This Vanguard Institutional Trading website 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.
Click here to view our Privacy notice for California residents.
The information we collect about you
The information that we collect on this site 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 also may be collected by or transferred to, and therefore 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 through or in connection with our websites 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.
When you register for secure access to this site, we ask you to provide us with certain personal information regarding each of your organization’s authorized site users, including name, phone number, email address, plans or accounts the user is authorized to access, and level of authority. In addition to information you or your organization provide to us, we may receive information about you that you authorize other parties to provide to us. We also may obtain information from third-party service suppliers not affiliated with Vanguard (service suppliers) in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
We use the information provided to us primarily to respond to inquiries or requests; to maintain and protect accounts; to process transactions; to fulfill our legal obligations; for research and analytical purposes; and to develop and provide the financial products and services that we offer or sponsor.
We may combine the information collected on our websites with information collected from or about you in other contexts. This may include information collected online, such as on our websites or through our email exchanges with you, from publicly available sources, or from offline sources, such as when you establish an 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.
How we handle your information
We do not share personally identifying information about prospective, current, or former clients or their representatives with unaffiliated third parties for use in marketing their own products and services. We may share personal information when needed to complete requested transactions or to make you aware of 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 or your organization 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 institution 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, advice services, brokerage services, or asset management and trust services.
- In certain instances, we contract with service suppliers to perform services for us. Where necessary, we will disclose personally identifying information we have about you to these service suppliers. In all such cases, we provide the service supplier with information about you only as necessary to carry out its responsibilities as provided in its agreement with us, and only for that purpose. And we require these service suppliers to treat your information with the same high degree of confidentiality that we do.
- Finally, we will release information about you if you direct or authorize us to do so, if we are compelled by law or legal process to do so, or in other legally limited circumstances (for example, to prevent fraud).
Cookies and web beacons
Our websites use some of the most secure forms of online communication available, including data encryption, transmission encryption, 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 and initiate online transactions.
We use a variety of online technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect information that helps us understand how our websites are used. Specifically, when you visit Vanguard online, we or our service suppliers 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; pages you view; links you click; searches you conduct; the internet protocol (IP) address used to access our websites; your general geographic location (e.g., your city, state, or zip code); and the website visited before our sites. We also may use similar tracking technologies in emails that we or our service suppliers send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues, to resolve technical or service problems, and for security purposes. We also analyze this information, with the assistance of our service suppliers, to improve our website 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 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 online services. This helps us to provide you with a useful experience when you browse and also allows us to improve our online services. We and our service suppliers use session cookies, which link your actions during a particular online 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.
Web beacons: Our websites and 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, embedded in a web page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.
We and our service suppliers 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.
If you are a Vanguard client who has registered for secure online access to your or your organization’s Vanguard accounts, 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 online visit to Vanguard, even if you do not 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 websites and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to your organization.
Website analytics and interest-based advertising
We may use service suppliers' technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your interactions with our online services and online advertising 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 for our clients.
Vanguard complies 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 individuals understand how their information is being used and provide choices for individuals who want more control. For information about Interest-Based Advertising and how to opt out, please visit the DAA consumer choice page, available here. 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 companies or based on the particular website or page that you are viewing. Also, if your browser is set to reject cookies when you visit the YourAdChoices opt-out page, or if you subsequently clear your browser cookies, your opt-out may not be or remain effective.
Although our websites currently do not respond to "do not track" browser headers, you can limit tracking by taking the opt-out steps discussed above.
Cross-border transfer of information
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. You can visit our Security Center to read more details about our online security and privacy features.
What you can do
For your protection, you should not provide your account information, user name, or password to anyone. Please be aware that despite our best efforts, no information security measures can guarantee 100% security all of the time. If you become aware of any suspicious activity relating to your account or information, it is your responsibility to contact us immediately.
If you have any questions relating to this privacy statement or concerns about the way in which we have handled information about you, please send us an email at email@example.com.