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The policy states that Betterment retains all customer data for a minimum of three years due to U.S. regulatory requirements, and continues to retain data on closed or deleted accounts for legal, regulatory, and security purposes.
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 that deletion requests, including account closure requests, do not result in full data removal; data is retained for at minimum three years under stated regulatory obligations, and potentially longer for legal or security purposes.
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 →Under these terms, customers who close their accounts or submit deletion requests should expect that Betterment will retain their personal and financial information for at least three years. The policy states this retention is required by U.S. regulatory requirements and that deletion requests may be denied on these grounds.
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"Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years. Please note that we retain information on deleted accounts as required for legal, regulatory and security purposes.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: The three-year minimum retention period references U.S. regulatory requirements applicable to registered investment advisors and broker-dealers, which include SEC Rule 17a-4 (broker-dealer records), SEC Regulation S-P (investment advisor customer records), and FINRA recordkeeping requirements. GLBA also imposes data safeguarding obligations that may extend to retained records. CCPA/CPRA permits denial of deletion requests where data retention is required by law or necessary to comply with legal obligations, which Betterment invokes as a basis for retention following account closure. 2) GOVERNANCE EXPOSURE: Medium. The policy asserts a regulatory basis for retention but does not specify which regulations mandate which retention periods for which data categories. This may create ambiguity in responding to data subject requests under state privacy laws, particularly where the GLBA exemption scope is contested. 3) JURISDICTION FLAGS: California (CCPA/CPRA deletion right exceptions), Colorado, Virginia, and other state privacy law jurisdictions impose obligations to honor deletion requests subject to defined exceptions. The GLBA legal obligation exception is broadly available but must be applied on a data-category-specific basis. EU/EEA users (if any) would require GDPR Article 17 retention exception justification for each retained data category. 4) CONTRACT AND VENDOR IMPLICATIONS: Employers and plan sponsors using Betterment at Work should confirm whether their service agreements address data retention timelines for plan participant data following plan termination or sponsor departure, and whether those timelines align with applicable ERISA recordkeeping requirements. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should maintain a data retention schedule that maps specific data categories to the applicable regulatory retention requirement, establish a process for evaluating deletion requests against the GLBA and other legal exceptions on a category-specific basis, and ensure that third-party service providers who have received customer data apply consistent retention and deletion practices.
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This provision establishes that deletion requests, including account closure requests, do not result in full data removal; data is retained for at minimum three years under stated regulatory obligations, and potentially longer for legal or security purposes.
Under these terms, customers who close their accounts or submit deletion requests should expect that Betterment will retain their personal and financial information for at least three years. The policy states this retention is required by U.S. regulatory requirements and that deletion requests may be denied on these grounds.
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