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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We may retain your Personal Data for a period of time consistent with the original purpose of collection...or as long as required to fulfill our legal and/or regulatory obligations.
Any biometric data we collect from you will be deleted within 48 hours and will be used for the purpose of enabling you to see yourself wearing virtual eyeglass frames.
We store your personal information for a period of time that is consistent with the business purposes set forth in Section 3 of this policy or as long as needed to fulfill and comply with legal obligations.
"Certain personal information that we collect and use to provide you with financial services, and which Betterment is obligated by federal law and/or regulations to retain, cannot be deleted upon request.Excerpt from Betterment's Privacy Policy
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The clause states: “Certain personal information that we collect and use to provide you with financial services, and which Betterment is obligated by federal law and/or regulations to retain, cannot be deleted upon request.”
ConductAtlas has identified this type of provision across 275 platforms. See the full comparison.
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