Privacy Policy
Last updated July 29, 2024
Introduction
Welcome to Betterment.
We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Betterment LLC (“Betterment”), MTG LLC d/b/a Betterment Securities, Betterment for Business LLC, and Betterment Financial LLC (collectively, the “Betterment Entities”) collect, including through our websites (www.betterment.com, advisors.betterment.com, and www.betterment.com/401k), Betterment’s original articles, our iOS mobile application and our Android mobile application. It also explains why we collect your information and how we use it.
Privacy is important to Betterment. We will never rent or sell your information to anyone. If you have any questions or if you believe that Betterment has not adhered to this privacy policy, please send us a note at [email protected]. We reserve the right to amend this privacy policy at our discretion and at any time.
Table of Contents
Privacy Notice
- What does Betterment do with your personal information?
- How do we use and share your personal information?
- Who we are
- What we do
- Key definitions
Full Privacy Policy
- Information we collect and why
- How we use your personal information
- How we share your information
- Opt-out information
- How to request deletion of the personal information we collect
- How your personal information is protected
- How you can access or change your personal information
- Anonymized information
- Other important information
- Additional disclosures: U.S. state privacy notice and California notice at collection
What does Betterment do with your personal information?
Why?
Financial companies choose how they share your personal information. Federal and state laws give consumers the right to limit some but not all sharing. Federal and state laws also require us to tell you how we collect, use, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on whether you are a visitor to our website or a customer and, if a customer, the product or service you have with us. Information we collect from customer includes, among other information:
- Full legal name, date of birth and social security number
- Information about your financial status
- Account balance, assets and transaction history
- A selfie for securing your account
When you are no longer our customer, we continue to retain and share your information as described in this notice below.
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Betterment chooses to share; and whether you can limit this sharing.
How do we use and share your personal information?
Does Betterment share? | Can you limit this sharing? | ||||||||
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Reasons for sharing personal information | |||||||||
For our everyday business purposes
Such as to verify your identity, process your transactions, maintain your account(s), respond to court orders and legal investigations or regulatory requests, or report to credit bureaus |
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For our marketing purposes
To offer our products and services to you. |
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For joint marketing with other financial companies
To offer our products and services to you. |
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For our affiliates’ everyday business purposes - Information about your transactions and experiences
As described below, you are able to limit our sharing of your Betterment Visa Debit Card transaction data with Dosh, our cash back rewards partner, by emailing [email protected]. |
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For our affiliates’ everyday business purposes - Information about your creditworthiness
Betterment does not collect or share personal information for these purposes. |
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For non-affiliates to market to you
Betterment does not collect or share personal information for these purposes. |
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Questions? Contact our customer support team at [email protected] or call (646) 600-8263
Who we are
Who is providing this notice?
- Betterment LLC
- Betterment Securities
- Betterment for Business LLC
- Betterment Financial LLC
What we do
How does Betterment protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These physical and electronic safeguards are described in further detail below and include but are not limited to encrypting data, restricting access to sensitive information solely to employees who need to use that information for a business purpose, and entering into contractual agreements that are intended to protect the confidentiality of any customer information shared with third-parties.
How does Betterment collect my personal information?
We collect your personal information, for example, when you:
- Open an account
- Input your financial information and goals in our platform
- Make a deposit, withdrawal, or transfer
- Use your Betterment Visa® Debit Card
We also collect your personal information from other companies. For example, if you elect to link an external account, holdings, or liabilities (such as a bank account, a non-Betterment brokerage account, or a student loan) to your Betterment account, we also collect personal information from your linked account.
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
- Sharing for affiliates’ everyday business purposes—information about your creditworthiness
- Affiliates from using your information to market to you
- Sharing for nonaffiliates to market to you
You should be aware that Betterment does not collect or share information for these purposes. Betterment also allows you to limit the sharing of information for Betterment's own marketing purposes.
State laws and individual companies may give you additional rights to limit sharing. See below for more information if you are a resident of California or Vermont.
Definitions
Affiliates - Companies related by common ownership or control
They can be financial and nonfinancial companies. Our affiliates are:
- Betterment LLC, a registered investment advisor, is the primary entity with which you interact. Betterment LLC maintains Betterment’s website, provides financial advice and goal recommendations to customers, and markets and advertises to customers and prospective customers.
- Betterment Holdings, Inc. is Betterment’s parent company. Betterment Holdings does not interface with customers.
- MTG LLC ("Betterment Securities") is Betterment’s registered broker-dealer affiliate. Betterment Securities does not directly interface with customers and does not conduct any marketing activities.
- Betterment for Business LLC is Betterment’s unregistered affiliate that offers administrative services to employer-sponsored retirement plans on the Betterment at Work platform. You interface with Betterment for Business if you have a Betterment 401(k) account.
- Betterment Financial LLC is Betterment’s unregistered affiliate that makes available a Betterment Checking Account and Betterment Visa® Debit Card through a partnership with nbkc bank, Member FDIC. You interface with Betterment Financial if you have a Betterment Checking account.
Non-affiliates - Companies not related by common ownership or control
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Non-affiliates we share your personal information with include service providers and vendors, banking partners, other financial institutions, data processors, identity verification services, and advertisers.
Joint marketing
A formal agreement between non-affiliated financial companies that together market financial products or services to you.
- Our joint marketing partners include our banking partner, nbkc bank, and other financial services companies.
Other important information
If you are an account holder of a joint account, you have individual rights with respect to our use of your personal information.
If you would like more specifics about how we use, store and share your information, read on for the rest of our privacy policy.
Full Privacy Policy
Information we collect and why
In order to provide a high-quality service, Betterment collects various types of information when you visit the website or mobile app, sign-up as a customer, or otherwise engage with Betterment.
Visitor information
We collect various types of anonymous information about visitors to Betterment, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Betterment site, browsing activity, and any site that referred you to Betterment). We also collect information that you input into our website, such as your name, phone number, or email address when you begin the account application process or comment on the Betterment blog. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Betterment service. 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.
Customer information
When you choose to create an account with Betterment, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, social security number and information about financial status. We are required by law to collect and store this information to provide you with financial services. If you do not wish to provide this information, you cannot become a Betterment customer.
Betterment conducts identity verification through Socure, which may also require the collection of facial images, such as headshots from your identification card and selfie photographs. Socure also collects information about the device accessing a Betterment account to analyze the risk of fraud. 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 will collect information about the transactions associated with, and the cash flows into and out of, accounts linked through Plaid.
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.
If you open or maintain a Betterment Checking account, you authorize MX Technologies, Inc. ("MX") to collect information about your Betterment Checking account transactions. You acknowledge and agree that the information collected, and the services provided to you, by MX are subject to certain terms and conditions.
If you open or maintain a Betterment Crypto investing account, you authorize Betterment to share certain personal information collected from you, including full legal name, email address, permanent address, date of birth, and social security number, with Gemini Trust Company, LLC (“Gemini”) for the purpose of opening your Crypto investing account with Gemini. You acknowledge and agree that the information collected, shared, and the services provided to you by Gemini are subject to Gemini’s Privacy Policy.
If you receive customer support by telephone from any of Betterment’s business lines, you acknowledge and agree that those support calls may be recorded. If you use Zoom to initiate a screenshare with Betterment’s customer support or human advice teams, you acknowledge and agree that Zoom may collect certain information about your location, as well as the timing and your use of its services, in accordance with Zoom's Privacy Policy.
If you use a Betterment Visa® Debit Card, you acknowledge and agree that Betterment will, on behalf of Dosh Holdings LLC, a subsidiary of Cardlytics, Inc. (“Dosh”), our cash rewards partner, collect certain transaction information about purchases made with your Betterment Visa® Debit Card. The transaction information includes information about your purchases and the vendors with which you transacted, but does not contain personally identifying information such as name, address, date of birth or social security number. Additionally, if you enable the location services feature, Betterment collects information about your location through your phone to provide you with cash back offers in your vicinity. You acknowledge and agree that the collection of information to offer cash back rewards is also subject to the Dosh Terms of Service and Privacy Policy.
Betterment at Work employer and employee information
We collect information from companies, including retirement plan sponsors and plan participants, that use the Betterment at Work platform. When a company creates an account with Betterment as a retirement plan sponsor, we will collect information on both the company and its employees as plan participants, including but not limited to, the company’s name, the company’s employer identification number, details about the company’s existing retirement plans, an email address of the company’s contact person and other relevant plan information. We will also collect certain personal and financial information about the plan participants, including, but not limited to, names, social security numbers, dates of birth, annual incomes, addresses, length of service with the company, gender, marital status, dates of hire, email addresses and other contact information, occupation, industry, personal interests, bank account balance, salary information, contribution rates and tax bracket.
Betterment at Work employers may also offer 529 education savings services through a joint offering between Betterment and Ascensus College Savings Recordkeeping Services, LLC (“Ascensus”). If you open or maintain an integrated 529 account through Betterment, Betterment will share certain personal information collected from you, including your full legal name, phone number, email address, mailing address, date of birth, social security number, and U.S. residency status with Ascensus and with your selected 529 plan for the purpose of opening your 529 account. The services provided by Ascensus and your 529 plan are subject to Ascensus’s Privacy Policy as well as the privacy policy of your 529 plan.
If you initiate a rollover using Capitalize Money, Inc. (“Capitalize”), Capitalize will share with Betterment information necessary to create a user profile for you, including full legal name, phone number, email address, mailing address, date of birth, and social security number. By initiating a rollover, you also authorize Betterment to share certain personal information collected from you, including your IRA account number(s) and user ID, with Capitalize for the purpose of completing your rollover. You acknowledge and agree that the information collected, shared, and the services provided to you by Capitalize are subject to Capitalize’s Privacy Policy.
Advisor information
We collect information from advisory firms that use the Betterment for Advisors platform, as well as from individual advisors, including but not limited to advisory firm and advisor names, email addresses, and other relevant information pertaining to advisors’ businesses. We also collect certain personal and financial information about advisory firm customers, who are Betterment customers, as described above in the “Customer Information” section. Additionally, we collect information from advisors who are considering partnering with Betterment.
Other ways we collect information
Apart from through the account opening process and from visitors to the site, we may collect various other types of personal information if you or a friend engages with Betterment. We collect your email address as part of our customer referral service or if you subscribe to the Betterment blog. We may also collect personal information if you enter it into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). Further, we may collect information regarding your browsing activity when you visit Betterment’s websites and actions you take within your Betterment account while logged in to your Betterment account.
Cookies and pixels
Cookies are small pieces of data that are stored on your computer, mobile phone or any other device used to access the internet. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.
We use these technologies to customize Betterment and improve your experience with the site. Cookies store information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Betterment and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel to track visitors across various websites or devices to better customize our marketing and advertising campaigns. We also offer certain tools from third-party service providers that may use cookies and/or pixels.
Certain cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept non-functional cookies or pixels to use this site. However, refusing to accept these cookies or pixels will make the use of Betterment more cumbersome and less accessible.
You may opt out of the use of cookies and pixels for behavioral advertising through the privacy controls on the Betterment website.
Advertising companies
Betterment advertises our services on websites not affiliated with Betterment, and we contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. We do not provide personally identifiable information to these advertising companies.
Betterment and third-party advertising companies may use the data collected to provide you with ads relevant to you and personalized content while you are on Betterment or other sites. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page. You may also contact these third party companies directly to opt out of targeted advertising from Betterment and/or any other firm. Please note that even if you choose to remove your information by opting out, you will still see advertisements while you are browsing online.
Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies. Because mobile devices may vary in how they operate and may not use cookies, the choice management options listed above may not work for all mobile devices and mobile apps.
Analytics services
We use third-party analytics tools, including Google Analytics (such tools collectively referred to as “Analytics Services”) to collect information about the usage of this site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve this site.
These Analytics Services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
How we use your personal information
Betterment uses your personal information to provide financial advice and other services; enhance your customer experience; improve our products and features; provide customer support; open, operate, and maintain your account in accordance with US law; investigate and understand how Betterment is used; monitor and protect the security and integrity of Betterment; and better market and advertise Betterment’s services. If you link external accounts to your Betterment account, we may use transactional data from those accounts to provide you with financial advice or to recommend additional Betterment products and services to you. You understand and agree that Betterment will compare your identifying information with government-provided lists of suspected terrorists.
As part of this process, we may from time to time include, compile, or aggregate some of your personal information in certain data analyses, reports, or other interpretations of investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it is not identifiable to any particular customer.
Additionally, we, or our service providers, may use your personal information to contact you regarding Betterment's services, resources, or Betterment job openings that we think may be of interest to you. Please note that if you hold an account with Betterment, you cannot opt out of certain communications related to the administration of your account, including communications related to billing, statement and trade confirmation delivery, or certain regulatory matters.
If Betterment is unable to contact you over email because your email address returned an undeliverable message, you understand and agree that Betterment may make alternative attempts to contact you via phone, SMS text, mail, or other communication means.
If you provide your phone number to Betterment, Betterment may contact you by phone regarding opening and/or funding an account. You may request to be put on a "Do Not Call" list maintained by Betterment.
How we share your information
We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.
In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services, public accounting firms and other professional firms, and certain other vendors and service providers who perform marketing, advertising, research and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, e.g., if you ask to transfer assets from Betterment to such financial institutions or if you make student loan repayments using Betterment's student loan management services. If you choose to use Betterment’s charitable giving feature, we will share your name and email address with the recipient charity, which the recipient charity may use to contact you.
We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), frontrunning or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Terms of Service or customer agreements. We also may disclose information about you if necessary to determine your eligibility to recover compensation in connection with class action lawsuits.
Furthermore, we may disclose personal information in specific other cases with your consent.
If you conduct business with us through Betterment for Advisors, we may exchange information we collect with your investment professional or with others they may authorize.
If you open a Betterment Checking account, Betterment will share information with nbkc bank and/or its agents for purposes relating to your account.
If you use a Betterment Visa® Debit Card, Betterment will share the transaction information described above with Dosh, Betterment’s cash rewards partner, and/or its agents for purposes of generating cash back rewards offers for your account. Dosh is prohibited from selling this data. Dosh also may not use this data for any purpose other than providing cash back rewards or another authorized purpose. If you do not wish for this information to be shared, you may disable cash back rewards by emailing [email protected]. Betterment also will share information about your location with Dosh if you allow Betterment to access your location through your phone. If you do not wish this information to be shared, you may choose not to enable location services on your phone.
If you open a Betterment Crypto investing account, Betterment will share information with Gemini and/or its affiliates for purposes relating to your account.
In order to provide workplace services to employers or plan sponsors through the Betterment at Work platform, such as retirement savings plan services, recordkeeping services, and student loan management services, we may exchange any information received in connection with such services with the employer or plan sponsor or others they may authorize, such as an employer-selected investment professional. We may also share information, including but not limited to account positions, contributions, distributions, and cash flows, with a third-party financial institution that serves as a directed trustee to 401(k) plans serviced by Betterment for Business and its affiliates.
If you contact Betterment Support, information you provide may be collected and used by third-party service providers to Betterment or their service providers, which may process that information using generative artificial intelligence technology, including but not limited to large language models. Betterment has received assurances that your personal information will not be used to train any of these models.
How we share your personal information for marketing and research analytics
As disclosed above, we use certain vendors and service providers who perform marketing, advertising, research and analytics services on our behalf.
These include platforms that monitor and provide analytics on our systems, applications that support automated emails for marketing efforts, applications that allow us to build personalized social media campaigns, and tools to record customer communication and interaction history. We use these service providers to comply with regulatory requirements, provide financial services, enhance your customer experience, improve our products and features, and provide customer support. These vendors and service providers with whom we share your personal information are bound by agreements with us to keep your personal information confidential and we never rent or sell your information to anyone.
We use reasonable efforts to limit the sharing of personally identifiable information with vendors and service providers when it is not reasonably required for the service and share anonymized or hashed information in lieu of personal information when it is practicable. Certain experiences on Betterment's website and applications may entail engaging directly with third-party service providers. In such situations, you will be presented with terms and conditions that apply to the use of that service, which may include authorizing such service providers to use anonymized data from your engagement to improve their own products or services. For more information about anonymized information, see details below.
Opt-out information
You may opt out of promotional or marketing emails by clicking “unsubscribe”, which appears in the footer of such emails. If you no longer wish to receive text messages, please type "STOP" in response to any such text. You may also opt out from push notifications from the Betterment application on your iOS or androidOS device. Lastly, you may opt out of the sharing of your Betterment Visa® Debit Card transaction data with Dosh by emailing [email protected].
Note that you cannot opt out of administrative communications, such as emails that contain account statements, notify you regarding changes to your account or contain updates to our terms and conditions.
How to request deletion of the personal information we collect
Betterment allows you to close your Betterment accounts. You can review our help center article on deleting accounts for instructions on how to do so. Closing a joint account works in the same manner, and either joint account holder can delete a shared joint account. Please note that we retain information on deleted accounts as required for legal, regulatory and security purposes.
How your personal information is protected
Betterment works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Betterment to agree to keep your information confidential.
Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Betterment account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.
How you can access or change your personal information that we have collected
Once you have registered with Betterment, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at [email protected]. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years.
Anonymized information
We may share anonymized information that is summarized or derived from information you provide to us with third parties. Anonymous information is information that does not include any personally identifiable information. From time to time, Betterment performs analysis on investing-related topics using anonymized and/or summarized insights from customers. Such research reports, blog posts, or findings may be shared with external publishers or published by us on financial topics of interest.
Other important information
Former customers
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers. We preserve former customer data in order to comply with regulatory obligations.
How we respond to do not track signals
Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Customers using certain modern browsers have the ability to activate a “Do Not Track” signal. Betterment currently responds to the “Do Not Track” signal as required by certain states' laws.
How you accept this policy
By using and continuing to use the Betterment websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms and Conditions take precedence over any conflicting privacy policy provision.
Changes to the policy
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. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. 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. Please check the effective date below to determine if there have been any changes since you have last reviewed the Betterment privacy policy.
Children
Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that their child under the age of 18 has created an account with Betterment and/or provided us with personally identifiable information, please contact us at [email protected]. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate their account.
U.S. State Privacy Notice and California Notice at Collection
Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant their residents certain rights and require additional disclosures (collectively, “State Privacy Laws”). If you are a resident of one of these states, this section applies to you and supplements the information contained in Betterment’s Full Privacy Policy.
As explained in our privacy policy above, both federal and state laws require us to tell you how we collect, use, share, and protect your personal information. As a result, our data collection practices are generally governed by federal law, including the Gramm-Leach-Bliley Act (“GLBA”). However, certain information collected is covered by State Privacy Laws. This may include information related to cross-contextual behavioral advertising or targeted advertising. Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”) of 2020 and other California laws (collectively, the “CCPA”), this may also include information about employees and employee applicants as well as enterprise data (such as business-to-business).
This notice is intended to provide information required under State Privacy Laws, including the CCPA. This notice applies to the data collection and processing practices of Betterment LLC, Betterment Securities, Betterment for Business LLC, and Betterment Financial LLC (collectively, “Betterment” or “we”).
We do not and will not sell consumer personal information in the traditional and colloquial sense of the word “sale.” We do use advertising technology on our website, which under some State Privacy Laws may be considered a “sale” or “share” of your information. We do not exchange our clients’ personal information for monetary payments. As discussed below, you may opt-out of targeted advertising at any time on our website. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data. For more information see below “Right to Opt-Out of Sale/Sharing.”
We disclose the following categories of personal information to third parties for the purpose of engaging in targeted advertising and other marketing activities, including to expand the reach and effectiveness of our marketing campaigns. These disclosures may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Privacy Laws.
Categories of personal information “shared,” “sold,” or used for targeted advertising categories of third parties | Categories of third parties |
Identifiers | Advertising and marketing networks. |
Commercial information | Advertising and marketing networks. |
Internet and electronic network activity information (including information from cookies) | Advertising and marketing networks. |
Your privacy choices and rights
Under the State Privacy Laws, you may have the rights to access, delete, and correct your personal data, to opt out of “sales” or “shares” of your personal data, and to limit the use and disclosure of your sensitive personal information, subject to certain exceptions under federal law, including the Gramm-Leach-Bliley Act (“GLBA”). We may deny your Data Subject Requests to delete if your data is:
- Not protected under CCPA;
- Subject to retention under federal law or regulation;
- Necessary for us or our service providers to:
- Detect security incidents,
- Protect against malicious, deceptive, fraudulent, or illegal activity,
- Assist law enforcement in prosecuting those responsible for such activities, or
- Comply with a legal obligation.
We will make every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the request on your behalf, we require documentation showing that the representative has such authority. You may only make a verifiable Data Subject Request for access or data portability twice within a 12-month period.
Right to delete
Certain personal information that we collect and use to provide you with financial services, and which Betterment is obligated by federal law and/or regulations to retain, cannot be deleted upon request.
Right to correction
Right to know/right to access and data portability rights
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, disclosing, or sharing that personal information.
- The categories of third parties with whom we disclose that personal information.
- The categories of personal information we disclosed or sold to each category of third party.
- The specific pieces of personal information we collected about you.
Right to opt-out of sale/sharing
Right to limit use and disclosure of sensitive personal information
We cannot respond to your Data Subject Request or provide you with personal information if we are unable to verify your identity, or unable to verify the authority for the person making the request as your agent. We will use personal information provided in a verifiable consumer Data Subject Request to verify your identity or authority to make the Data Subject Request, and not for any other purpose.
Response timing and format
We do not charge a fee to process or respond to Data Subject Requests.
Authorized agent
If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
California-specific notices
We are only required to respond to a customer request for this list once during any calendar year. To make such a request, please see above under the section “Exercising Your Privacy Choices and Rights.” Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
The following chart shows details about the Data Subject Requests we received under CCPA from January 1, 2023, to December 31, 2023:
Request type | Received | Fulfilled1 | Denied2 |
Requests to delete | 314 | 51 | 76 |
Requests to know/access and data portability | 2 | 2 | 0 |
Requests to correct | 0 | 0 | 0 |
Requests to opt out of personal information sales or sharing | 5 | 4 | 0 |
Requests to limit use and disclosure of sensitive personal information | 0 | 0 | 0 |
1 Fulfilled means any requests that were fulfilled in whole or fulfilled to the extent allowable under applicable law and regulations, including federal law and regulation.
2 Denials do not include requests that are determined to be inapplicable because they are received from non-California residents and/or request information that is not covered under CCPA.
During the last twelve (12) months, we have collected personal information in the following categories from consumers and disclosed personal information with the following categories of recipients. Although the list contains examples of information collected, we do not collect every specific piece of personal information for every consumer:
Category of personal information | Examples of personal information collected | Categories of recipients |
Identifiers | Name, address, email address, phone number, account identifiers, online identifiers, Social Security number, or other similar identifiers. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
California customer records or similar information in states with applicable privacy laws |
Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, employment, employment history, bank account number, and other financial information. This category may overlap with other categories. |
Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Characteristics of protected classifications under state or federal law | Age, marital status, or gender. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Commercial information | Purchasing or consuming histories or tendencies. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Internet or other similar network activity | Information on your interaction with our website, applications, or advertisements. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Geolocation data | Physical location of logins. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Professional or employment-related information | Current occupation. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Inferences | Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
Sensitive Personal Information | Government-issued identifiers (such as Social Security number and driver’s license), financial account numbers in combination with login credentials, and facial images used for identification. | Our affiliates, service providers, third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you. |
We collect personal information for the business and commercial purposes and uses described in the above section in the Full Privacy Policy.
In addition to the sources described in the section above entitled “Information We Collect and Why,” we collect personal information from the following categories of sources:
- Directly from our clients or their agents,
- Indirectly from our clients or their agents, in the course of the services that we provide,
- Directly and indirectly from activity on our website,
- Other third-party sources, including government sources, data brokers and social networks, and
- From third parties that interact with us in connection with the services we perform.
- The length of time that the data is needed for the purposes for which it was created or collected,
- The length of time the data is needed for other operational or record retention purposes,
- The length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds,
- How the data is stored,
- Whether the data is needed for security purposes and fraud prevention, and
- Whether the data is needed to ensure the continuity of our products and services.
Non-discrimination
- Deny you services.
- Charge you different prices for our services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of service.
Questions
If you have any questions on the privacy policy, please contact us at:
Betterment
27 West 23rd Street, 6th Floor New York, NY 10010
[email protected]
212-228-1328