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 grants Betterment unilateral authority to alter the terms governing users' personal information without restriction on timing.
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 privacy terms governing how Betterment handles users' information may be changed by Betterment at its discretion and at any time.
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We may update this Notice from time to time. We will notify you of material changes to this Notice and will update the Last Revised date on this Notice.
If we make material changes to it or the ways we process your information, we'll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).
Occasionally, we may update this privacy policy (or other documents in the Adobe Privacy Center) to allow Adobe to accommodate new technologies, industry practices, regulatory requirements or for other purposes.
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"We reserve the right to amend this privacy policy at our discretion and at any time.— Excerpt from Betterment's Betterment Privacy Policy
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The clause is consequential because it grants Betterment unilateral authority to alter the terms governing users' personal information without restriction on timing.
The privacy terms governing how Betterment handles users' information may be changed by Betterment at its discretion and at any time.
ConductAtlas has identified this type of provision across 289 platforms. See the full comparison.
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