Vanguard Retirement Plan Access and Vanguard 403(b) Services Program Participant privacy policy
The following privacy policy is provided by The Vanguard Group, Inc. (“Vanguard”) and describes how we collect, use, share, and protect information of participants (including prospective, current, and former participants, and their beneficiaries and/or alternate payees ("Participants”)) in the employer-sponsored retirement plans for which Vanguard provides plan recordkeeping and administrative services.
Click here to view our Privacy notice for California residents.
Under the Vanguard Retirement Plan Access Program, Vanguard provides recordkeeping services to retirement plans through an arrangement with Ascensus, LLC. Ascensus Trust Company (“Ascensus Trust”), an affiliate of Ascensus, LLC, provides custodial or trustee services to those same retirement plans.
Under the Vanguard 403(b) Services Program, Vanguard provides recordkeeping services to retirement plans through an arrangement with Newport Group, Inc., some or all which may be provided by Ascensus, LLC, an affiliate of Newport Group, Inc. Newport Trust Company ("Newport Trust") and Ascensus Trust, affiliates of Newport Group, Inc., provide custodial services to those same 403(b) retirement plans.
Ascensus Trust and Newport Trust understand the importance of safeguarding their customers’ financial assets and protecting their personal and financial information. Newport Trust and Ascensus Trust maintain a separate policy distinct from Vanguard’s that describes how they collect, use, share, and protect their customers’ information through the Vanguard 403(b) Services Program and the Vanguard Retirement Plan Access Program. The privacy policy applicable to both Newport Trust and Ascensus Trust can be found here.
Our commitment to you
As the recordkeeper of the employer-sponsored or other retirement plan in which you participate, Vanguard understands the importance of protecting your personal and financial information. When we share Participant information, we do so under the circumstances described in this policy.
We use the personal and other information provided to us primarily to respond to your inquiries or requests, to maintain and protect your accounts, to process transactions you request, to provide education related to retirement plans and financial goals, 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.
The personal information we collect about you
Vanguard may collect Participant information from you or from your plan sponsor, its representatives, and third-party service suppliers not affiliated with Vanguard (service suppliers). For example, we may collect information about you when you request information or materials from Vanguard and when you enter information into an online application or enrollment process.
To provide plan recordkeeping and administrative services, information we may collect or receive about you includes, among other things, your name, address, Social Security or taxpayer identification number, employee identification number, phone number, email address, date of birth, account balances, investment activity, and accounts at other institutions.
We may combine the information collected on our websites 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, or from offline sources, such as when you enroll in your plan or call Vanguard Participant Services. 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.
How we handle your personal information
We do not share personally identifying information about Participants with unaffiliated third parties for use in marketing their own products and services. We may share personal information when needed to complete transactions that you request or to raise your awareness about the financial products and services that we offer. Here are the details:
- To respond to inquiries, complete transactions, make account changes, and provide requested services, it may be necessary to provide identifying information about you to Vanguard’s affiliates or service suppliers, or to other authorized third parties 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.
- To provide retirement plan education that may increase your chances of meeting your financial goals or the goals of the plan, and to educate you about financial products and services that Vanguard offers or sponsors, to better understand your needs, and to improve our product and service offerings, we may share your information within the Vanguard family of affiliated companies, to the extent permitted by law.
- At the direction of your plan sponsor, we will provide your information to third parties, such as service providers of the plan or the plan sponsor.
- To comply with regulatory or legal requirements, we may provide your information to regulatory bodies, taxing agencies, and law enforcement.
- In certain instances, we contract with service suppliers to perform services for us. Where necessary, we will disclose information, including personally identifying information, that we have about you to these service suppliers. In all such cases, we provide the service supplier with personal information 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 personal information with the same high degree of confidentiality that we do.
- To engage in research collaborations designed to enhance public understanding of workplace retirement plans and to encourage supportive public policies, we may share information with leading academic researchers or industry trade associations. Our research collaborations have included projects with The Wharton School of the University of Pennsylvania, Columbia University, and UCLA, among others. In all cases, the information we provide does not include any identifying information about you, such as your name, address, or Social Security number.
- Finally, we will release information about you if we are directed or authorized 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).
Cookies and web beacons
Our websites use secure forms of online communication, including data encryption, transmission encryption, usernames and passwords, and multi-factor authentication. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
We 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 websites are used. Specifically, when you visit our websites, we or our service suppliers may automatically collect a variety of technical and navigational information 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, your general geographic location (e.g., 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 of 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 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. 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 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 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 is discussed below in the section titled “Website analytics.”
Web beacons: Our websites 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 offer customized features that require our use of cookies and web beacons. Certain sections of our websites require cookies to be enabled to support site performance and provide enhanced authentication. For example, cookies enable us to personalize and improve the user experience and help enhance site 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 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 the email was opened, and whether the recipient clicked any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications.
If you have registered for secure online access to your plan account, we are able to combine the information we collect about your website usage during a secure (logged-on) session with other information we know about you, such as any account transactions you conducted during the web session. We can also identify your computer or device on each online visit to our websites, even if you do not log in, and link information about that visit to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our websites, as well as to identify Vanguard products and services that may be of interest to our clients and participants.
Our website includes 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 website 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.
Website analytics
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. In particular, our website uses Google 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 Google Analytics on servers outside your country of residence. You may opt out of the use of cookies by Google Analytics here.
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 through different devices may be combined. By making these connections, we may be able to better understand the relevance of our content to customize that content for you.
Although our websites currently do not respond to “do not track” browser headers, site users can limit tracking by taking the opt-out steps discussed above.
How we safeguard information
Within Vanguard, we restrict access to personal information to those Vanguard and service supplier employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with requested information, or notifying you of new products and services. To protect this 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.
What you can do
For the protection of your information, please do not provide your Vanguard account information, username, 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.
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'll keep you informed
This privacy policy is subject to change. You should review it periodically. If we make changes, we will update the "revised" date and post the revised policy on the website. Although Vanguard is committed to the protection of your personal and financial information, specific requirements regarding Vanguard’s collection, handling, and use of your information may vary depending on your plan sponsor’s particular arrangements with Vanguard. For more information, Participants should contact their plan sponsor.
Effective 8/2024