Vanguard Asset Management, Limited, and its affiliated companies ("Vanguard", "we", or "us") value the privacy and security of information about Vanguard's clients and potential investors. Vanguard may collect and retain certain information in order to provide a variety of financial products and services to our customers, including investment management and financial advice. In this privacy policy ("Policy"), we describe how Vanguard collects, uses, and discloses information collected by Vanguard on this website (the "Site").
The information that we collect is controlled by Vanguard Asset Management (UK) Limited, 25 Walbrook, London, GB EC4N 8AF, which is an affiliate of The Vanguard Group, Inc., headquartered in the United States at 100 Vanguard Boulevard, Malvern, Pennsylvania 19355-2331 and reachable by mail at P.O. Box 2600, Valley Forge, PA 19482-2600. As discussed below in the section titled Cross-border transfer of information, information that we collect 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 collects and processes both Personal Data and Other Data. For purposes of this Policy, "Personal Data" is any information that alone or together with other information in Vanguard's possession relates to an identified or identifiable natural person, such as name, phone number, email address, financial account information, and online identifiers and account information such as user name and password. "Other Data" is any additional information that is not Personal Data. In this section, we describe our information-collection practices, including the types of Personal and Other Data that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Data.
We may combine the Personal and Other Data we collect directly from you with information collected from or about you in other contexts, such as on the Site. 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 products or services to you.
Vanguard may collect the following Personal Data from or about you:
Personal Data we collect directly from you, such as when you request information from us, invest with us, or register to use the Site: Vanguard collects and maintains Personal Data about you, and about any person or entity on whose behalf you are acting, that you provide to us, such as when you obtain a product or service from Vanguard, request information or materials from us, register to use the Site, or otherwise interact with us or our Site. The types of Personal Data we collect vary based on your particular interaction with us, but could include:
Personal Data for your account: Depending on the type of account, and to the extent permitted by law, we may collect the following Personal Data from 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:
We also may collect Personal Data for your account from third parties authorised to disclose your Personal Data, 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. Where you disclose information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you will only do so in accordance with applicable data protection laws; that you will ensure that before doing so, the individuals in question are provided with a copy of this Policy and made aware of the fact that Vanguard will hold information relating to them and may use it for any of the purposes set out in this Policy; and where necessary that you will obtain the other individuals’ consent to Vanguard’s collection, use, and disclosure of their information as described in this Policy. Vanguard may, where required under applicable law, notify those individuals that they have been provided with their Personal Data and provide a copy of this Policy to them.
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 (after according prior announcement and, if required, your consent each via phone) 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.
Where you have consented, we may collect data about you on our Site and through emails that we send to you, including whether you click on links in our emails. We use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further in our cookie policy.
We may combine Other Data with additional information that we have collected about you, including, where applicable, your name and other Personal Data. When we combine Other Data with Personal Data, we treat all of the combined information as Personal Data. If you have registered for secure access on our Site, we are able to combine the information we collect about your usage of our Site 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 Site, even if you do not log on, and determine whether you came to our Site by clicking on an email link. This enables us to link information about your Site visits, 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 Site and the effectiveness of our email communications and 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 please see the section in our cookie policy titled: What cookies do we use and why?
How do we use Personal and Other Data?
We use the Personal and Other Data 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:
Legal bases for using Personal Data
We will only collect, use, and share your Personal Data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
If you would like to find out more about the legal bases on which we process Personal Data, please contact us using the details below.
To whom do we disclose Personal and Other Data?
We may disclose Personal and Other Data to third parties for the following purposes, as permitted by law. You have certain rights to object to the processing of your Personal Data as described below:
Affiliates: We disclose Personal and Other Data to Vanguard Affiliates for the purposes described in this Policy. Vanguard Affiliates may contact you by email, to make you aware of Vanguard's product and service offerings (each provided you consented to the reception of such emails or, if you did not object to such emails, you previously acquired products or services from us indicating your interest to receive them as well).
Service providers: We may disclose Personal and Other Data to our service providers, who use it to perform tasks on Vanguard's behalf. Among other things, these service providers help us provide Vanguard products and services, send disclosures and statements to you, administer your accounts, and manage and improve the Site. 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:
Customer agents: Where covered by a legal basis for such processing, we may disclose Personal Data to your agents or representatives, including:
Legal purposes: We may use and disclose your Personal Data as far as this is 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 Site, 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, in accordance with applicable law.
Market research: We 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, in accordance with applicable law. For example, we may run client satisfaction surveys or run focus groups on proposed products. Any Personal Data processed for market research is deleted as soon as it is no longer required, i.e. upon termination of the market research study/studies for which such data was collected or, if earlier, you objected to the processing of your Personal Data for such purpose.
Direct sharing through third-party websites and services: The Site may enable you to share information directly with websites or online services operated by third parties. For example, the Site contains features that allow you to share articles or content through Facebook, Google Plus, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and to the public more generally. These websites and services may also set and/or access a cookie on your device.
Competitions, contests, and promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Site 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 Site or Vanguard's products and services, such as sharing reports on the usage of the Site or Vanguard's services for regulatory reporting or marketing purposes.
Vanguard generally maintains servers and systems in Europe as well as in the United States. 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 information to, or otherwise share your information with, other third parties in the United States or countries other than your country of residence, including to Vanguard Affiliates for the following purposes: staff administration; management of employment relationship; recruitment; management of commercial relationship with business partners and customers; advertising, marketing and public relations; accounts and records; research and compliance with financial regulations. Such transfers occur only when we are satisfied that we have an appropriate legal basis to do so, meaning that our transfer and use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you; our transfer and use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have; you have provided your consent to our using the Personal Data; and/or our transfer and use of your Personal Data is in our legitimate interest as a commercial organisation Vanguard will only transfer personal information outside the European Economic Area (EEA) where it is necessary and proportionate to do so and in limited circumstances. Where the Personal and Other Data that we collect is transferred to and processed in the United States or anywhere else outside the EEA for the purposes described above, we will take steps to ensure that the information receives the equivalent level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses (controller to controller and controller to processor). You may have a right to details of the mechanisms under which your data may be transferred outside the EEA.
Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Data 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.
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Data 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 username and password private.
The Site may contain links to sites operated by partner networks, advertisers, and other companies not affiliated with Vanguard. Vanguard does not sponsor or endorse the linked sites, or any products or services offered by them. If you follow a link to any of these sites, you’ll be subject to the site’s privacy policy, which you should read and understand before using the site or its products or services.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers for legal and regulatory purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Data:
Right to access Personal Data
You have a right to request that we provide you with a copy of your Personal Data that we hold, and you have the right to be informed of:
Right to rectify or erase Personal Data
You have a right to request that we rectify inaccurate Personal Data. We may seek to verify the accuracy of the Personal Data before rectifying it.
You can also request that we erase your Personal Data in limited circumstances where:
We are not required to comply with your request to erase Personal Data if the processing of your Personal Data is necessary:
Right to restrict the processing of your Personal Data
You can ask us to restrict your Personal Data, but only where:
We can continue to use your Personal Data following a request for restriction:
Right to transfer your Personal Data
You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
Right to object to the processing of your Personal Data
You can object to any processing of your Personal Data which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your Personal Data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your Personal Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
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 website analytics and online interest-based advertising by following the respective steps detailed above in the section titled Website analytics and Interest-Based Advertising.
Right to obtain a copy of Personal Data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with the data protection authority
Vanguard’s primary supervisory authority for privacy and data protection matters is the Information Commissioner's Office (ICO). You also have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you would like to exercise any of the rights described above, 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.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
The Site is 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 Site 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 privacy@vanguard.com . You also may contact us by sending a message to:
Vanguard Asset Management, Limited
Attn: Data Protection Officer
25 Walbrook
London, GB EC4N 8AF
If you raise concerns about how we have handled your Personal Data, we may request additional details from you regarding your concerns, and we may 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 Site 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.
January 2022