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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To the extent that the rules or terms of those promotions concerning the treatment of your personal information conflict with this Privacy Policy, the rules of those promotions will control.
To the extent that any provisions in the Business Terms of Service conflict with these Terms, the Business Terms of Service shall govern to the extent of the conflict.
Regardless of who terminates these Terms, both you and Snap continue to be bound by Sections 2, 3 (to the extent any additional terms and conditions would, by their terms, survive), and 6 - 25 of the Terms.
"Our Terms and Conditions take precedence over any conflicting privacy policy provision.Excerpt from Betterment's Privacy Policy
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The clause states: “Our Terms and Conditions take precedence over any conflicting privacy policy provision.”
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