Betterment may share your personal and financial information with financial company partners for joint marketing purposes, which means these partners can use your data to market their own products to you.
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 establishes a data sharing framework that permits Betterment to disclose user information to affiliated financial institutions for marketing purposes, expanding the circle of entities with access to customer data beyond Betterment's direct operations.
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 →Removal of this provision eliminates disclosure about joint marketing practices, replaced by more specific 'Marketing Communications and Opt-Out' provision with direct contact information.
View full change record →Your financial data, including account details and contact information, may be shared with third-party financial firms for marketing, broadening who has access to your personal information.
How other platforms handle this
We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information...
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"For joint marketing with other financial companies - To offer our products and services to you. Our joint marketing partners include our banking partner, nbkc bank, and other financial services companies.Excerpt from Betterment's Privacy Policy
Joint marketing arrangements under GLBA require financial institutions to provide customers with opt-out rights and maintain contractual restrictions on partner data use.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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The clause establishes a data sharing framework that permits Betterment to disclose user information to affiliated financial institutions for marketing purposes, expanding the circle of entities with access to customer data beyond Betterment's direct operations.
Your financial data, including account details and contact information, may be shared with third-party financial firms for marketing, broadening who has access to your personal information.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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