Betterment collects sensitive categories of personal information, which may include Social Security numbers, financial account details, and other identifiers required for financial services.
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 establishes the scope of sensitive data categories that Betterment's identity verification procedures are authorized to collect as part of account onboarding and verification processes. The use of third-party identity verification services (Socure) creates data handling obligations across multiple entities.
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 →Renamed from 'Sensitive Personal Information Collection' (high severity) to 'Sensitive Financial Data Collection' (medium severity), with addition of concrete examples of identifiers and financial data collected.
View full change record →Your most sensitive personal and financial data is held by Betterment, and understanding how it is secured and with whom it is shared is important for assessing your personal risk exposure.
How other platforms handle this
You may give us your Identity Data, Contact Data, Financial Data, Profile Data, and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise.
you may refer a friend to Instacart or send an Instacart gift delivery or gift card to someone. In these cases, we collect the recipient's name, email, and delivery address, as applicable.
We collect information about your use of the Services, such as the dates and times of access, browsing history, search, information about the links you click and about third-party applications...
"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. Sensitive Personal Information - Government-issued identifiers (such as Social Security number and driver's license), financial account numbers in combination with login credentials, and facial images used for identification.Excerpt from Betterment's Privacy Policy
Collection of sensitive personal information under CPRA triggers additional obligations including limited use requirements and the right for consumers to restrict its processing.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision establishes the scope of sensitive data categories that Betterment's identity verification procedures are authorized to collect as part of account onboarding and verification processes. The use of third-party identity verification services (Socure) creates data handling obligations across multiple entities.
Your most sensitive personal and financial data is held by Betterment, and understanding how it is secured and with whom it is shared is important for assessing your personal risk exposure.
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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