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 apply for secure access to this site, we ask you to provide us with certain personal contact information, including your name, address, phone number, and email address. In addition to information you 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 your information primarily to respond to your inquiries or requests; to maintain and protect your accounts; to process transactions that you submit; 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 or through our mobile applications 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.

We do not share personally identifying information about our website visitors or our current, former, or prospective clients with unaffiliated third parties for use in marketing their own products and services. We may share your personal information when needed to fulfill your requests for information or access to various tools, 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).

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 and our mobile applications 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 or mobile applications; 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 and mobile application 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 or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications 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.

If you are concerned about having cookies on your computer or other device, you can set your web 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 websites or our mobile applications may not operate correctly. For further information about deleting or blocking cookies, please visit here. 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 "Website analytics and interest-based advertising."

Web beacons: Our websites, our mobile applications, 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 or mobile application 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.
Our websites and mobile applications offer customized features that require our use of cookies and web beacons. Certain sections of our websites and mobile applications require cookies to be enabled to support site or application performance and provide enhanced authentication. For example, cookies enable us to personalize and improve your user experience and help enhance navigation. Cookies also help us to understand how people use our online services so that we can improve their structure, functionality, and content. Web beacons allow us, directly or through our service suppliers, to collect information used for website and mobile application analytics, such as how many users have visited particular pages or downloaded documents, or how frequently users search for a particular term. However, our use of these cookies and web beacons is limited. We do not use them to view or collect data in cookies or 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 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 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 who has registered for secure online access to your Vanguard accounts, we are able to combine the information we collect about your usage of our website or mobile application during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your 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, 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 in our mobile applications and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to you.

Our websites include links to third-party sites or information that we think may be of interest to you. When you click these links and leave our websites, our sites' 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 websites may enable you to share information directly with websites or online services operated by third parties. For example, our sites contain features that allow you to share articles or content through Facebook, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and to the public more generally. Even if you do not click these plug-in features, these third parties may collect information about you, such as your IP address and the pages that you view, and they 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 their content or practices. The collection, use, and disclosure of information through these websites and services are subject to the privacy policies of the third-party websites or services, and not this privacy policy.

We engage service suppliers to collect the information discussed above to engage in analysis, auditing, research, and reporting. These service suppliers 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 and mobile applications. In particular, our websites and mobile applications use Adobe Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of our online services 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 here.

We also partner with service suppliers, including social networks, to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (Interest-Based Advertising), and to help us measure brand awareness and the effectiveness of our online advertising. These service suppliers may use cookies, web beacons, and other similar technologies to collect information about your activity on our websites, and they may combine it with information about your activity on other, unaffiliated websites. We and our service suppliers may use data collected on our websites or when you open emails from Vanguard, together with other information we have about you and your Vanguard relationships, to serve Vanguard ads to you on other sites as you browse the web. For example, our advertising service suppliers may use the fact that you visited our site to target ads for Vanguard products and services to you on non-Vanguard websites. In addition, our advertising service suppliers might use information about your use of our online services to help target non-Vanguard advertisements based on your online activity in general. We share demographic information (e.g., age) with certain service suppliers; we do not provide your name or otherwise identify you to any of these service suppliers.

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 you.

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.

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.

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 accordance with applicable law and 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.

For your protection, you should not provide your Vanguard 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.

Vanguard offers a variety of options for accessing and reviewing your account information. You can review your information on your statements and other account documents, as well as through our automated telephone services and websites. You may also write or call us with your request for information. Specific website addresses, mailing addresses, and telephone numbers are listed on your account statements and other Vanguard correspondence.

If you have any questions relating to this privacy policy or concerns about the way in which we have handled information about you, please send us an email at privacy@vanguard.com.

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

Effective 1/2023