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 have implemented administrative, technical, physical, electronic, and managerial procedures to safeguard and secure the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
"encrypting data, restricting access to sensitive information solely to employees who need to use that information for a business purpose, and entering into contractual agreements that are intended to protect the confidentiality of any customer information...Excerpt from Betterment's Privacy Policy
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The clause states: “encrypting data, restricting access to sensitive information solely to employees who need to use that information for a business purpose, and entering into contractual agreements that are intended to protect the confidentiality of any customer information...”
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