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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.
View change record →How other platforms handle this
You may make a verifiable consumer request related to your personal information twice per 12-month period.
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.
where the EU GDPR or UK GDPR applies, we will respond within one calendar month of receiving a verifiable request, and where your request is complex...we may extend that period by up to a further two months.
Monitoring
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"We will not discriminate against you for exercising any of your rights. Unless permitted by the State Privacy Laws, we will not: Deny you services. Charge you different prices for our services...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 will not discriminate against you for exercising any of your rights. Unless permitted by the State Privacy Laws, we will not: Deny you services. Charge you different prices for our services...”
ConductAtlas has identified this type of provision across 294 platforms. See the full comparison.
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