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 use Service Data to provide you and our customers with recommendations (for example, suggesting ways to better secure your account or data, reduce service charges or improve performance, or optimize your configurations)...
we may use this information to make it easier for you to find the people you want to send payments to, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services.
Developing new products and services and improving the Services
"If you link external accounts to your Betterment account, we may use transactional data from those accounts to provide you with financial advice or to recommend additional Betterment products and services to you.Excerpt from Betterment's Privacy Policy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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The clause states: “If you link external accounts to your Betterment account, we may use transactional data from those accounts to provide you with financial advice or to recommend additional Betterment products and services to you.”
ConductAtlas has identified this type of provision across 278 platforms. See the full comparison.
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