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Vanguard Asset Management, Limited
Cookie policy

Vanguard Asset Management, Limited, and its affiliated companies ("Vanguard," "we", or "us") use cookies on our websites operated within the European Economic Area (the “Sites”). This cookie policy provides you with detailed information about the types of cookies we use and the purposes for using those cookies. For information about how Vanguard collects, uses, and shares other types of information, please read our privacy policy.

This policy does not govern the operation of our websites for Vanguard's US investors. To review the privacy policy that applies to US customers of Vanguard, please visit our websites intended for US investors and review the privacy policies posted there.

Our Sites 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 Sites are used. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. When you visit our Sites, you have the ability to accept or decline these cookies and other tracking mechanisms, except those that are strictly necessary in order for you to enter and move around the Sites and use essential Site features, and you can change your preference at any time.

What is a cookie?

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 recognise devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our Sites. This helps us to provide you with a useful experience when you browse our Sites and also allows us to improve our Sites. 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.

Our Sites 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. In some cases, a web beacon triggers the placement or updating of a persistent cookie on your device.

What cookies do we use and why?

The cookies used on our Sites are categorised as follows:

Strictly Necessary

"Strictly Necessary" cookies let you enter and move around the Sites and use essential features. Without these cookies, services and information you have asked for cannot be provided. We use these Strictly Necessary cookies primarily to identify you as having confirmed your eligibility to enter and use our Sites, and to make sure you connect to the right service on our Sites when we make any changes to the way the Sites work. Accepting these cookies is a condition of using our Sites, so if you prevent these cookies, we cannot guarantee your use of our Sites or how the security on our Sites will perform during your visit.

Performance and analytics

"Performance" cookies collect information about how you use our Sites, such as which pages you visit and any errors you experience. These cookies are used to help us improve how our Sites work and understand what interests our users. We use Performance cookies for:

  • Analytics, to provide a variety of statistics on how our Sites are used;
  • Error management, to help us improve the website by measuring any errors that occur;
  • Design testing, to test different designs of our Sites to improve the users' experience; and
  • Website analytics, which enable us to collect, either directly or through third-party service providers, a variety of technical and navigational information, 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; web pages you view; links you click; searches conducted on the Sites; the internet protocol (IP) address used to access our Sites; your general geographic location (e.g. your city, postal code, or metropolitan region); and the website visited before our Sites. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We also analyse this information, with the assistance of our service providers, to improve our web 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.
In particular, our Sites use Adobe Analytics to help collect and analyse certain information for the purposes discussed above. The information generated about your use of our Sites 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.

Some of our Performance cookies are managed for us by third parties. However, we do not allow the third party to use the cookies for any purpose other than those listed above.

Functionality

"Functionality" cookies help to provide services or to remember settings to improve your visit. We use Functionality cookies primarily to identify whether and when you've visited our Sites previously. Some of these cookies are managed for us by third parties, but we don't allow the third party to use the cookies for any purpose other than those listed above.

Targeting

"Targeting" cookies permit us – through our third-party service providers – to identify whether and when you have seen or clicked on a particular Vanguard advertisement on a third-party website, as well as enabling us to target our advertising to you on other websites after you have visited our Sites. We partner with third parties to provide targeted advertising services that are customised 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 third parties use cookies, web beacons, and other similar technologies to collect information about your activity on our Sites, and they may combine it with information about your activity on other, unaffiliated websites. We and our service providers may use data collected on our Sites 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, third parties may use the fact that you visited our Sites to target ads for Vanguard services to you on non-Vanguard websites. In addition, our third-party advertising service providers might use information about your use of our Sites to help target non-Vanguard advertisements based on your online activity in general.

We and our service providers may also 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.

For more information about Interest-Based Advertising and how to opt out, please visit:

Although our Sites currently do not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies, and not this cookie policy.

How to withdraw your consent or delete or block our cookies

Unless you have adjusted your browser setting so that it will refuse cookies, Vanguard's system will set Strictly Necessary cookies when you visit our Sites, and we will also set Performance, Functionality, and Targeting cookies if you provide your consent.  You can change your cookie settings at any time though the Cookie preferences link at the bottom of our Site pages.

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 our Sites may not operate correctly.

If you change the settings on your web browser or delete your cookies, you will be presented with the consent option again the next time you visit our Sites.

For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/.

Revised May 2018