Vanguard 403(b) Services Program Privacy Policy (Vanguard)

Our commitment to our customers 

Under the Vanguard 403(b) Services Program, The Vanguard Group, Inc. (“Vanguard”) provides recordkeeping services to 403(b) retirement plans through an arrangement with Newport Group, Inc.  Newport Trust Company (“Newport Trust”), a subsidiary of Newport Group, Inc. that is not affiliated with Vanguard, provides custodial services to those same 403(b) retirement plans.  Vanguard and Newport Trust both understand the importance of safeguarding their customers’ financial assets and protecting their personal and financial information.  This privacy policy is provided by Vanguard, on our own behalf and that of our service providers (collectively, “Vanguard” or “we”),and describes how we collect, use, share, and protect customers’ information.  Newport Trust provides a separate policy that describes how it collects, uses, shares and protects its customers’ information through the Vanguard 403(b) Services Program.  Newport Trust’s privacy policy can be located at https://secure.newportgroup.com/entfiles/docs/NTC_Privacy_Policy_Final_updated_7202018.pdf

You trust Vanguard to protect your assets and your data. Because your personal and financial data are your private information, we hold ourselves to the highest standards in their safekeeping and use.

This means, most importantly, that Vanguard does not sell personal information to anyone

Instead, Vanguard uses the personal information that is provided to us primarily to complete transactions, to make our customers aware of financial products and services that we offer or sponsor, to improve upon our product and service offerings, and to provide education related to retirement plans and financial goals.

The personal information we collect about our customers 

In order to provide 403(b) retirement plan recordkeeping and administration services, we need to collect or receive certain personal information relating to the 403(b) plan and its participants, including, among other things, a participant’s name, address, Social Security or taxpayer identification number, employee identification number, phone number, e-mail address, date of birth, and information related to accounts at other institutions (“personal information”). The personal information we collect may be transferred to or stored by Vanguard or our service providers in the United States or elsewhere, as permitted by law. 

Vanguard may collect personal information from a participant or from a plan sponsor, its representatives, and third-party service providers. For example, we may collect personal information when a plan participant requests literature or a transaction that involves Vanguard or one of the Vanguard-affiliated companies, and when a plan participant enters information into an online form or application. 

We may combine the personal information collected on our website with personal information collected in other contexts. This may include information collected online, such as through email exchanges with a plan participant, or from offline sources, such as information that we collect when a plan participant enrolls in a plan or calls Vanguard. 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 services to you. 

How we handle personal information 

Vanguard does not sell personal information to third parties. We use this information primarily to provide financial products and services and to raise awareness about other services we offer. We may also use or share information in the following situations: 

Cookies, web beacons, and online privacy  

Our concern for our customers’ privacy naturally extends to plan participants and plan sponsors who use our 403(b) website, vanguard403bservices.com. Our website uses some of the most secure forms of online communication available, including data encryption, transmission encryption, and user names and passwords. These technologies provide a high level of security and privacy for customers accessing their account information, initiating online transactions, or sending secure messages. 

Our website uses 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 site is used. Specifically, when you visit our website, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including: 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; webpages you view; links you click; searches conducted on the site; the internet protocol (IP) address used to access our site; your general geographic location ((e.g., your city, state, or ZIP code); and the website visited before our site. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We may also analyze this information, with the assistance of our service providers, to improve our web design and functionality, to enhance our ability to serve customers, 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, 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 recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our website. This helps us to provide you with a useful experience when you browse our site and also allows us to improve our site. 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. 

If you are concerned about having cookies on your computer or other device, 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 website may not operate correctly. For further information about deleting or blocking cookies, please visit allaboutcookies.org/manage-cookies/. 

Web beacons:Our website and the emails that you receive from Vanguard may use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is a tiny transparent image embedded in a webpage or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.

Vanguard403bservices.com offers customized features that require our use of cookies and web beacons. Certain sections of our website require cookies to be enabled to support site performance and provide enhanced authentication. For example, cookies enable us to personalize and improve your user experience and help enhance site navigation. Cookies also help us to understand how people use our site so that we can improve site structure, functionality, and content. Web beacons allow us, directly or through our third-party service providers, to collect information used for website analytics, such as how many users have visited particular pages or downloaded documents on our site, or how frequently users search for a particular term on our site. However, our use of these cookies and web beacons is limited. We do not use them to pull other data from your hard drive, to gain confidential or sensitive information about you, or to view data in cookies or other 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 needs and as described in this privacy policy. 

We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information about 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 any links in the email.  These technologies enable us to gauge the effectiveness, relevance, and value of our email communications.

For customers who have registered for secure access to their accounts on vanguard.com and vanguard403bservices.com, we are able to combine the information we collect about their usage of our website during a secure (logged-on) session with other information we know about them, such as any account transactions they may conduct during a web session. We can also identify your computer or device on each visit to our website, even if you do not log on, 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 website, as well as to identify Vanguard products and services that may be of interest to you. 

Our website includes links to third-party sites or information that we think may be of interest to you. When you click on these links and leave our website, our site’s 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. 

Third-party analyticsWe partner with third parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our website. In particular, our site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. Importantly, we do not collect any personal information through Google Analytics.  The information generated about your use of our website 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

Although our website currently does 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 policy. 

How we safeguard personal information 

Within Vanguard, we restrict access to personal information to those Vanguard and service provider employees who need to know the information in order to perform their jobs, such as servicing accounts, providing requested information, or notifying plan participants of new products and services. To protect this information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology. 

What you can do  

For your protection, we strongly recommend that you do not provide your account information, user name, or password to anyone. You should regularly change your account password for your online account, and this password should be unique to this account and not used with any other accounts.  If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately. 

We'll keep you informed 

This privacy policy is subject to change.  You should review it periodically. If we make changes, we will revise the "last updated" date and post the revised policy on vanguard403bservices.com. 

Revised 7/20/18