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. This Privacy Notice (“Notice”) explains how we collect, use and share your Personal Data when you use this website (the “Site”).
For UK Personal 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 the purposes of this Notice, “Personal Data”, or “Personal Information”, means any information alone or together with other information which 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 from which the individual can be identified.
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.
Vanguard may collect Personal Data directly from you when you request information, invest with us, or use our Sites. We may combine this information with data collected in other contexts; online (including email exchanges), from public sources, or offline (such as when you open an account or contact customer service). Combined information will be handled in line with this Notice.
If you choose not to provide certain information, we may be unable to offer some products or services. If we or fraud‑prevention agencies identify a fraud or money‑laundering risk, we may refuse or stop providing services.
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.
We may combine data we collect across channels including Site usage, email interactions, and offline information. When combined with Personal Data, all such information is treated as Personal Data under this Notice. We may use this combined data to assess the usefulness of our Site, communications, and advertising, and to identify Vanguard products or services that may be of interest to you.
For information on analytics and advertising technologies, please refer to the section titled “What cookies do we use and why?” in our Cookie Notice.
Third‑Party Information Collection:
We may collect Personal Data from you about other individuals connected to your account. If you provide information about authorised signatories, dependents, relatives, beneficiaries, employees, agents, or other representatives, you confirm that you do so in compliance with applicable data protection laws. You also confirm that, before sharing their information, you have provided them with a copy of this Notice, informed them that Vanguard will hold and use their Personal Data for the purposes described in this Notice, and obtained their consent where required.
Where required by law, Vanguard may notify those individuals that we have received their Personal Data and provide them with a copy of this Notice.
We use your Personal Data for the purposes for which it was provided, for the activities described in this Notice, and as required by law.
We will only collect, use, and share your Personal Data where we have an appropriate legal basis to do so.
The legal bases we rely on include Contract, Legal/Regulatory Obligation, Legitimate Interests, Consent, and, in limited cases, Public Interest.
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 do so only where 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 |
Purpose of Processing |
Legal Basis (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, provide updates, and respond to enquiries or complaints. |
Legitimate interests – Art. 6(1)(f) |
Data collected directly from you or provided by third parties |
To comply with record‑keeping reporting, anti-money laundering, fraud, tax, and other legal requirements. |
Legal obligation – Art. 6(1)(c) |
Data collected directly from you
Data from Communications with you
Automatically collected data |
To send permitted marketing communications, promotions and newsletters. |
Consent – 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 improve or develop new products and services. |
Legitimate interests – Art. 6(1)(f) |
Automatically collected data |
To personalise 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) or Legitimate interests – Art. 6(1)(f) |
|
To support Site performance, analytics, navigation, and functionality. |
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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 data |
Conducting client satisfaction surveys and product research. |
Legitimate interests – Art. 6(1)(f) |
Survey and automatically collected data |
To conduct 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) |
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 internal processes, such as detecting and preventing fraud, financial crime, or assess security risks. These tools help us identify potential issues but do not make final decisions without appropriate human involvement.
We may disclose Personal Data to third parties for the purposes described in this Notice, and only as permitted by applicable law. You may have the right to 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 perform services on our behalf, 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 instructions.
Customer agents and representatives
We may share Personal Data with your authorised agents or representatives, including:
We may disclose Personal Data where necessary to protect the rights and property of Vanguard or its Affiliates, to obtain legal advice, establish or defend claims, prevent fraud, ensure security, or protect others. We may also share information to comply with laws, court orders, regulatory requests, or to support crime prevention, including identity verification and anti‑money‑laundering checks. Fraud‑prevention agencies may share your data with law enforcement.
Corporate transactions
We may disclose Personal Data in connection with a licensing arrangement, merger, acquisition, financing, restructuring, bankruptcy, or other corporate transaction, in accordance with applicable law.
Market research
We may share limited contact information with market‑research firms or Affiliates to assess our services and client experience, such as for client satisfaction surveys or product‑related focus groups.
Third‑party websites and social‑media tools
Our Sites may allow you to share content or interact with third‑party platforms (e.g., LinkedIn, X, Facebook) If you use these features, your information may be shared with those platforms and their users. These third‑party services operate under their own privacy policies, not this Notice.
Competitions and promotions
If you choose to participate in competitions, contests, or promotions, we or third‑party agencies may collect information needed to confirm eligibility or comply with regulatory requirements. Details of winners may be published as legally required.
Aggregated information
We may share aggregated, non‑identifiable information (e.g., usage statistics) for regulatory reporting, marketing, or analytical 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 necessary to fulfil the purposes for which it was collected, including to meet our legal, regulatory, accounting, and reporting obligations.
In determining appropriate retention periods, we consider the nature, sensitivity, and volume of the Personal Data, the purposes for which we process it, the risk of harm from unauthorised use or disclosure, and applicable legal and regulatory requirements.
As a general guide:
• account and investment records are typically retained for the duration of the client relationship and for a period afterwards in accordance with regulatory and legal requirements;
• transaction, anti‑money laundering, and financial crime records are retained for periods required by law;
• marketing and preference data is retained until you withdraw your consent or object to receiving such communications.
Where Personal Data is no longer required, it is securely deleted or anonymised. Anonymised data may be retained for research, statistical, or analytical purposes and will no longer identify you.
Further details of our retention periods are set out in our internal retention schedule. You may request additional information by contacting us using the details in the “Contact us” section.
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 Sites are not directed to individuals under the age of 18, and Vanguard does not knowingly collect Personal Data directly from children through the Sites.
We process Personal Data relating to individuals under the age of 18 only where this is necessary to provide specific products or services intended for them, such as Vanguard Junior ISA accounts. In these cases, we generally collect and process children’s Personal Data via a parent or legal guardian who holds parental responsibility and who acts on the child’s behalf.
As children grow older, we may provide them with information about how their Personal Data is used in a manner appropriate to their age and understanding.
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 may also contact us by sending a message to:
Vanguard Asset Management, Limited
Attn: Data Protection Officer
4th Floor The Walbrook Building
25 Walbrook
London EC4N 8AF
We will post changes to this Notice on our Personal Investor Site along with the effective date of the changed Notice. We recommend that you review this Notice periodically. If we make a material change to this Notice, you will be provided with appropriate information.
Revised: June 2026