Vanguard Asset Management Limited (an affiliate of Vanguard Group Inc.) ("Vanguard", "we", or "us") is committed to protecting your Personal Data and respecting your privacy.
We collect and use certain information to provide a variety of financial products and services to you, including investment management and financial advice. In this privacy notice ("Notice"), we describe how Vanguard collects, uses, and discloses information collected by Vanguard on this website (the "Site").
For Vanguard UK Professional Investors, Vanguard Asset Management Limited is the controller of your Personal Data. Other Vanguard Group companies may process your data on our behalf, as described below.
Vanguard collects and processes Personal Data. For purposes of this Notice, "Personal Data" or “Personal Information” is any information that alone or together with other information Vanguard has, or can reasonably access, relates to an identified or identifiable natural person, such as name, phone number, email address, financial account information, and online identifiers and account information such as user name and password.
Vanguard may also collect and process Special Categories of Personal Data. For the purposes described in this Notice, (“Special Categories of Personal Data”) includes details about your race or ethnicity, religious, or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We may combine the Personal Data we collect directly from you with information collected from or about you in other contexts, such as on the Site. This may include information collected online, such as through our email exchanges with you or from publicly available sources, such as your company website if you are a financial adviser; 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 products or services to you. If we or fraud-prevention agencies identify a fraud or money-laundering risk, we may refuse or stop providing services.
Vanguard may collect Personal Data directly from you when you request information, invest with us or use our Sites.
We also use Aggregated Data, which is usually statistical or demographic information that does not identify you although we may combine it with Personal Data in some cases.
In line with applicable law, Vanguard may record and monitor calls for training, quality, assurance, security and customer service.
The types of Personal Data Vanguard collect depends on your interactions with us and may include:
From third parties: We may collect information from you regarding other individuals related to your account. Where you disclose information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you will only do so in accordance with applicable data protection laws; that you will ensure that before doing so, the individuals in question are provided with a copy of this Notice and made aware of the fact that Vanguard will hold information relating to them and may use it for any of the purposes set out in this Notice; and where necessary that you will obtain the other individuals’ consent to Vanguard’s collection, use, and disclosure of their information as described in this Notice. Vanguard may, where required under applicable law, notify those individuals that they have been provided with their Personal Data and provide a copy of this Notice to them.
Direct Interactions with Vanguard: If you communicate with Vanguard by telephone, email, online chat, text message or any other form of communication, Vanguard may keep a record of that communication. In accordance with applicable law, Vanguard may also (after notifying you and, if required, obtaining your consent) record and monitor telephone calls for training, quality assurance, security, and customer service purposes.
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.
Automated Interactions: Where you have consented, we may collect data about you on our Site and through emails that we send to you, including whether you click on links in our emails. We use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further in our Cookie Notice.
Combining data:
We may combine this data with additional information that we have collected about you, including, where applicable, your name and other Personal Data. When we combine this data with Personal Data, we treat all of the combined information as Personal Data under this Notice. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Site and the effectiveness of our email communications and online advertising, as well as to identify Vanguard products and services that may be of interest to you.
For more information about how we and our service providers use information for analytics and advertising purposes, please see the section in our Cookie Notice titled: What cookies do we use and why?
What is the purpose and legal basis for processing your Personal Data?
We use your Personal Data for the purposes for which it was provided to us, including as described in this Notice and as required by law.
We will only collect, use, and share your Personal Data for these purposes where we are satisfied that we have an appropriate legal basis (or "ground") to do this.
The legal bases we rely on include Contract, Legal/Regulatory Obligation, Legitimate Interests, Consent, and, in limited cases, Public Interest. We have outlined these lawful basis and purposes in the table below.
Where we rely on legitimate interests, these include preventing fraud, improving our services and ensuring the security of our systems. We balance these interests against your rights and only process data where our interests are not overridden.
Where we process Special Categories of Personal Data or Personal Data relating to criminal convictions and offences, we only do so were permitted by applicable data protection law, including where necessary to comply with legal or regulatory obligations or for the prevention of fraud, financial crime and money laundering.
Personal Data categories |
Purposes for processing |
Legal basis for processing (GDPR) |
Data collected directly from you (including third-party details you provide) |
To establish and manage your relationship with us and deliver Vanguard products and services.
|
Contract – Art. 6(1)(b) |
Data collected directly from you |
To communicate with you, notify you about important updates or changes to Vanguard's products and services, and address relevant inquiries or complaints.
|
Legitimate interests – Art. 6(1) (f)
|
Data collected directly from you or provided by third parties |
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 laws.
|
Legal obligation – Art. 6 (1)(c). |
Data collected directly from you
Data from Communications with you
Automatically collected data |
For marketing communications, promotional purposes, or newsletters in accordance with applicable law.
|
Legal obligation – Art. 6(1)(a) or Legitimate interests – Art. 6(1)(f)
|
Data collected directly from you
Data from Communications with you
Automatically collected Data |
To create new products and services or improve our existing products and services;
|
Legitimate interests – Art. 6(1)(f)
|
Automatically collected data
|
To tailor the content, advertising and your Site experience
|
Consent – Art. 6(1)(a) |
To analyse Site usage and understand how services are accessed. |
Consent – Art. 6(1)(a) Legitimate Interests – Art. 6 (1)(f)
|
|
To support Site performance, analytics, navigation and improve and functionality.
|
||
Data collected directly from you Data from Communications with you
Survey collected data
Automatically collected data |
To protect Vanguard’s rights, prevent fraud and support security and compliance. |
Legal obligation – Art. 6(1)(c). and or Legitimate Interests – Art. 6(1)(f)
|
Survey collected data |
Conducting client satisfaction surveys and product research. |
Legitimate interests – Art. 6(1)(f)
|
Survey collected data
Automatically collected data |
For broader research and analytics.
|
|
Data collected directly from you or automatically collected data |
To enable sharing of content with third-party platforms (e.g. social media) |
Consent – Art. 6(1)(a) |
To provide enhanced client services and resolve complaints |
Legitimate interests – Art. 6(1)(f) & Legal obligation – Art. 6 (1)(c) |
|
To provide Open Banking Services (e.g. payments to Client Money Accounts). |
Contractual obligation – Art. 6(1)(b) |
|
To improve personalisation, investment outcomes and client engagement. |
Legitimate interests – Art. 6(1)(f) and/or Consent – Art. 6(1)(a) for personalised outreach |
|
To create content for social media, videos and website features. |
Consent – Art. 6(1)(a) |
Do we conduct automated decision-making using your Personal Data?
We do not make decisions about you that are based solely on automated processing, including profiling, which produce legal or similarly significant effects on you.
We may in limited cases, use automated tools to support certain or internal processes, such as detecting or preventing fraud, financial crime or to assess security risks. These tools help us identify potential issues but do not make final decisions without appropriate human involvement.
To whom do we disclose Personal Data?
We may disclose Personal Data to third parties for the purposes described in this Notice and as permitted by law. You may have the right object to certain types of processing of your Personal Data as outlined below:
Affiliates: We may share Personal Data with Vanguard Affiliates for the purposes set out in this Notice. Affiliates may contact you, in line with applicable law regarding Vanguard products and services.
Service providers: We disclose Personal Data to trusted service providers, who use it to perform tasks on our behalf. These include services such as supporting our Sites, administering accounts, sending communications and providing analytics, technology or professional services. These providers process Personal Data in accordance with applicable law and under our direct instructions.
Customer agents and representatives: Where covered by a legal basis for such processing, we may disclose Personal Data to your agents or representatives, including:
Legal and regulatory purposes: We may disclose information about you to comply with the law, judicial proceeding, court order, or other legal process, such as in response to a court order or 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 authorised to act.
Corporate Transactions: We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitisation, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, in accordance with applicable law.
Market research: We 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, in accordance with applicable law. Any Personal Data processed for market research is deleted as soon as it is no longer required, e.g. upon termination of the market research study/studies for which such data was collected or, if earlier, you objected to the processing of your Personal Data for such purpose.
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, X, LinkedIn. 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. These websites and services may also set and/or access a cookie on your device.
Competitions, contests, and promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Site or elsewhere, and if you choose to participate, we or third parties may request your name, address, telephone number, email address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations. In compliance with the relevant regulations, it may also be necessary to publish details of the winners of competitions in appropriate news media.
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 operates globally and, in some circumstances, your Personal Data may be transferred to, stored in, or accessed from countries outside the United Kingdom and the European Economic Area (EEA), including the United States.
Transfers from the UK: Where Personal Data is transferred from the UK to a country that is not recognised as providing an adequate level of protection under UK data protection law, we ensure appropriate safeguards are in place. These safeguards include the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as approved by the UK Information Commission.
Transfers from the European Economic Area: Where Personal Data is transferred from the EEA to a country that is not recognised by the European Commission as providing an adequate level of protection, we rely on the European Commission’s approved Standard Contractual Clauses.
In all cases, we assess the circumstances of the transfer and, where required, implement additional safeguards to ensure that your Personal Data continues to be protected to a standard essentially equivalent to that required under applicable data protection laws. You may request further information about the safeguards we use by contacting us using the details in the “Contact us” section.
We retain your Personal Data only for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. By law we have to keep basic information about our customers (including contact data, identity, financial and transaction data) after they cease being customers for legal and regulatory purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights in relation to your personal data, depending on the circumstances.
You can exercise your rights by contacting us using the details in the Contact us section. We may need to ask for additional information to verify your identity before responding. In certain cases permitted by law, we may charge a reasonable fee or refuse to act on your request.
If you are unhappy with how Vanguard has used your personal data, you can make a complaint by contacting us using the details in the Contact us section.
We encourage you to contact us first so that we have the opportunity to review and resolve your concern directly. This does not affect your right to make a complaint to the UK Information Commissioner’s Office (ICO) at any time.
If you make a data protection complaint, please provide enough information for us to understand your concern. We will acknowledge receipt of your complaint and investigate it without undue delay. We will keep you informed of the outcome.
The Site is 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 . You also may contact us by sending a message to:
Vanguard Asset Management, Limited
Attn: Data Protection Officer
25 Walbrook
London, GB EC4N 8AF
If you raise concerns about how we have handled your Personal Data, we may request additional details from you regarding your concerns, and we may engage or consult with other parties in order to investigate and resolve your issue. We will keep records of your request and any resolution of your issue.
We will post changes to this Notice on our Site along with the effective date of the changed Notice. We recommend that you review this Policy periodically. If we make a material change to this Notice, you will be provided with appropriate notice.
Revised June 2026