Provision record
Betterment · Betterment Privacy Policy · View original document ↗

Third-Party Tracking Technologies and Behavioral Data Collection

Medium severity Medium confidence Explicit document language Common · 278 of 352 platforms
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Document Record

What it is

Betterment uses cookies and third-party tools like Google Analytics to track your behavior on its website and app, collecting data such as your IP address, device information, and browsing activity.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

For a financial services platform holding highly sensitive data, the use of third-party behavioral tracking tools on core product pages raises questions about whether behavioral data derived from financial account interactions is being shared with advertising technology providers.

Interpretive note: The policy does not specify whether tracking technologies are active on authenticated account pages or limited to marketing pages, creating uncertainty about the scope of behavioral data shared with analytics vendors.

Recent Activity

This document changed recently

Medium Jul 1, 2026

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 →

Clause Stability Stable

0
Changes
5
Months Monitored
May 10, 2026
First Seen
May 22, 2026
Last Seen
This clause type exists across 3334 other provisions on other platforms.

Consumer impact (what this means for users)

This provision means that your browsing and interaction patterns on Betterment's platform, potentially including pages visited within your investment account interface, may be observed and shared with third-party analytics vendors like Google.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Use the cookie preference or Do Not Sell or Share My Personal Information link in Betterment's website footer to opt out of tracking for advertising purposes. You can also enable the Global Privacy Control browser signal, which Betterment may be required to honor under applicable state law.

How other platforms handle this

MyFitnessPal Medium

We use your personal information to send you newsletters and other promotional communications, including information about MyFitnessPal's new offerings, features, offers, events, webinars, and other information.

Lyft Medium

We may infer certain information from your interactions with the Lyft Platform and other personal information available to us. For example, if you frequently ride to or from airports, we may infer you are a frequent traveler.

Square Medium

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.

See all platforms with this clause type →
▸ View Original Clause Language DOCUMENT RECORD
"
We use cookies, web beacons, pixel tags, and similar tracking technologies on our websites and mobile applications. We may also use third-party analytics and advertising partners, such as Google Analytics and Google Tag Manager, to collect information about how you use our services. This information may include your IP address, browser type, device identifiers, pages visited, and interactions with our content.

Excerpt from Betterment's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1) REGULATORY LANDSCAPE: The deployment of third-party tracking technologies on a GLBA-covered financial services platform may implicate GLBA's restrictions on sharing nonpublic personal information with non-affiliated third parties.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

CCPA/CPRA
California, USA
CAN-SPAM
United States Federal
FCRA
United States Federal
FTC Act Section 5
United States Federal
GLBA
United States Federal

Provision details

Document information
Document
Betterment Privacy Policy
Entity
Betterment
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009206
Document ID
CA-D-00212
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
629c272827ea0612be12e62d401333f60cf68e24915b52ee0ededd29e635c68b
Analysis generated
May 10, 2026 15:51 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Betterment
Document: Betterment Privacy Policy
Record ID: CA-P-009206
Captured: 2026-05-10 15:51:14 UTC
SHA-256: 629c272827ea0612…
URL: https://conductatlas.com/platform/betterment/betterment-privacy-policy/provision/CA-P-009206/third-party-tracking-technologies-and-behavioral-data-collection/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Betterment's Third-Party Tracking Technologies and Behavioral Data Collection clause do?

For a financial services platform holding highly sensitive data, the use of third-party behavioral tracking tools on core product pages raises questions about whether behavioral data derived from financial account interactions is being shared with advertising technology providers.

How does this clause affect you?

This provision means that your browsing and interaction patterns on Betterment's platform, potentially including pages visited within your investment account interface, may be observed and shared with third-party analytics vendors like Google.

How many platforms have this type of clause?

ConductAtlas has identified this type of provision across 278 platforms. See the full comparison.

Is ConductAtlas affiliated with Betterment?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Betterment.