This Vanguard Blog for Institutional Investors site (“Site”) is owned and operated by The Vanguard Group, Inc., and all of its subsidiaries and affiliates, including Vanguard Marketing Corporation (collectively, “Vanguard”). Vanguard is committed to maintaining the privacy of your personal information. Our information collection and handling practices for this Site are set forth below.

 The personal information we collect

If you wish to comment on a post on this Site, we require you to provide us with your first and last name and e-mail address. To encourage constructive commentary, posted comments will identify you by first name and last initial. You should not include any personally identifying information in your comments, such as any Vanguard account information, and you should not ask questions or request information about transactions.

We may combine the information collected on this Site with information collected from or about you in other contexts, as described in more detail below. This may include information collected online, such as through our websites or email exchanges with you, or from offline sources, such as information that we collect if you establish an account with us or call customer service. If you do not wish to provide information to Vanguard, we may be unable to provide certain services to you.

 How we handle your information

We do not sell information about users of this Site to any third parties. Nor do we share such information, except as set forth below. Here are the details:

Except for published comments, the opinions, comments, and any other information you provide to Vanguard through this Site are not available or visible to anyone other than authorized personnel of Vanguard and our service providers.

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.

We will also release information about you if you direct or authorize 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 and web beacons

This Site uses a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect information that helps us understand how the Site is used. Specifically, when you visit this Site, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including: 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; webpages you view; links you click; searches conducted on the Site; the internet protocol (IP) address used to access our Site; 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 third parties send to you, as further described below. 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.

Cookies: A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website. Cookies contain information that is transferred to or read on your device and allow websites to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Site. This helps us to provide you with a useful experience when you browse our Site and also allows us to improve our Site. We and our third-party service providers use session cookies, which link your actions during a particular browser 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.

If you are concerned about having cookies on your computer or other device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of our Site may not operate correctly. For further information about deleting or blocking cookies, please visit allaboutcookies.org/manage-cookies/. Information about how to opt out of the use of cookies for certain purposes (such as interest-based advertising) is discussed in the section titled “Third-party analytics and interest-based advertising.”

Web beacons: This Site and the emails that you receive from Vanguard may use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is a tiny transparent image embedded in a webpage or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.

This Site offers customized features that require our use of cookies and web beacons. Certain sections of the Site require cookies to be enabled to support Site performance and provide enhanced authentication. 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 this Site so that we can improve Site structure, functionality, and content. Web beacons allow us, directly or through our third-party service providers, to collect information used for website analytics, such as how many users have visited particular pages on this Site, or how frequently users search for a particular term on the Site. However, our use of these cookies and web beacons is limited. We do not use them to pull other 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 as described in this privacy policy.

We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information about 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 and have registered for secure access on another Vanguard website, we are able to combine the information we collect about your usage of our websites 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 websites, 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 websites 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 third-party service providers’ technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your use of our websites 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 to you.

This Site includes links to third-party sites or information that we think may be of interest to you. When you click on these links and leave this Site, this Site’s terms and conditions of use and privacy policy no longer apply. You are responsible for complying with the third party site’s terms of use and understanding its privacy policy, both of which you should review carefully.

This Site may also integrate certain third-party plug-ins to enable content sharing via social media applications (such as the Facebook “Like” button or the Twitter “Follow” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie on your device. These plug-ins are governed by the privacy policy of the company providing them.

Third-party analytics and interest-based advertising

We partner with third parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our websites. In particular, this Site uses Adobe Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of this Site may be transmitted to and stored by Adobe Analytics on servers outside your country of residence. You may opt out of the use of cookies by Adobe Analytics at adobe.com/privacy/opt-out.html.

We also partner with third-party service providers to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (interest-based advertising), and to help us measure brand awareness and the effectiveness of our online advertising. These service providers may use cookies and web beacons to collect information about your activity on our websites, and they may combine it with information about your activity on other, unaffiliated websites. We and our service providers may use data collected on our websites or when you open emails from Vanguard, together with other information we have about you and your Vanguard relationships, to serve Vanguard ads to you on other sites as you browse the web. For example, third parties may use the fact that you visited this Site to target ads for Vanguard products and services to you on non-Vanguard websites. In addition, our third-party advertising providers might use information about your use of our websites to help target non-Vanguard advertisements to you based on your online activity in general. We do not provide any information to these service providers that could personally identify our users or clients, and they do not collect such information for us.

Vanguard uses the Ghostery assurance service to comply 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 data are 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 opt-out page, available at aboutads.info/choices. 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 providers or based on the particular website that you are viewing. Also, if your browser is set to reject cookies when you visit the AdChoices opt-out page, or if you subsequently clear your browser cookies, your opt-out may no longer be effective.

Although this Site currently does not respond to “Do not track” browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this privacy policy. For information about mobile privacy, please review the privacy policy available through our mobile applications.

How we safeguard your information

This Site has security measures in place to protect the loss, misuse, and alteration of the information under our control. These measures provide a high level of security and privacy when you furnish your opinions and comments.

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. To protect your 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 Vanguard 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 may change this privacy policy without notice from time to time. Please visit this page for updates and changes.

 

March 2017