California Privacy Notice

This notice for California residents supplements the information contained in Betterment’s Privacy Policy and applies solely to consumers who reside in the State of California. This notice is intended to provide information required under the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. Any terms defined in the CCPA or its implementing regulations have the same meaning when used in this notice. 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. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.

Information We Collect

There are eleven categories of personal information described in the CCPA. During the last twelve (12) months, we have collected personal information in the following categories from consumers, although the list contains examples of information collected, and we do not collect every specific piece of personal information for every consumer:

• Identifiers: Name, address, email address, phone number, account identifiers, online identifiers, Social Security number, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): 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.
• Protected classification characteristics under California or federal law: Age, marital status, or gender.
• Commercial information: Purchasing or consuming histories or tendencies.
• Internet or other similar network activity: Information on a consumer’s interaction with our website, applications, or advertisements.
• Geolocation data: Physical location of logins.
• Professional or employment-related information: Current occupation.

We collect personal information:

• 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, and
• From third-parties that interact with us in connection with the services we perform.

What is not included in the definition of personal information?

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide you with the products and services that you request from us, including financial advice and other financial services.
• To provide you with emails or other communications concerning our products and services, including customer support.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To enhance your customer experience.
• To improve our products and services.
• To investigate and understand how our services are used, including through testing, research, analysis, and product development.
• To contact you to market our own products, services, resources, or any Betterment job openings that we think might be of interest to you.
• To maintain your account in accordance with applicable U.S. federal and state law.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To monitor and protect the security and integrity of Betterment.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different or unrelated purposes without notifying you.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we seek to require the third-party recipient 1) not to disclose the information, except as permitted by you, 2) not to sell the information, and 3) not use the information for any purpose except the purposes described in our agreement with the third-party recipient.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties:

• Identifiers.
• California Customer Records personal information categories.
• Protected classification characteristics under California or federal law.
• Internet or other similar network activity
• Professional or employment-related information.

We may disclose your personal information for a business purpose to the following categories of third parties:

• 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.

In the preceding twelve (12) months, we have not sold any personal information. Betterment does not sell, rent, or trade consumers’ personal information.

Your Rights as a California Resident

The CCPA provides California residents with specific rights regarding their personal information. This section describes consumers rights under the CCPA rights and explains how you can exercise those rights with Betterment.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (a “Request”). Once we confirm your Request, we will disclose to you, upon specific request:

• 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 that personal information.
• The categories of third parties with whom we share that personal information.
• The categories of personal information about you that we shared for a business purpose.
• The specific pieces of personal information we collected about you.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your Request, we will delete (and direct our service providers to delete) your personal information from our (and their) records, unless an exception applies.

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.

We also may deny your deletion request if retaining the information is 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.

Exercising Access, Data Portability, and Deletion Rights

To exercise your rights described above, please submit a Request to us by:

• Email, at ccpa@betterment.com
• By phone, at (833) 740-0099

Only you or an agent registered with the California Secretary of State who is authorized to act on your behalf may make a Request.

You may only make two Requests within a 12-month period. Each Request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 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.
• Describe your Request with sufficient detail that allows us to properly evaluate and respond to it.

We will not respond to your Request or provide you with personal information if we are unable to verify your identity, or to verify the authority for the person making the request as your agent. We will use personal information provided in a verifiable consumer Request to verify your identity or authority to make the Request, and not for any other purpose.

Response Timing and Format

We will acknowledge your Request within 10 days. We attempt to respond to every Request within 45 days. If we require more time, we will inform you of the reason and how much additional time we require (up to 90 days in total). Any disclosures we provide may only cover the 12-month period preceding the Request’s receipt. If we are unable to satisfy your Request, or a part of your Request, we will explain why.

We do not charge a fee to process or respond to Requests.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• 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.

Changes to Our California Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or by updating this notice on our brochure page.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us.

By email: ccpa@betterment.com

By phone; +1 (833) 740-0099