Common use of Nondisclosure of Material, Nonpublic Information Clause in Contracts

Nondisclosure of Material, Nonpublic Information. In connection with the Services that it provides, Betterment Securities may, from time to time, come into possession of confidential and material, nonpublic information. Betterment Securities is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a customer of Betterment Securities. Betterment Securities maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know the information and to assure that it is meeting its obligations to customers and remains in compliance with applicable law. Client understands and agrees that these policies and procedures are necessary and appropriate and recognize that, in certain circumstances, Betterment Securities will have knowledge of certain confidential or material, nonpublic information which, if disclosed, might affect Client’s decision to buy, sell, or hold a security, but that Betterment Securities will be prohibited from communicating such information to Client or using it for Client’s benefit.

Nondisclosure of Material, Nonpublic Information. In connection with the Services that it provides, Betterment Securities may, from time to time, come into possession of confidential and material, nonpublic information. Betterment Securities is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a customer of Betterment Securities. Betterment Securities maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know the information and to assure that it is meeting its obligations to customers and remains in compliance with applicable law. Client understands and agrees that these policies and procedures are necessary and appropriate to comply with applicable law and recognize that, in certain circumstances, Betterment Securities will have knowledge of certain confidential or material, nonpublic information which, if disclosed, might affect Client’s decision to buy, sell, or hold a security, but that Betterment Securities will be prohibited from communicating such information to Client or using it for Client’s benefit.