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 personal 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, offer, and provide the financial products and services that we offer or sponsor.
The personal information we collect about you
The types of personal information we collect and share depend on the product or service you have with us. Examples of personal information we collect may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, accounts at other institutions, and information collected through your use of our website.
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 service providers not affiliated with Vanguard in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. The information we collect about you may be transferred to or stored by Vanguard or our service providers 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 through cookies or 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 use and disclose your personal information
We may use and share your personal information when needed to complete transactions at your request, to provide our services, to make you aware of financial products and services that we offer, to market or advertise our products or services, or where legally compelled to do so. 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, including but not limited to your name and relevant account information.
- 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 contact information and information about your current product and service usage 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 providers to perform services for us. Where necessary and in accordance with legal requirements, we may disclose any personal information we have about you to these service providers. In all such cases, we provide the service providers 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 providers to treat your information with the same high degree of confidentiality that we do.
- In order to market our products and services, we engage non-financial companies to show you relevant advertisements while you browse other websites or use social media. For further information on these activities, please see the section titled Interest-Based Advertising, below. To opt out of our sharing of your personal information with nonaffiliated third parties, please click here.
- Finally, we will release information about prospective, current, or former customers 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).
We engage service providers to collect the information discussed above to engage in analysis, auditing, research, and reporting. These service providers may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our website or our mobile application.
Adobe Analytics. Our website and mobile application use Adobe Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of our online services may be transmitted to and stored by Adobe Analytics on servers outside your country of residence.
We may use service providers’ 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.
Your Opt Out Rights
Opting Out of Interest-Based Advertising. When you access Vanguard’s website, we will provide you with the ability to opt out of third-party data sharing related to Interest-Based Advertising. To opt out, please click here. When you complete this process, you will provide us with your email address. We will send you a validation code to the email address you specify, and once you confirm that validation code electronically, we will remove the email address you specified from third party sharing. If you have more than one email address on file with us, you will need to complete this process for each email address on file to fully opt out. This link also provides further information on how to opt out of certain cookies, as well as the sharing of cookie information related to Interest-Based Advertising. Note that blocking some types of cookies may impact your experience of the site and the services we are able to offer. To learn more, visit the Vanguard Privacy Center.
Do Not Track Signals. Although our website currently does not respond to “do not track” browser settings, 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. To learn more about our online security and privacy features, please visit our Security Center.
Safeguard your account information. For your protection, you should not provide your account information, username, or password to anyone. If you become aware of any suspicious activity relating to your account or if you suspect fraud, please call us at 877-223-6977 or email us at firstname.lastname@example.org.
Review your account information. 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 phone services and website. You may also write or call us with your request for information. Specific website addresses, mailing addresses, and phone numbers are listed on your account statements and other Vanguard correspondence.
Website not for children
Our website and apps are neither intended for, nor targeted to children under 16, and we do not collect personal information directly from children under 16. We receive limited personal information about children from parents and other responsible adults only as required to establish and maintain accounts for the children’s benefit.
Privacy Information for Nevada Residents
Nevada residents may opt out of the sale of covered information to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your personal information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we engage in sales of personal information under Nevada law in the future, please contact us.
We will keep you informed
If you have questions about the way in which we have handled information about you, please do not hesitate to send us an email at email@example.com.
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