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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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Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
When you exercise any of your applicable legal rights to access, amend, or delete your personal information, we may request additional information from you for the purpose of confirming your identity.
If we deny your rights request, you have the right to appeal that decision. We will provide you with the necessary information to submit an appeal at that time.
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"We may deny your Data Subject Requests to delete if your data is: Not protected under CCPA; Subject to retention under federal law or regulation; Necessary for us or our service providers to: Detect security incidents...Excerpt from Betterment's Privacy Policy
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The clause states: “We may deny your Data Subject Requests to delete if your data is: Not protected under CCPA; Subject to retention under federal law or regulation; Necessary for us or our service providers to: Detect security incidents...”
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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