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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These terms may change from time to time. Notice of material changes will be posted on this page with an updated effective date...however, you are responsible for regularly checking this page for any changes.
We will update this Privacy Policy from time to time. We always indicate the date the last changes were published, and if changes are significant, we'll provide a more prominent notice as required by law...
We will provide notice of significant updates, but please check our Privacy Notice periodically for changes. We'll always post the date our Privacy Notice was last updated at the top of the Notice.
"We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review.Excerpt from Betterment's Privacy Policy
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The clause states: “We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review.”
ConductAtlas has identified this type of provision across 288 platforms. See the full comparison.
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