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.
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Affirm will retain your information in accordance with our Privacy Policy and any applicable state or federal law, rule or regulation.
In the event of Account deletion for any reason, the Company may, but is not obligated to, delete any of Your Content. the Company shall not be responsible for the failure to delete or deletion of Your Content.
If the disclosing party sends a written request, the receiving party will promptly return or destroy all Confidential Information received from the disclosing party, together with copies, except that a party may retain archival copies in accordance with its document retention policy or as required b...
"If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.Excerpt from Betterment's Privacy Policy
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The clause states: “If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.”
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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