Our commitment to you
As a Vanguard investor or prospective investor, you may entrust to our care not only your money but your personal and financial information as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. When we share client or prospective client information—whether it is your personal information or the fact that you are or may become a Vanguard client—we do so under the circumstances described in this policy.
We use your information primarily to respond to your inquiries or requests; to maintain and protect your accounts; to process transactions that you submit; to fulfill our legal obligations; for research and analytical purposes; and to develop and provide the financial products and services that we offer or sponsor.
The personal information we collect about you
You provide personal information when you complete a Vanguard account application. (If you enter information in an online account application, we may store the information even if you don't complete or submit the application.) You also provide personal information when you request information or materials from us or otherwise interact with Vanguard, as well as when you transact in your accounts.
In addition to personal information you provide to us, we may receive information about you that you authorize other parties to provide to us. We also may obtain personal information from third-party service suppliers not affiliated with Vanguard (service suppliers) in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. Personal information collected from any source may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions. The information we collect about you may be transferred to or stored by Vanguard or our service suppliers in the United States or elsewhere, as permitted by law.
We may combine the information collected on our website or through our mobile application with information collected from or about you in other contexts. This may include information collected online, such as on our website or through our email exchanges with you, or from offline sources, such as 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 products or services to you.
How we handle your personal information
We do not share personally identifying information about our investors or prospective investors with unaffiliated third parties for use in marketing their own products and services. We may share your personal information when needed to complete transactions at your request or to make you aware of financial products and services that we offer. Here are the details:
- In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Vanguard. For example, if you ask to transfer assets from another financial institution to Vanguard, we will need to provide certain information about you to that institution to complete the transaction.
- In order to alert you to other financial products and services that Vanguard offers or sponsors, we may share your information within the Vanguard family of affiliated companies, to the extent permitted by law. This would include, for example, sharing your information within Vanguard to make you aware of new Vanguard funds or other investment offerings, advice services, brokerage services, or asset management and trust services.
- In certain instances, we contract with service suppliers to perform services for us. Where necessary, we will disclose personally identifying information we have about you to these service suppliers. In all such cases, we provide the service supplier with information about you only as necessary to carry out its responsibilities as provided in its agreement with us, and only for that purpose. And we require these service suppliers to treat your information with the same high degree of confidentiality that we do.
- Finally, we will release information about you if you direct or authorize us to do so, if we are compelled by law or legal process to do so, or in other legally limited circumstances (for example, to prevent fraud).
Cookies, web beacons, and online privacy
Our concern for the privacy of our investors and prospective investors naturally extends to those who use our personal investors website, investor.vanguard.com, and our Vanguard investors mobile application.
Our website and our mobile application use some of the most secure forms of online communication available, including data encryption, transmission encryption, user names and passwords, adaptive authentication techniques, and back-end fraud and account monitoring. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
We use a variety of online technologies, as described further below, to collect information that helps us understand how our website and our mobile application are used. Specifically, when you visit Vanguard online, we or our service suppliers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you click; searches you conduct; the internet protocol (IP) address used to access our website or mobile application; your general geographic location (e.g., your city, state, or zip code); and the website visited before our site. We also may use similar tracking technologies in emails that we or our service suppliers send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues, to resolve technical or service problems, and for security purposes. We also analyze this information, with the assistance of our service suppliers, to improve our website and mobile application design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.
A cookie is a small file of letters and numbers that is stored on your computer or other device when you visit a website or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our online services. This helps us to provide you with a useful experience when you browse and also allows us to improve our online services. We and our service suppliers use session cookies, which link your actions during a particular online 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.
Our website, our mobile application, and the emails that you receive from Vanguard 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, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.
We and our service suppliers 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 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.
If you are a Vanguard investor who has registered for secure online access to your Vanguard accounts, we are able to combine the information we collect about your usage of our website or mobile application during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to Vanguard, even if you do not log on, and link information about that visit, as well as 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 website and in our mobile application and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to you.
We may use service suppliers technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your interactions with our online services and online advertising through different devices may be combined. By making these connections, we may be able to better understand the relevance of our content and the impact of our advertising and to customize that content and advertising for you.
Vanguard complies with the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA). As part of this service, Vanguard's targeted advertisements on other websites are delivered with icons that help consumers understand how their information is being used and provide choices for consumers who want more control. For information about Interest-Based Advertising and how to opt out, please visit the DAA consumer choice page, available at http://optout.aboutads.info/. Opting out of Interest-Based Advertising means that you will no longer receive ads targeted to you by the companies listed on the consumer choice page, but you may still receive targeted ads from other companies or based on the particular website or page that you are viewing. Also, if your browser is set to reject cookies when you visit the YourAdChoices opt-out page, or if you subsequently clear your browser cookies, your opt-out may not be or remain effective.
Although our website currently does not respond to “do not track” browser headers, you can limit tracking by taking the opt-out steps discussed above.
How we safeguard your personal information
Within Vanguard, we restrict access to information about you to those Vanguard employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology. You can visit our Security Center to read more details about our online security and privacy features.
What you can do
For your protection, you should not provide your account information, user name, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately.
Vanguard offers a variety of options for accessing and reviewing your account information. You can review your information on your statements and other account documents, as well as through our automated telephone services and website. You may also write or call us with your request for information. Specific website addresses, mailing addresses, and telephone numbers are listed on your account statements and other Vanguard correspondence.
We will keep you informed
©2019 The Vanguard Group, Inc. All rights reserved