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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If we become aware that a child has provided us with personal data without parental consent, we remove such data and terminate the child's account (except where we are required to retain all or a portion of such data for compliance purposes).
...limit the suspension to only accounts involved in the activities in question...
In the event that you have not logged in or otherwise used the Services for six (6) months or longer following purchase or receipt of a Product during a free trial, we reserve the right to terminate your subscription...
"if we become aware at any point that a child under the age of 18 is using our service, we will terminate their account.Excerpt from Betterment's Privacy Policy
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The clause states: “if we become aware at any point that a child under the age of 18 is using our service, we will terminate their account.”
ConductAtlas has identified this type of provision across 276 platforms. See the full comparison.
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