The policy discloses that Betterment shares customer personal information with generative AI service providers, including large language model vendors, and states that Betterment receives assurances from those providers that the data is not used to train their models.
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 discloses a category of third-party data processor not commonly detailed in financial services privacy policies and relies on vendor-provided assurances rather than specifying the contractual or auditable mechanisms that enforce the model training restriction.
Interpretive note: The enforceability and scope of the model training assurances are not described in the document, making it unclear whether they constitute binding contractual restrictions or informal representations.
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 →The agreement authorizes sharing of personal information with generative AI vendors and large language model providers as part of Betterment's service delivery infrastructure. The protection against model training use rests on assurances received from those vendors, the contractual enforceability and audit rights of which are not described in the policy.
Cross-platform context
See how other platforms handle Generative AI Vendor Disclosure and Model Training Assurance and similar clauses.
Compare across platforms →"These service providers also include providers of generative artificial intelligence technologies (including large language models), from which we receive assurances that your personal information is not used for the purpose of model training.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages FTC Act Section 5 authority over unfair or deceptive practices, as well as emerging regulatory guidance from the FTC on AI data practices.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
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This provision discloses a category of third-party data processor not commonly detailed in financial services privacy policies and relies on vendor-provided assurances rather than specifying the contractual or auditable mechanisms that enforce the model training restriction.
The agreement authorizes sharing of personal information with generative AI vendors and large language model providers as part of Betterment's service delivery infrastructure. The protection against model training use rests on assurances received from those vendors, the contractual enforceability and audit rights of which are not described in the policy.
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