantee is provided.
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