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Privacy Policy for About Vanguard

This About Vanguard site, part of Vanguard.com, 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 information we collect

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.

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, from publicly available sources, 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.

Cookies and web beacons

Our websites use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect information that helps us understand how our sites are used. Specifically, when you visit our sites, 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 sites; the internet protocol (IP) address used to access our sites; your general geographic location (e.g., your city, state, 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. 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 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 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 sites 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 website analytics) is discussed in the section titled “Third-party analytics.”

Web beacons: Our sites 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.

Our sites offer customized features that require our use of cookies and web beacons. Certain sections of the sites require cookies to be enabled to support site 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 sites 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 the site, or how users navigate through our sites. However, our use of these cookies and web beacons is limited. We don't 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 to your accounts on a Vanguard site, 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 account transactions you conduct 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 each of those visits, 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 communications and 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.

Our websites include links to third-party sites or information that we think may be of interest to you. When you click on these links and leave our site, our 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.

Our sites 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

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.

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.

How we handle your information

We do not sell information about users of our websites to third parties. Nor do we share such information, except as set forth below.

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).

Cross-border transfer of information

Vanguard generally maintains centralized 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, the information that we collect through or in connection with our sites is transferred to and processed in the United States for the purposes described above, pursuant to methods permitted by the laws of your country of residence for ensuring that information about you will be adequately protected. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this privacy policy or using our sites, you expressly consent to such transfer and processing.

How we safeguard information

We use commercially reasonable physical, electronic, and procedural safeguards to protect your information from loss, misuse, and unauthorized 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 unauthorized 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. 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.

6/2017