Vanguard Investments Canada, Inc. ("Vanguard," "we," or "us") values the privacy and security of information about our clients and potential investors. In this privacy notice ("Notice"), we describe how Vanguard collects, uses, and discloses information collected on its websites (“Site”).
Your use of our Site or related services, and any dispute over privacy, is subject to this Notice and our 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 also may be collected by or transferred to, and therefore controlled by, Vanguard Investments Canada, Inc., 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, the Site may be transferred to and processed in the United States or another jurisdiction outside Canada, which may have less stringent data protection laws.
We may collect, process, use, and disclose both Personal Information (“PI”) and Other Information in connection with your use of the Site. For purposes of this Notice, PI is any information that alone or together with other information relates to an identified or identifiable person, such as name, phone number, email address, financial account information, and online account information such as username and password. "Other Information" is any additional information that is not PI. In this section, we describe our information collection practices, including the types of PI and Other Information that we collect. In subsequent sections of this Notice, we describe how we use and disclose PI and Other Information.
We may combine the PI and Other Information collected on the Site with information collected from or about you in other contexts. 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 advisor; 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 Notice. If you do not wish to provide information to Vanguard, we may be unable to provide certain services to you.
Vanguard may collect the following PI from or about you:
PI we collect directly from you online, such as when you register to use the Site or request information from us: Vanguard may collect and maintain PI about you, and about any person or entity on whose behalf you are acting, that you provide to us on the Site, such as when you register to use the Site, obtain a product or service from Vanguard, request information or materials from us, or otherwise interact with our Site. The types of PI we collect vary based on your particular interaction with us, but could include:
PI for your account: Depending on the type of account, and to the extent permitted by law, we may collect the following PI from you or about 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 on the Site:
Full name, company name, primary role or title, date of birth, gender, and contact details, including mailing address, email address, and telephone and fax numbers;
User name, password, PIN, and answers to security questions;
Tax identification 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 authorized signatories, agents, or representatives;
Copies of any relevant trust deeds, partnership agreements, constitutions, or articles of association;
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 PI for your account from third parties authorized to disclose your PI, 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. By disclosing information about authorized signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you have the consent of those parties to such collection, use, and disclosure of their information as described in this Notice.
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 Vanguard's behalf that you provide in response to those surveys is at your discretion.
Our Site uses a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect Other Information that helps us understand how our Site is used. Specifically, when you visit the Site, 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; web pages you view; links you click; searches conducted on the Site; the internet protocol (IP) address used to access our Site; your general geographic location (e.g., your city, province, postal code, or metropolitan region); and the website visited before our Site. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below.
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 Site. This helps us to provide you with a useful experience when you browse our Site and allows us to improve our Site. 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: http://www.allaboutcookies.org/manage-cookies/. 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 Site or 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 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 Information with additional information that we have collected about you, including, where applicable, your name and other PI. When we combine Other Information with PI, we treat all the combined information as PI. If you have registered for secure access on our Site, we are able to combine the information we collect about your usage of our Site 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 Site, 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.
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 the Site. In particular, the Site uses Adobe Analytics. to help collect and analyze certain information for the purposes discussed above. The information generated about your use of the Site may be transmitted to and stored by Adobe Analytics on servers outside Canada. You may opt out of the use of cookies by Adobe Analytics here.
We also partner with third parties to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (Interest-Based Advertising). These third parties may use cookies and web beacons to collect information about your activity on our Site, and they may combine it with information about your activity on other, unaffiliated websites. For example, third parties may use the fact that you visited the Site to target ads for Vanguard services to you on non-Vanguard websites. In addition, our third-party advertising providers might use information about your use of the Site to help target non-Vanguard advertisements based on your online activity in general. You may opt out of Interest-Based Advertising by clicking the “Manage cookies” link found at the bottom of every page of the Site.
We use the PI and Other Information that we collect for the purposes described in this Notice 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 fulfill 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;
For marketing and promotional purposes, consistent with applicable law. For example, we may use your PI, such as your email address, to send you news and newsletters, or to otherwise contact you about 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 tailor the content, information, and advertising that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Site;
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);
To count and recognize visitors to the Site and various Site features and better understand how users access and use our Site and Vanguard products and services;
To create new products and services or improve our existing 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.
We may disclose PI and Other Information to third parties for the following purposes, as permitted by law:
Affiliates: We may disclose PI and Other Information to Vanguard Affiliates for the purposes described in this Notice. Vanguard Affiliates may contact you by email, where permitted by law, to make you aware of Vanguard's product and service offerings.
Service providers: We may disclose PI and Other Information to our service providers, who use it to perform tasks on Vanguard's behalf. Among other things, these service providers help us manage and improve the Site, provide Vanguard services, mail disclosures and statements to you, and administer your accounts. 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 organization involved in providing, managing, or administering the Site, 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 advisors, and other professional advisors.
Customer agents: We may disclose PI to your agents or representatives, including:
Your financial advisor;
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 authorized 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 Site, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a 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 authorized 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, securitization, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, as permitted by applicable law. By agreeing to the terms of this Notice, you are consenting to this disclosure.
Market research: We also may 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. For example, we may run client satisfaction surveys or run focus groups on proposed products.
Direct sharing through third-party websites and services: The Site may enable you to share information directly with websites or online services operated by third parties. For example, the Site contains 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. If you choose to use these features, you may disclose information to users of those websites or services and 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 Notice.
Aggregated information: From time to time, Vanguard may share aggregated information about users of the Site or Vanguard's products and services, such as sharing reports on the usage of the Site or Vanguard's services for regulatory reporting or marketing purposes.
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 Vanguard or Vanguard Affiliates located in or outside the United States. Vanguard also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries outside Canada. As a result, the PI and Other Information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above, pursuant to methods permitted by the laws of Canada 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 Canada. Further, PI might be disclosed to governments or law enforcement agencies in these countries where required by law. By accepting this Notice, using the Site, or by providing any PI or Other Information to us, you expressly consent to such transfer and processing.
Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that PI 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.
We use commercially reasonable physical, electronic, and procedural safeguards to protect your PI 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 be guaranteed. 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.
Vanguard retains PI for as long as necessary to provide our services to you, to fulfill the purposes described in this Notice and/or our business purposes, or as required by law, regulation, or internal policy.
We provide you with the ability to access, review, correct, delete, or inquire about information that we hold about you, as required and permitted under applicable law. You also may have a right to oppose or limit the collection and processing of your information as described in this Notice, or to revoke your consent, although we may be unable to provide services to you if you oppose this processing or if you revoke consent.
If you would like to exercise your applicable data rights, 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. Please note that we may need to take additional steps, such as to verify your identity, before we can grant your request. As permitted by law, we will notify you of the basis for any denial of your request.
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.
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 Site or sending any information about themselves to anyone over the internet.
If you have any questions relating to this Notice, 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. Please include your relationship to Vanguard in your email. You also may contact us by sending a message to:
Canada:
Vanguard Investments Canada, Inc.
Attn: Privacy Officer
22 Adelaide Street West
Suite 2500
Toronto, ON M5H 4E3
United States:
The Vanguard Group, Inc.
Attn: Global Privacy
P.O. Box 2600
Valley Forge, PA 19482-2600
If you raise any concerns about how we handle your Personal Information, we may request additional details from you and may need to engage or consult with other parties to investigate and resolve your issue.
We will post changes to this Notice on our Sites along with the effective date of the changed Notice. We recommend that you review this Notice periodically. If we make a material change to this Notice, you will be provided with appropriate notice.