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
In some cases we will seek your consent to send you marketing communications.
Where the law allows us to, we may use the content you and other users have posted for training or to help us to improve the way we filter content on our platform.
We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions and this Privacy Policy.
"the third-party advisor may use your information to provide investment advisory services or market its other services to you.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: “the third-party advisor may use your information to provide investment advisory services or market its other services to you.”
ConductAtlas has identified this type of provision across 278 platforms. See the full comparison.
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