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The policy reserves the right for Betterment to modify its terms at any time without prior notice, with changes effective immediately upon posting; for material changes, the document states Betterment will make best-efforts notification via email or in-app alert.
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 the governing privacy terms can change without advance notice, with the revised version taking effect upon publication, and places responsibility on users to monitor the policy for updates.
Interpretive note: The policy does not define 'material' changes, and the best-efforts notification standard may not satisfy the requirements of all applicable state privacy laws or GLBA notice obligations in all circumstances.
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 this clause, the terms governing Betterment's data collection and sharing practices may change at any time, with immediate effect upon posting. For material changes, the policy states Betterment will make best-efforts notifications, though the provision does not guarantee advance notice or a grace period before new terms apply.
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"We reserve the right to amend this privacy policy at our discretion and at any time. We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app.Excerpt from Betterment's Privacy Policy
1) REGULATORY LANDSCAPE: Several state privacy laws, including CCPA/CPRA and various state consumer protection statutes, may impose requirements on how material privacy policy changes are communicated to consumers, particularly where new data practices are introduced. The FTC has taken enforcement action against companies that implemented material privacy changes without adequate notice or consent. GLBA also requires financial institutions to provide updated privacy notices when practices change in ways that require disclosure. 2) GOVERNANCE EXPOSURE: Medium. The best-efforts notification standard for material changes does not specify what constitutes a 'material' change, the timeframe for notification, or whether prior consent is required before new practices take effect. This ambiguity may create exposure under state privacy laws that require affirmative consent for material changes to data practices. 3) JURISDICTION FLAGS: California (CCPA/CPRA) and states with enacted consumer privacy laws may require more than best-efforts notification for changes that introduce new categories of data processing or sharing. EU/EEA users under GDPR would require a lawful basis for any materially changed processing activity, which immediate-effect posting may not satisfy. 4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers and employer plan sponsors using the Betterment at Work platform should evaluate whether their service agreements include provisions that lock in specific privacy terms or require notice before changes affecting their employee data take effect. 5) COMPLIANCE CONSIDERATIONS: Legal teams should assess whether the policy's amendment mechanism satisfies GLBA annual privacy notice requirements (or qualifies for the alternative delivery method exception), whether 'material change' is defined consistently with applicable state law standards, and whether a consent mechanism is required before applying changed terms to existing customer data.
This provision establishes that the governing privacy terms can change without advance notice, with the revised version taking effect upon publication, and places responsibility on users to monitor the policy for updates.
Under this clause, the terms governing Betterment's data collection and sharing practices may change at any time, with immediate effect upon posting. For material changes, the policy states Betterment will make best-efforts notifications, though the provision does not guarantee advance notice or a grace period before new terms apply.
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