The policy states that by using Betterment's services, customers acknowledge and agree that the privacy policies of multiple third-party providers, including Socure, Plaid, Stripe, MX Technologies, Apex Clearing, Ascensus, and Capitalize, govern those providers' use of customer data, and in some cases expressly grants those providers the right, power, and authority to access, store, and transmit customer information.
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
This provision establishes that data governance for a material portion of customer information is delegated to the terms of multiple third-party providers, and in the case of Plaid and Stripe, customers expressly authorize those providers to access and transmit their financial and payment information under those providers' own privacy frameworks.
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 →Under these clauses, the agreement incorporates by reference the privacy policies of Socure, Plaid, Stripe, MX Technologies, Apex Clearing, Ascensus, and Capitalize, meaning customers are bound by the data practices of each provider for information processed through those services, in addition to Betterment's stated commitments.
Cross-platform context
See how other platforms handle Third-Party Provider Privacy Policy Delegation (Plaid, Stripe, Socure, MX, Apex, Ascensus) and similar clauses.
Compare across platforms →"By creating an account with Betterment, you acknowledge and agree that the terms of Socure's Privacy Policy will govern Socure's use of such information. Betterment offers account linking and aggregation services through Plaid Inc. ('Plaid'). By using account linking and aggregation services, you acknowledge and agree that the terms of Plaid's Privacy Policy will govern Plaid's use of such information, and you expressly agree to the terms and conditions of Plaid's Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide these services to you. Betterment uses Stripe, Inc. ('Stripe') to process customer payments. By using these payment services, you acknowledge and agree to the terms of Stripe's Privacy Policy. Further, you expressly grant Stripe the right, power, and authority to access, store, and transmit your payment information as reasonably necessary for Stripe to provide these services to you.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GLBA requirements for financial institution data sharing with service providers, CCPA/CPRA service provider and contractor classification requirements, and FTC Act authority over data handling representations.
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This provision establishes that data governance for a material portion of customer information is delegated to the terms of multiple third-party providers, and in the case of Plaid and Stripe, customers expressly authorize those providers to access and transmit their financial and payment information under those providers' own privacy frameworks.
Under these clauses, the agreement incorporates by reference the privacy policies of Socure, Plaid, Stripe, MX Technologies, Apex Clearing, Ascensus, and Capitalize, meaning customers are bound by the data practices of each provider for information processed through those services, in addition to Betterment's stated commitments.
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