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 decline 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:

Performance and Analytics

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 analyse 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. 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. 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.

Advertising and Social

If you grant us your consent, we use "Advertising" and “Social” 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, please visit:

Network Advertising Initiative (NAI) opt-out page; and

European Interactive Digital Advertising Alliance (EDAA) opt-out page (available in 27 languages).

Although our Sites currently do not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above.

Cookie details

Category

Controller

Purpose

Duration

Performance and Analytics

s_vi #
s_cc
s_sq
s_fid
s_ukts
gpv_pn

Adobe Systems Software Ireland Limited

Used to track Vanguard site visitor activity, including storing unique user ID, whether cookies are enabled, date and time of visit, pages visited, links selected, and browser configuration.

For more details see:

https://www.adobe.com/privacy/experience-cloud.html

Session – two years

Advertising

IDE
NID

Google Ireland Limited

Used by Google to track user behavior across websites in order to serve relevant ads, and to determine when a user sees a Vanguard ad and then visits Vanguard’s site and takes action.

For more details see:

https://policies.google.com/technologies/cookies#types-of-cookies

Six months – two years

Social

lms_ads
lms_analytics
li_fat_id
UserMatchHistory

LinkedIn Ireland Unlimited Company

Used to identify LinkedIn members visiting Vanguard’s site and to store an indirect ID for LinkedIn members, for analytics and advertising services, including advertising to Vanguard site visitors when they visit LinkedIn.

For more details see:

https://www.linkedin.com/legal/l/cookie-table#thirdparty

30 days

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 Performance and Analytics, Advertising, and Social cookies as far as you provide your consent to these. You can change your cookie settings at any time though the preference indicator at the top of this page.

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 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 January 2021

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ESG