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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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"As noted above, although this use of personal information may constitute a "sale" of personal information under certain State Privacy Laws, Betterment never receives monetary payments in exchange for personal information...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: “As noted above, although this use of personal information may constitute a "sale" of personal information under certain State Privacy Laws, Betterment never receives monetary payments in exchange for personal information...”
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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