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 establishes that customer data cannot be deleted within three years, limiting any practical effect of deletion requests during that period.
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' data will be retained by Betterment for a minimum of three years regardless of any preference to have it deleted sooner.
How other platforms handle this
Customer will be permitted to export Customer Data via the Services; provided, that Customer acknowledges and agrees that such ability to export may be limited by the applicable Services plan in effect and the data retention settings enabled by Customer.
We collect and keep personal data only as needed or allowed for the purposes set out in this Statement, based on the reason we collected the personal data in the first instance and what is permitted under the laws that apply to the processing.
Affirm will retain your information in accordance with our Privacy Policy and any applicable state or federal law, rule or regulation.
"Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years.Excerpt from Betterment's Privacy Policy
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The clause is consequential because it establishes that customer data cannot be deleted within three years, limiting any practical effect of deletion requests during that period.
Users' data will be retained by Betterment for a minimum of three years regardless of any preference to have it deleted sooner.
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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