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 a mandatory screening practice in which users' identifying information is matched against government terrorist watchlists.
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' identifying information will be checked by Betterment against government-provided lists of suspected terrorists.
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any personal information that you provide through the Walmart Sites will be used by Walmart in accordance with Walmart's Privacy Policy
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"You understand and agree that Betterment will compare your identifying information with government-provided lists of suspected terrorists.— Excerpt from Betterment's Betterment Privacy Policy
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The clause is consequential because it discloses a mandatory screening practice in which users' identifying information is matched against government terrorist watchlists.
Users' identifying information will be checked by Betterment against government-provided lists of suspected terrorists.
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