The following privacy policy is provided by the Vanguard funds, The Vanguard Group, Inc., Vanguard Marketing Corporation, Vanguard Advisers, Inc., Vanguard Fiduciary Trust Company, and Vanguard National Trust Company.
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 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 parties in order to verify your identity, to prevent fraud, or to help us identify products and services that may benefit you. We and our e-mail service providers may determine whether you receive and open our e-mails by using pixel tags, also known as web beacons, which are tiny transparent graphic images embedded in a web page or e-mail to measure usage and activity. This enables us to gauge the effectiveness of our e-mail communications.
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 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 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 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).
How we protect privacy online
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, and user names and passwords. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
- Vanguard.com offers customized features that require our use of "cookies" and similar data files—tiny pieces of information that we ask your browser to store. Certain sections of our site require cookies to be enabled to enhance website performance. For example, cookies enable us to personalize and improve your user experience and help enhance site navigation. Cookies also help us to understand how people use our site so that we can improve site structure and functionality. However, we make very limited use of these cookies and data files. We don’t use them to pull data from your hard drive or to view data in cookies or other similar data files created by other websites. We will not share the information in these data files or give others access to it—except to help us better serve your investment needs and in accordance with this privacy policy.
- 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 address, pages visited, 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, or it may be analyzed to improve our web design and functionality and our ability to serve you and your accounts.
- In certain cases, we may use third-party service providers to place advertisements for us on other websites, and to help us measure brand awareness and the effectiveness of our online advertising. These service providers may use cookies and pixel tags to collect limited technical, web navigation, and other information, such as the advertisement presented, your IP address, operating system and browser type, the web page from which you linked to our site (if any), and pages visited or generated on our site. We and our service providers may use data collected on this site to serve ads to you on other sites as you browse the web. We do not provide any personally identifiable information about our users or clients to these service providers, and they do not collect such information for us. All information collected on our website is used exclusively by Vanguard, or by our service providers on our behalf, and is not shared with unaffiliated third parties.
- 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 http://www.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 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.
We'll keep you informed
As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time, but rest assured that if we do change it, we will tell you promptly.
Revised 09/2012.
