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
Send You Promotional and Marketing Materials Consent (where required by law) Legitimate Interests when consent is not required by law (specifically our interests in marketing features and products that may interest you...)
In some cases we will seek your consent to send you marketing communications.
We may use your Personal Data to send you information about the services provided by the ZipRecruiter Group; provided, however that we will obtain consent to do so where required by applicable law.
"We (or service providers on our behalf) may then send communications and marketing to your email.Excerpt from Betterment's Privacy Policy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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The clause states: “We (or service providers on our behalf) may then send communications and marketing to your email.”
ConductAtlas has identified this type of provision across 278 platforms. See the full comparison.
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