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 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.
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We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice...but no longer than as required or permitted under applicable law or internal Walmart policy.
Customer will be permitted to export Customer Data via the Services; provided, that Customer acknowledges and agrees that such ability to export may be limited by the applicable Services plan in effect and the data retention settings enabled by Customer.
We will retain personal information and the contents of our communications with you as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period of time.
"When you are no longer our customer, we continue to retain and share your information as described in this notice below.Excerpt from Betterment's Privacy Policy
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The clause states: “When you are no longer our customer, we continue to retain and share your information as described in this notice below.”
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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