Our commitment to you
As a Vanguard investor, you have entrusted to our care not only your hard-earned money but your personal and financial data 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. Because your personal and financial data are your private information, we hold ourselves to the highest standards in their safekeeping and use.
This means, most importantly, that we do not sell client or prospective client information—whether it is your personal information or the fact that you are or may become a Vanguard client—to anyone.
Instead, we use your information primarily to complete transactions that you request or to make you aware of other 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 application, we may store the information even if you don’t complete or submit the application.) You also provide personal information when you request literature or a transaction that involves Vanguard or one of the Vanguard-affiliated companies.
In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may benefit 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 providers in the United States or elsewhere, as permitted by law.
How we handle your personal information
We do not sell information about current or former clients or their accounts to third parties. Nor do we share personal information about clients or prospective clients, except when needed to complete transactions at your request or to make you aware of related 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 company 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, or the brokerage services offered through Vanguard’s brokerage companies, or the asset management and trust services offered through Vanguard’s trust companies and registered investment advisors inside Vanguard.
- In certain instances, we may contract with nonaffiliated companies to perform services for us. Where necessary, we will disclose information we have about you to these third parties. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities, and only for that purpose. And we require these third parties to treat your private information with the same high degree of confidentiality that we do.
- Finally, we will release information about you if you direct us to do so, if we are compelled by law 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 shareholders naturally extends to those who use our Personal Investors website, vanguard.com.
- Our website uses some of the most secure forms of online communication available, including data encryption, Secure Sockets Layer (SSL) protocol, 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.
- Our website uses a variety of technologies to collect information that helps us understand how our site is used. A cookie is a small file of letters and numbers that is stored on the hard drive of your computer. Cookies may expire at the end of a web session or persist in order to store your settings and preferences. A web beacon, also known as a pixel tag, is a tiny transparent image embedded in a web page or an e-mail to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your computer.
- When you register for access to vanguard.com, we ask you to authorize Vanguard’s storage of an Adobe Flash Shared Object in order to authenticate your computer. The information in this object, also called a Flash cookie, is available only to Vanguard and its service providers, and you may change your local storage settings at any time through Adobe Flash Player.
- When you visit our website, we may collect, either directly or through third-party service providers, certain technical and navigational information, such as computer browser type, internet protocol (IP) address, pages visited, date and time of your visit, and average time spent on our website. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We also analyze this information, with the assistance of our service providers, to improve our web 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.
- We and our service providers may use web beacons to determine whether and when you receive and open our e-mails; these beacons may also capture information about the type of device, operating system, e-mail program, and web browser used to view the e-mail and whether you click on any links in the e-mail. This enables us to gauge the effectiveness, relevance, and value of our e-mail communications.
- If you are a Vanguard investor who has registered for secure access to your accounts on vanguard.com, we are able to combine the information we collect about your usage of our website during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your web session. We can also identify your computer or device on each visit to our website, even if you don’t log on, and link information about that visit to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our website, as well as to identify Vanguard products and services that may be of interest to you.
- Vanguard uses the Evidon assurance service to comply with the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance. As part of this service, Vanguard’s advertisements on other websites are sometimes delivered with icons that help consumers understand how their data are being used and provide choices for consumers that want more control. For information about online behavioral advertising and your choices, you may visit aboutads.info.
See our Site Help and Technical Help for more details about our online security and privacy features.
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.
What you can do
For your protection, we strongly recommend that you do 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.
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