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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You may contact our privacy team with any requests of disclosure, correction, or deletion of your personal information. You may also request suspension of use or suspension of sharing of your personal information with certain third parties.
When you use them, we'll validate your request by verifying your identity (for example, by confirming that you're signed in to your Google Account).
If you are an end user in a Workspace not owned by you and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization who owns your ClickUp Workspace.
"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.
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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 289 platforms. See the full comparison.
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