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 discloses that biometric-adjacent facial image data may be collected and processed by a third-party vendor, Socure, as part of Betterment's identity verification process.
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 →Users undergoing identity verification may have their facial images, including ID headshots and selfies, collected by Socure on Betterment's behalf.
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"Betterment conducts identity verification through Socure, which may also require the collection of facial images, such as headshots from your identification card and selfie photographs.— Excerpt from Betterment's Betterment Privacy Policy
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The clause is consequential because it discloses that biometric-adjacent facial image data may be collected and processed by a third-party vendor, Socure, as part of Betterment's identity verification process.
Users undergoing identity verification may have their facial images, including ID headshots and selfies, collected by Socure on Betterment's behalf.
ConductAtlas has identified this type of provision across 299 platforms. See the full comparison.
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