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.
View change record →How other platforms handle this
you may refer a friend to Instacart or send an Instacart gift delivery or gift card to someone. In these cases, we collect the recipient's name, email, and delivery address, as applicable.
We collect information about your use of the Services, such as the dates and times of access, browsing history, search, information about the links you click and about third-party applications...
For paid subscriptions, we collect details like name, billing address, and payment specifics.
"When you choose to create an account with Betterment, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, social security number and information about financial status.Excerpt from Betterment's Privacy Policy
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The clause states: “When you choose to create an account with Betterment, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, social security number and information about financial status.”
ConductAtlas has identified this type of provision across 296 platforms. See the full comparison.
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