Vanguard Institutional Portal privacy policy

Introduction

The Vanguard Group, Inc. and Vanguard-affiliated companies ("Vanguard," "we," or "us") value the privacy and security of information about Vanguard's clients and potential investors. Vanguard entities outside the United States 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 on websites operated by Vanguard entities outside the United States that link to this privacy policy (the "Sites"). For a list of Vanguard-affiliated companies ("Vanguard Affiliates") outside the US, please visit here.

Please read this Policy carefully. By providing information to Vanguard, investing with Vanguard, or visiting or using our Sites, you acknowledge the practices described in this Policy. Your use of our products and services, including our Sites, and any dispute over privacy, is subject to this Policy, the applicable Vanguard prospectus, and, as applicable, our Sites'Terms and conditions of use, including applicable limitations on damages and the resolution of disputes.

The information that we collect is controlled by The Vanguard Group, Inc., which is headquartered in the United States at 100 Vanguard Boulevard, Malvern, Pennsylvania 19355-2331 and can be reached by mail at P.O. Box 1110, Valley Forge, PA 19482-1110. This information is also controlled by the Vanguard Affiliate located in your country of residence or with which you are dealing directly. 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.

Information collection

What Personal Data do we collect?

What Other Data do we collect automatically?

Use, legal basis, and disclosure

How do we use Personal and Other Data?

Legal bases for using Personal Data

To whom do we disclose Personal and Other Data?

Websites analytics and Interest-Based Advertising

Cross-border transfer of information

Personal Data quality

Information security and retention

Your legal rights

Children's privacy

Contact us

Changes to this Policy

Information collection

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 Vanguards 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 Sites. 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.

What Personal Data do we collect?

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 Sites: 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 Sites, or otherwise interact with us or our Sites. The types of Personal Data we collect vary based on your particular interaction with us, but could include:

• Your name, company name, and primary role or title;
• Postal mailing address;
• Telephone and fax numbers;
• Email address;
• Account number and other account information;
• User name, password, and other security credentials; and
• Other information you provide to us directly, such as information collected for identification or authentication purposes.

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:

• Full name, date of birth, gender, and contact details, including mailing address, email address, and telephone and fax numbers;
• Tax identification number/national insurance number, and bank account and payment method details, if such information is needed for the purpose of administering your accounts;
• Employment details, which may include annual salary;
• Contribution amounts and investment choices;
• Details about authorised signatories, agents, or representatives;
• Copies of any relevant legal documents;
• Details of services you are interested in and about your investment needs;
• Information about employees, agents, or other representatives of a client or prospective client, if such information is needed to open or maintain an account; and
• Other information that you provide to us in connection with 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 Vanguards 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 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 Vanguards behalf that you provide in response to those surveys is at your discretion.

What Other Data do we collect automatically?

Our Sites use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect Other Data that helps us understand how our Sites are used.  Specifically, when you visit the Sites, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including as applicable:  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; web pages you view; links you click; searches conducted on the Sites; the internet protocol (IP) address used to access our Sites; your general geographic location (e.g., your city, postal code, or metropolitan region); and the website visited before our Sites.  We also may use similar tracking technologies in emails that we or third parties send to you, as further described below.  To learn more about how our Sites use cookies, please read our Cookie policy.  When you visit our Sites, you have the ability to accept or decline these cookies and other tracking mechanisms, except those that are strictly necessary in order for you to enter and move around the Sites and use essential Site features, and you can change your preference at any time.

• 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 recognise devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Sites. This helps us to provide you with a useful experience when you browse our Sites and also allows us to improve our Sites. 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, 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 computer. 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 the Sites may not operate correctly. For further information about deleting or blocking cookies, please visit here. Information about how to opt out of the use of cookies for certain purposes (such as interest-based advertising) is discussed below in the section titled Third-party analytics and Interest-Based Advertising.

• Web beacons: The Sites or the emails that you receive from Vanguard use an application known as a web beacon (also known as a pixel tag or clear gif) A web beacon is an electronic file that usually consists of a single-pixel image. 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 such as 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 on 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.

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 Sites, we are able to combine the information we collect about your usage of our Sites 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 Sites, even if you do not log on, and link information about that visit, 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 Sites and the effectiveness of our 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 Website analytics and Interest-Based Advertising.

Use, legal basis, and disclosure

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:

• To establish and administer accounts and your relationship with us, to fulfil the terms of any agreement you have with us, and to otherwise provide Vanguard's products and services to you;
• To communicate with you, notify you about important updates or changes to Vanguard's products and services, and address relevant inquiries or complaints;
• To comply with our legal obligations and protect our legal rights, including, without limitation, to comply with record-keeping, reporting, and tax obligations under applicable law (such as corporations, tax, managed investments or securities, and anti-money laundering laws);
• For marketing and promotional purposes, in accordance with applicable law. For example, as permitted by applicable law, we will use your Personal Data, such as your email address, to send you news and newsletters, or to otherwise contact you about Vanguard products or information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication;
• To create new products and services or improve our existing products and services;
• To tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled Third-party analytics and Interest-Based Advertising, to offer location customisation and personalised help and instructions, and to otherwise personalise your experiences with Vanguard and while using the Sites;
• To count and recognise visitors to the Sites and various Site features and better understand how users access and use our Sites and Vanguard products and services;
• To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
• For other research and analytical purposes

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:

• Our use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your contact, demographic, and banking information required to establish and fund your account in the performance of our services);
• Our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to undertake vetting to comply with anti-money laundering legislation or where we are required to disclose Personal Data to a court or tax authority);
• You have provided your consent to us using the Personal Data (for example in relation to our use of cookies on the Sites); and/or
• Our use of your Personal Data is in our legitimate interest as a commercial organisation (for example in order to make improvements to our products and services and to provide you with information you request); in these cases we will process your Personal Data at all times in a way that is proportionate and respects your privacy rights, and you have a right to object to this processing as explained in the section below titled Your legal rights.

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, in accordance with applicable law, to make you aware of Vanguard's product and service offerings.

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 Sites. 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:

• Any organisation involved in providing, managing, or administering the Sites, related systems, or other Vanguard services, such as administrators, mail houses, email senders and providers, technology service providers, and third parties that provide analytics and advertising services as described in the section below titled Third-party analytics and Interest-Based Advertising; and
• Vanguard's auditors, consultants, legal advisers, and other professional advisers

Customer agents: We may disclose Personal Data to your agents or representatives, including:

• Your legal or other professional adviser(s);
• Any administrator or trustee for a fund or trust to which your investment balance is to be transferred or rolled over;
• Your legal representative or attorney; and
• Other financial institutions that hold an account in your name or on which you are authorised to act, for example, where amounts have been transferred to or from that account.

Legal purposes: We may use and disclose information about you as we believe reasonably 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 Sites, 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.

Direct sharing through third-party websites and services: The Sites may enable you to share information directly with websites or online services operated by third parties. For example, the Sites contain 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. Because these third-party websites and services are not operated by Vanguard, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Policy.

Competitions, contests, and promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Sites 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 Sites or Vanguard's products and services, such as sharing reports on the usage of the Sites or Vanguard's services for regulatory reporting or marketing purposes.

Website analytics and Interest-Based Advertising

We partner with third parties to collect the Other Data discussed above to engage in Site analysis, auditing, research, and reporting. When you visit our Sites, 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 the Sites. We use these cookies to identify you as having confirmed your eligibility to enter and use our Sites, and to make sure you connect to the right service on our Sites when we make any changes to the way the Sites work. These cookies are also used to help us improve how our Sites work and understand what interests our users, and for error management, to help us improve our Sites by measuring any errors that occur. In particular, the Sites use Adobe Analytics to help collect and analyse certain information for the purposes discussed above. The information generated about your use of the Sites 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 here.

We also partner with third-party service providers, including social networks, to provide targeted advertising services that are customised 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. If you provide your consent on our Sites, these service providers may use cookies, web beacons, and other similar technologies to collect information about your activity on our Sites, 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 Sites 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 the Sites to target ads for Vanguard products and services to you on non-Vanguard websites. In addition, our third-party advertising service providers might use information about your use of the Sites to help target non-Vanguard advertisements based on your online activity in general.

For more information about Interest-Based Advertising and how to opt out, please visit:

• Network Advertising Initiative opt-out page; and
• European Interactive Digital Advertising Alliance opt-out page (available in 27 languages).

Although our Sites currently do 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 Policy.

Cross-border transfer of information

Vanguard generally maintains centralised servers and systems in the United States and may maintain servers and systems elsewhere.  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.  As a result, where the Personal and Other Data that we collect is transferred to and processed in the United States or another jurisdiction outside your country of residence for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within your country of residence, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, where applicable, or relying on certification schemes such as the EU-US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside your country of residence.

Personal Data quality

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.

Information security and retention

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 user name and password private.

Vanguard retains Personal Data for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy. We are obliged to retain certain information to ensure accuracy, to help maintain quality of service, and for legal, regulatory, fraud prevention and legitimate business purposes.

The Sites 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, youll be subject to the sites privacy policy, which you should read and understand before using the site or its products or services.

Your legal rights

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:

• the source of your Personal Data;
• the purposes, legal basis, and methods of processing;
• the data controllers identity; and
• the entities or categories of entities to whom your Personal Data may be transferred.

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:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object (see Right to object below); or
• it has been processed unlawfully; or
• to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase Personal Data if the processing of your Personal Data is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise, or defence of legal claims.

Right to restrict the processing of your Personal Data

You can ask us to restrict your Personal Data, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your Personal Data following a request for restriction:

• where we have your consent; or
• to establish, exercise, or defend legal claims; or
• to protect the rights of another natural or legal person.

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:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

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 analytics and online interest-based advertising by following the steps detailed above in the section titled Third-party 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 your local supervisory authority

If you are in the European Union, you 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.

Children's privacy

The Sites are 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 Sites or sending any information about themselves to anyone over the Internet.

Contact us

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:

If you raise concerns about how we have handled your Personal Data, we may request additional details from you regarding your concerns, and 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.

Changes to this Policy

We will post changes to this Policy on our Sites 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.

Revised October 2018