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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This Privacy Policy is also incorporated into and governed by our Terms of Use.
Because our Services may be utilized without a subscription, canceling your subscription does not remove your profile from our Services. If you wish to fully terminate your account, you must terminate your account as set forth in Section 9.
This Policy does not apply to Personal Data we process in our role as a data processor or service provider on behalf of our customers and partners.
"By using and continuing to use the Betterment websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto.Excerpt from Betterment's Privacy Policy
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The clause states: “By using and continuing to use the Betterment websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto.”
ConductAtlas has identified this type of provision across 297 platforms. See the full comparison.
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