The Vanguard Group, Inc., sponsor of this website (“Site”), 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

When you engage with this Site, we may collect, either directly or through third-party service providers, certain technical and navigation information, such as computer browser type, internet protocol (IP) address, pages visited, date and time of your visit, and average time spent on the Site. This information may be used, for example, to respond to your comments, 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 and to tailor our marketing and communications regarding our products and services.

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.

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 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 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 to collect information that helps us understand how the Site is used. A cookie is a small file of letters and numbers that is stored on the hard drive of your computer. Cookies may expire at the end of a web session or persist in order to store your settings and preferences. A web beacon, also known as a pixel tag, is a tiny transparent image embedded in a web page to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your computer.

Cookies help us to understand how people use the 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 the Site. 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 in accordance with this privacy policy. You can change your cookie preferences by activating the setting on your web browser that allows you to delete or refuse the setting of cookies. Please consult your web browser’s help documentation for more information about deleting or blocking cookies.

If you are a Vanguard investor, we may be able identify your computer or device on each visit to this Site and link information about that visit to you. We may use this combined information to assess the appeal and usefulness of the information offered on this Site, as well as to identify Vanguard products and services that may be of interest to you.

In certain cases, we may use third-party service providers to place advertisements for us on other websites, 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 limited technical, web navigation, and other information, such as the advertisement presented, your IP address, operating system, and browser type, the web page from which you linked to this Site (if any), and pages visited on this Site. We and our service providers may use data collected on this Site to serve ads to you on other sites as you browse the web. We do not provide any personally identifiable information about our users or clients to these service providers, and they do not collect such information for us. All information collected on this Site is used exclusively by Vanguard, or by our service providers on our behalf, and is not shared with unaffiliated third parties.

Vanguard uses the Ghostery assurance service to comply with the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance. As part of this service, Vanguard’s advertisements on other websites are sometimes delivered with icons that help individuals understand how their data are being used and provide choices for consumers that want more control. For information about online behavioral advertising and your choices, you may visit aboutads.info.

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.

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

June 2014