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
We will make it clear by notice to you which (if any) goods or services, or website links, we receive a benefit from by featuring them on our Platform.
In certain situations, Glassdoor may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
prevent or detect violations of our Terms or fraud or abuse of Strava or its users; or (4) protect our operations or our property or other legal rights, including in connection with actual or potential litigation.
"We also may disclose information about you if necessary to determine your eligibility to recover compensation in connection with class action lawsuits.Excerpt from Betterment's Privacy Policy
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The clause states: “We also may disclose information about you if necessary to determine your eligibility to recover compensation in connection with class action lawsuits.”
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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