The Vanguard Group, Inc., is committed to maintaining the privacy of your personal information. Information collection and handling practices for this Site are set forth below.

The information we collect

When you engage with this website (“Site”), we collect and store certain information about your internet connection and your use. This information may be used, for example, to respond to your comment, to alert you to software-compatibility issues or to resolve technical or service problems, or it may be analyzed to improve our web design and functionality. The information collected may include the following:

  • the date and time you access the Site;
  • the pages that you visit;
  • if you linked to this Site from another website, the address of that site;
  • the type of web browser used to access this Site; and
  • the IP address from which you access this Site.

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 might also reveal information in your opinions or comments, but you should not include any personally identifying information in your comments, such as any Vanguard account information, nor should you ask questions or request information or transactions.

Temporary or “session” cookies are used on this Site to help us accurately analyze how users navigate at an aggregated level. A cookie is a small file of letters and numbers placed on your computer or device. These cookies are stored in memory and are only available during an active browser session. These cookies do not collect personal information on users, and they are erased as soon as you close your web browser. No personally identifiable information about you is maintained as a result of a temporary or session cookie.

We also use persistent cookies to collect information about how you use this Site, such as which pages you visit and any errors you experience. You can change your cookie preferences at any time by activating the setting on your web browser that allows you to delete or refuse the setting of cookies.

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 Vanguard personnel.

If necessary, we may disclose information we have about you to nonaffiliated companies we engage to perform services for us in connection with the Site. In any such case, 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 us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to prevent fraud).

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 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.

We may change this Privacy Policy without notice from time to time. Please visit this page for updates and changes.

July 2013

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