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 United Kingdom (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.

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 reject these cookies and other tracking mechanisms, except those that are strictly necessary in order for you to enter and use the Sites, and you can change your preference at any time using the preference indicator at the top of this page.

What is a cookie?

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 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 (“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 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 page or an email to measure usage and activity. 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 Cookies

We use Strictly Necessary cookies to ensure our website is functioning properly. For instance, to help you complete common online requests, like setting your privacy preferences, logging onto your account, and completing forms online. These cookies are set by default and cannot be disabled.

Performance Cookies

Performance cookies allow us to measure website traffic and the popularity of pages. This data collected is used to measure and improve the website experience for our clients and visitors to the website. If you turn off these cookies your personal information will not be included in our aggregated data, and we will not be able to know when you have visited our site. If you grant us your consent, we use cookies for website analytics, by collecting, either directly or through our 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 analyze this information, with the assistance of our service providers, to improve our web design and functionality and to enhance our ability to serve you and your accounts.

In particular, our Sites use Adobe Analytics to help collect and analyses certain information for the web analytics purposes discussed in this section. You may opt out of the use of specific cookies by Adobe Analytics here

Functional Cookies

We use Functional cookies to improve the functionality and personalization on our website and the services that we offer. If you reject these cookies some or all of the services may not function properly.

Targeting Cookies

Targeting cookies allow us to display advertising on this site adapted to you by combining data from your browsing habits and data from Vanguard and third-party customer databases. These cookies identify your unique browser, internet device, geographic location, and similar information. If you disable these cookies, we cannot send you advertising tailored to you and your investment interests.

Because we respect your privacy, Vanguard is selective when choosing advertising partners. If you grant us your consent, we use Targeting cookies that permit us, through our service providers, 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 providers 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, together with other information we have about you and your Vanguard relationships, to target ads for Vanguard products and services to you on non-Vanguard websites as you browse the web. In addition, our service providers might use information collected during your use of our Sites to help target non-Vanguard advertisements based on your online activity in general.

For more information about Interest-Based Advertising and how to grant and withdraw your consent with browser headers, please visit: Network Advertising Initiative (NAI) opt-out page; and European Interactive Digital Advertising Alliance (EDAA) opt-out page (available in 27 languages).

The information generated about your use of our Sites may be transmitted to and stored by on servers outside your country of residence. As a result, where the information we collect is transferred to and processed in the United States or anywhere else outside the United Kingdom (UK) for the purposes described in this policy, we will take steps to ensure that the information receives the same level of protection as if it remained within the UK, including entering into data transfer agreements and/or using approved standard contractual clauses. You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the EEA by sending us an email at privacy@vanguard.com. You also may contact us by sending a message to:

Vanguard Asset Management Limited
Attn: Data Protection Officer
25 Walbrook
London, GB EC4N 8AF

We may redact data transfer agreements to protect commercial terms.

Third-party cookie privacy policies

How to withdraw your consent or delete or block our cookies

You can change your cookie preferences at any time using our cookie preference tool. By choosing "Accept all cookies," you agree to the use of all cookies on our website. You can also reject all cookies (except the Strictly Necessary Cookies) by clicking “Reject All” and you can control the cookie types you wish to allow by selecting "Manage cookies" below. Rejecting cookies won't prevent you from accessing Vanguard's site.

By clicking on the cookie on each category of cookies, you will see the list of cookies corresponding to each category with a <Yes / No> button allowing you to make your choice to accept or refuse, regarding each category of cookie. Once you have made your choice, you should click on «Confirm My Choices». You can also reject or accept all categories by clicking on the appropriate buttons.

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 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 Sites may not operate correctly.

If you change the settings on your web browser or delete your cookies, in either case so that Vanguard is not able to detect any prior cookie preferences you may have indicated, you may 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 March 2022

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