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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If the disclosing party sends a written request, the receiving party will promptly return or destroy all Confidential Information received from the disclosing party, together with copies, except that a party may retain archival copies in accordance with its document retention policy or as required b...
In limited circumstances, we may retain certain information for purposes including safety, security, fraud prevention, and compliance with our legal obligations.
to the extent practicable, upon request of the Disclosing Party return or destroy all Confidential Information of the Disclosing Party that is in its possession upon termination or expiration of this Agreement.
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"To the extent you enter identifying information as part of the account application process, we are required by law to store that information to comply with federal regulations.— Excerpt from Betterment's Betterment Privacy Policy
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The clause states: “To the extent you enter identifying information as part of the account application process, we are required by law to store that information to comply with federal regulations.”
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