Effective date: December 2016
By visiting or using the Sites, clicking "I agree" or any other button indicating your acceptance of this Policy, or otherwise providing information to Vanguard, you consent to the collection, processing, use, and disclosure of information about you as set out in this Policy, including transfers to third parties and other countries. Your use of our Sites or related services, and any dispute over privacy, is subject to this Policy and our Terms and conditions of use, including applicable limitations on damages and the resolution of disputes.
The information that we collect is controlled by The Vanguard Group, Inc., which is headquartered in the United States at 100 Vanguard Boulevard, Malvern, Pennsylvania 19355-2331 and can be reached by mail at P.O. Box 1110, Valley Forge, PA 19482-1110. This information also may be collected by or transferred to, and therefore controlled by, the Vanguard Affiliate located in your country of residence or with which you are dealing directly. As discussed below in the section titled Cross-border transfer of information, information that we collect through or in connection with the Sites may be transferred to and processed in the United States or another jurisdiction outside your country of residence, which may have less stringent data protection laws than in your country of residence.
Vanguard may collect, process, use, and disclose both Personal Information and Other Information in connection with your use of the Sites. For purposes of this Policy, "Personal Information" is any information that alone or together with other information in Vanguard's possession relates to an identified or identifiable person, such as name, phone number, email address, financial account information, and online account information such as user name and password. "Other Information" is any additional information that is not Personal Information. In this section, we describe our information-collection practices, including the types of Personal and Other Information that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Information.
We may combine the Personal and Other Information collected on the Sites with information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you; from publicly available sources, such as your company website if you are a financial adviser; from the registrar for our exchange-traded funds so that we can provide information about products or services that may be of benefit; or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined information in accordance with this Policy. If you do not wish to provide information to Vanguard, we may be unable to provide certain services to you.
What Personal Information do we collect?
Vanguard may collect the following Personal Information from or about you:
Personal Information we collect directly from you online, such as when you register to use the Sites or request information from us: Vanguard may collect and maintain Personal Information about you, and about any person or entity on whose behalf you are acting, that you provide to us on the Sites, such as when you register to use the Sites, obtain a product or service from Vanguard, request information or materials from us, or otherwise interact with our Sites. The types of Personal Information we collect vary based on your particular interaction with us, but could include:
- Your name, company name, and primary role or title;
- Postal mailing address;
- Telephone and fax numbers;
- Email address;
- Account number and other account information;
- User name, password, PIN, and answers to security questions; and
- Other information you provide to us directly online, such as information collected for identification or authentication purposes.
Personal Information for your account: Depending on the type of account, and to the extent permitted by law, we may collect the following Personal Information from you or about you when you open an investment account, establish a business relationship with Vanguard on behalf of yourself or another individual or entity, or manage your account on the Sites:
- Full name, date of birth, gender, and contact details, including mailing address, email address, and telephone and fax numbers;
- Tax identification number and bank account and payment method details, if such information is needed for the purpose of administering your accounts;
- Employment details, which may include annual salary;
- Contribution amounts and investment choices;
- Details about authorised signatories, agents, or representatives;
- Copies of any relevant trust deeds, partnership agreements, constitutions, or articles of association;
- Details of services you are interested in and about your investment needs;
- Information about employees, agents, or other representatives of a client or prospective client, if such information is needed to open or maintain an account; and
- Other information that you provide to us in connection with your account.
We also may collect Personal Information for your account from third parties authorised to disclose your Personal Information, such as from your employer or from companies that provide identification verification services.
Information about third parties: We may collect information from you regarding other individuals related to your account. By disclosing information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you have the consent of those parties to such collection, use, and disclosure of their information as described in this Policy.
Information from telephone, email, online chat, or text message communications with Vanguard: If you communicate with Vanguard by telephone, email, online chat, or text message, Vanguard may keep a record of that communication. In accordance with applicable law, Vanguard also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.
Information contained in surveys: Vanguard may ask you to complete surveys for research and client satisfaction assessment or similar client service-related purposes. You are not required to respond to those surveys, and any information collected by Vanguard or on Vanguard's behalf that you provide in response to those surveys is at your discretion.
What Other Information do we collect automatically?
- Cookies: A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website. Cookies contain information that is transferred to or read on your device and allow websites to recognise devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Sites. This helps us to provide you with a useful experience when you browse our Sites and also allows us to improve our Sites. We and our third-party service providers use session cookies, which link your actions during a particular browser session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.
- Web beacons: The Sites or the emails that you receive from Vanguard may use an application known as a "web beacon" (also known as a "pixel tag" or "clear gif"). A web beacon is an electronic file that usually consists of a single-pixel image. We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click on any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Vanguard relationships.
We may combine Other Information with additional information that we have collected about you, including, where applicable, your name and other Personal Information. When we combine Other Information with Personal Information, we treat all of the combined information as Personal Information. If you have registered for secure access on our Sites, we are able to combine the information we collect about your usage of our Sites during a secure (logged-on) session with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our Sites, even if you do not log on, and link information about that visit, as well as about Vanguard ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Sites and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see the section below titled Third-party analytics and Interest-Based Advertising.
Use and disclosure
How do we use Personal and Other Information?
We use the Personal and Other Information that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:
- To establish and administer accounts and your relationship with us, to fulfil the terms of any agreement you have with us, and to otherwise provide Vanguard's products and services to you;
- To communicate with you, notify you about important updates or changes to Vanguard's products and services, and address relevant inquiries or complaints;
- For marketing and promotional purposes, consistent with applicable law. For example, we may use your Personal Information, such as your email address, to send you news and newsletters, or to otherwise contact you about products or information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication;
- To tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled Third-party analytics and Interest-Based Advertising, to offer location customisation and personalised help and instructions, and to otherwise personalise your experiences while using the Sites;
- To comply with our legal obligations and protect our legal rights, including, without limitation, to comply with record-keeping, reporting, and tax obligations under applicable law (such as corporations, tax, managed investments or securities, and anti-money laundering laws);
- To count and recognise visitors to the Sites and various Site features and better understand how users access and use our Sites and Vanguard products and services;
- To create new products and services or improve our existing products and services;
- To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
- For other research and analytical purposes.
To whom do we disclose Personal and Other Information?
We may disclose Personal and Other Information to third parties for the following purposes, as permitted by law:
Affiliates: We may disclose Personal and Other Information to Vanguard Affiliates for the purposes described in this Policy. Vanguard Affiliates may contact you by email, where permitted by law, to make you aware of Vanguard's product and service offerings.
Service providers: We may disclose Personal and Other Information to our service providers, who use it to perform tasks on Vanguard's behalf. Among other things, these service providers help us manage and improve the Sites, provide Vanguard services, mail disclosures and statements to you, and administer your accounts. Our service providers may collect, process, and retain information about you, in accordance with the laws of your country, directly on behalf of Vanguard. Vanguard's service providers include:
- Any organisation involved in providing, managing, or administering the Sites, related systems, or other Vanguard services, such as administrators, mail houses, email senders and providers, technology service providers, and third parties that provide analytics and advertising services as described in the section below titled Third-party analytics and Interest-Based Advertising; and
- Vanguard's auditors, consultants, legal advisers, and other professional advisers.
Customer agents: We may disclose Personal Information to your agents or representatives, including:
- Your financial adviser;
- Any administrator or trustee for a fund or trust to which your investment balance is to be transferred or rolled over;
- Your legal representative or attorney; and
- Other financial institutions that hold an account in your name or on which you are authorised to act, for example, where amounts have been transferred to or from that account.
Legal purposes: We may use and disclose information about you as we believe reasonably necessary to protect the rights and property of Vanguard and Vanguard Affiliates, including to establish legal claims or defences, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of Vanguard Affiliates, to protect against fraud and abuse, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or subpoena. We may disclose information to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorised to act.
Sale or other transfer of the company: We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitisation, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, as permitted by applicable law. By agreeing to the terms of this Policy, you are consenting to this disclosure.
Market research: We also may provide information to market research companies or Vanguard Affiliates for the purpose of assessing information about our business or client base. We may provide our clients' or prospective clients' contact details to market research companies to undertake research on behalf of Vanguard. For example, we may run client satisfaction surveys or run focus groups on proposed products.
Direct sharing through third-party websites and services: The Sites may enable you to share information directly with websites or online services operated by third parties. For example, the Sites contain features that allow you to share articles or content through Facebook, Google Plus, Twitter, LinkedIn, and other services. If you choose to use these features, you may disclose information to users of those websites or services and the public more generally. Because these third-party websites and services are not operated by Vanguard, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Policy.
Competitions, contests, and promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Vanguard Sites or elsewhere, and if you choose to participate, we or third parties may request your name, address, telephone number, email address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations. In compliance with the relevant regulations, it may also be necessary to publish details of the winners of competitions in appropriate news media.
Aggregated information: From time to time, Vanguard may share aggregated information about users of the Sites or Vanguard's products and services, such as sharing reports on the usage of the Sites or Vanguard's services for regulatory reporting or marketing purposes.
Third-party analytics and Interest-Based Advertising
For more information about Interest-Based Advertising and how to opt out, please visit:
- Network Advertising Initiative (NAI) opt-out page, available at www.networkadvertising.org/choices;
- Digital Advertising Alliance (DAA) opt-out page, available at www.aboutads.info/choices;
- Digital Advertising Alliance of Canada (DAAC) opt-out page, available at http://youradchoices.ca/choices/;
- European Interactive Digital Advertising Alliance (EDAA) opt-out page (available in 27 languages), available at http://www.youronlinechoices.eu/; and
- Australian Digital Advertising Alliance (ADAA) opt-out page, available at http://www.youronlinechoices.com.au/opt-out/.
Although our Sites currently do not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies, and not this Policy.
Cross-border transfer of information
Vanguard generally maintains centralised servers and systems in the United States and may maintain servers and systems elsewhere. These servers and systems are managed by or on behalf of The Vanguard Group, Inc., or Vanguard Affiliates located in or outside the United States. Vanguard also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, the Personal and Other Information that we collect through or in connection with the Sites is transferred to and processed in the United States for the purposes described above, pursuant to methods permitted by the laws of your country of residence for ensuring that information about you will be adequately protected. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this Policy, using the Sites, or by providing any Personal or Other Information to us, you expressly consent to such transfer and processing.
Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Information collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by Vanguard, you should contact us at the address provided in the Contact us section below.
Information security and retention
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Information from loss, misuse, and unauthorised access, disclosure, alteration, and destruction in accordance with applicable law. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorised access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user name and password private.
Vanguard retains Personal Information for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.
Choices, access, and correction of information
We provide you with the ability to access, review, correct, delete, or inquire about information that we hold about you, as required and permitted under applicable law. You also may have a right to oppose or limit the collection and processing of your information as described in this Policy, or to revoke your consent, although we may be unable to provide services to you if you oppose this processing or if you revoke consent.
If you would like to access, review, correct, delete, or inquire about your information, place limitations on the collection or processing of your information, or revoke your consent, please send us a request at the address or email provided in the Contact us section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete. Please note that we may need to take additional steps, such as to verify your identity, before we can grant your request. As permitted by law, we will notify you of the basis for any denial of your request.
If you would like Vanguard to stop sending promotional communications to your email address, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication.
You may opt out of the use of your information for analytics and online interest-based advertising by following the steps detailed above in the section titled Third-party analytics and Interest-Based Advertising.
The Sites are not directed to children under the age of 18, and Vanguard does not collect information from anyone it knows is under the age of 18. We recommend that persons under 18 years of age ask their parents for permission before using the Sites or sending any information about themselves to anyone over the internet.
If you have any questions relating to this Policy, or concerns about the way in which we have handled information about you, please do not hesitate to send us an email at firstname.lastname@example.org. You also may contact us by sending a message to:
Vanguard Asset Management, Limited
Attn: Data Protection Officer
London, GB EC4N 8AF
Vanguard Investments Switzerland GmbH
Attn: Data Protection Officer
CH 8002 Zurich
Vanguard Investments Hong Kong Limited
Attn: Data Protection Officer
48/F, The Center
99 Queen's Road Central, Hong Kong
Vanguard Investments Japan, Ltd.
Attn: Data Protection Officer
21F Sanno Park Tower
Tokyo, Japan 100-6162
Vanguard Investments Singapore Pte Ltd.
Attn: Compliance Officer
3 Phillip Street
#07 01 Royal Group Building
Singapore, SG 048693
Vanguard Investments Australia, Ltd.
Attn: Client Services
2 Southbank Boulevard
Southbank Vic AU 3001
1300 655 101
Vanguard Investments Canada Inc.
Attn: Compliance Officer
22 Adelaide Street West
Toronto, ON M5H 4E3
(outside US and Canada):
Vanguard International Department, J19
Attn: Enterprise Data Governance & Privacy
400 Devon Park Drive
Wayne, PA 19087
The Vanguard Group, Inc.
Attn: Enterprise Data Governance & Privacy
P.O. Box 2600
Valley Forge, PA 19482-2600
If you raise any concerns about how we have handled your Personal Information, we may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and resolve your issue. We will keep records of your request and any resolution of your issue.
We will post changes to this Policy on our Sites along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, you will be provided with appropriate notice.