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VIGM S.A. de C.V. Asesor en Inversiones Independiente

Privacy policy

 

Introduction

VIGM S.A. de C.V. Asesor en Inversiones Independiente ("Vanguard Mexico"), The Vanguard Group, Inc., and Vanguard affiliated companies (collectively, "Vanguard," "we," or "us," unless necessary to distinguish among affiliates, which are referred to as the "Vanguard Affiliates") value the privacy and security of your information. In this privacy policy ("Policy"), we describe how Vanguard collects, uses, and transfers information collected by Vanguard, including on websites operated in Mexico on which this Policy is posted (the "Sites"). For a complete list of Vanguard Affiliates, please click here.

By visiting and using the Sites, clicking "I agree," "Accept," or any other button or taking any action indicating your acceptance of this Policy, or otherwise voluntarily providing information to Vanguard through the formularies and means offered for specific purposes, you consent to the collection, processing, use, and transfer of information about you as set out in this Policy and the specific privacy notices included in the corresponding formats, including transfers to third parties and other countries. Your use of our Sites or related services, and any dispute over privacy, is subject to this Policy and our Terms and conditions of use, including applicable limitations on damages and the resolution of disputes.

The information collected on the Sites is controlled by Vanguard Mexico, Pedregal 24, 15th Floor, Molino del Rey, C.P. 11040 Miguel Hidalgo, CDMX, Mexico, and The Vanguard Group, Inc., headquartered in the United States at 100 Vanguard Boulevard, Malvern, Pennsylvania 19355-2331 and can be reached by mail at P.O. Box 1110, Valley Forge, PA 19482-1110. This information may be transferred to, and therefore controlled by, the Vanguard Affiliate located in your country of residence or with which you are or may be dealing directly. As discussed below in the section titled Cross-border transfer of information, information that we collect through or in connection with the Sites may be transferred to and processed in the United States or another jurisdiction outside your country of residence, which may have less stringent data protection laws than in your country of residence; in all cases Vanguard is bound to comply with this Policy.

 Information collection
   What Personal Information do we collect?
   What Personal and Other Information do we collect automatically?
Use and transfer
   How do we use Personal and Other Information?
   To whom do we transfer Personal and Other Information?
Third-party analytics and Interest-Based Advertising
Cross-border transfer of information
Personal Information quality
Information security and retention
Choices, access, and correction of information
Children's privacy
Contact us
Changes to this Policy

 

Information collection

Vanguard may collect, process, use, and transfer both Personal Information and Other Information. For purposes of this Policy, "Personal Information" is any information that alone or together with other information in Vanguard's possession relates to an identified or identifiable natural person, such as name, phone number and email address. "Other Information" is any additional information that is not Personal Information. In this section, we describe our information-collection practices, including the types of Personal and Other Information that we collect. In subsequent sections of this Policy, we describe how we use and transfer Personal and Other Information.

We may combine the Personal and Other Information we collect directly from you with information collected from or about you in other contexts, such as on the Sites. This may include information collected online, such as through our email exchanges with you; from publicly available sources, such as your company website if you are a financial adviser; from the registrar for our exchange-traded funds; or from offline sources, such as information that we collect when you call customer service or establish a business relationship with us. 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 products or services to you.

 

What Personal Information do we collect?

Vanguard may collect the following Personal Information from or about you:

Personal Information we collect directly from you, such as when you request information from us, invest with us, or register to use the Sites: Vanguard may collect and maintain Personal Information about you, and about any person or entity on whose behalf you are acting, that you provide to us, such as when you register to use the Sites, obtain a product or service from Vanguard, request information or materials from us, or otherwise interact with us or our Sites. The types of Personal Information we collect vary based on your particular interaction with us, but could include:

  • Your name, company name, and primary role or title;
  • Postal mailing address;
  • Telephone and fax numbers;
  • Email address;

Personal Information: Depending on the type of service, and to the extent permitted by law, we may collect the following Personal Information from you or about you when you establish a business relationship with Vanguard on behalf of yourself or another individual or entity:

  • Full name, date of birth, gender, and contact details, which may include mailing address, email address, and telephone and fax numbers;
  • Tax identification number and bank account details, if such information is needed for the purpose of the business relationship;
  • Employment details, which may include annual salary;
  • Amounts and investment choices;
  • Details about authorized signatories, agents, or representatives;
  • Copies of any relevant trust deeds, partnership agreements, constitutions, or articles of association;
  • Details of services you are interested in and about your investment needs;
  • Information about employees, agents, or other representatives of a client or prospective client, if such information is needed for the business relationship; and
  • Other information in connection with your business relationship with Vanguard.

All financial data shall be collected, processed and used only for the purpose of fulfilling obligations arising from the legal relationship between Vanguard and you.

We do not collect any sensitive Personal Information from you.

In addition, we may also collect Personal Information from third parties authorized to disclose your Personal Information, such as from your employer or from companies that provide identification verification services.

Information about third parties: By disclosing information about authorized signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you have the consent of those parties to such collection, use, and transfer of their information as described in this Policy and that you have made this Policy available to those third parties.

Information from telephone, email, online chat, or text message communications with Vanguard: If you communicate with Vanguard by telephone, email, online chat, or text message, Vanguard may keep a record of that communication. In accordance with applicable law, Vanguard also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.

Information contained in 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.

 

What Personal and Other Information do we collect automatically?

Our Sites use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect Personal and Other Information that helps us understand how our Sites are used. Specifically, when you visit the Sites, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, 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, state, postal code, or metropolitan region); and the website visited before our Sites. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. To learn more about how our Sites use cookies, please visit the Vanguard Cookie Policy.

  • 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 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 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, 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 computer. 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 the Sites may not operate correctly. For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/. Information about how to opt out of the use of cookies for certain purposes (such as interest-based advertising) is discussed below in the section titled Third-party analytics and Interest-Based Advertising.

 

  • Web beacons: The Sites or 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 an electronic file that usually consists of a single-pixel image. 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 such as 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 on any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Vanguard relationships.

We may combine Other Information with additional information that we have collected about you, including, where applicable, your name and other Personal Information. When we combine Other Information with Personal Information, we treat all of the combined information as Personal Information. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Sites and the effectiveness of our 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 below titled Third-party analytics and Interest-Based Advertising.

 

Use and transfer

How do we use Personal and Other Information?

We use the Personal and Other Information that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes. Such necessary purposes are as follows:

Primary purposes:

  • To establish a business relationship with us, to fulfill the terms of any agreement you have with us, and to otherwise provide Vanguard's products and services to you;
  • To communicate with you, notify you about important updates or changes to Vanguard's products and services, and address relevant inquiries or complaints;
  • To comply with our legal obligations and protect our legal rights, to comply with record-keeping, reporting, and tax obligations under applicable law (for example: corporations, tax, investments or securities, and anti-money laundering laws);
  • To count and recognize visitors to the Sites and various Site features and better understand how users access and use our Sites and Vanguard products and services;
  • To create new products and services or improve our existing products and services;
  • To support Site performance, perform Site analytics, enhance Site navigation, and improve our web design and functionality; and
  • For research and analytical purposes.

In addition, the Personal and Other Information we collect may be used, if you do not oppose or opt-out as explained in this Policy and so long as permitted by law, for the following voluntary/secondary purposes:

Secondary purposes:

  • For marketing and promotional purposes, in accordance with applicable law. We may use your Personal Information, such as your email address, to send you news and newsletters, or to otherwise contact you about Vanguard products or information we think may be of interest to you. Although we hope you will find our promotional communications of interest, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication; and
  • To tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled Third-party analytics and Interest-Based Advertising, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Sites.

 

To whom do we transfer Personal and Other Information?

We may transfer Personal and Other Information to third parties for the following purposes, as permitted by law.

Affiliates: We may transfer Personal and Other Information to Vanguard Affiliates, which have substantially the same internal privacy policies as we do, for the purposes described in this Policy. Vanguard Affiliates may contact you by email, in accordance with applicable law, to make you aware of Vanguard's product and service offerings. Vanguard maintains centralized servers and systems in the United States and may maintain servers and systems elsewhere. Vanguard also may subcontract the processing of your Personal and Other Information to, or otherwise share your Personal and Other Information with, other third parties acting on behalf of Vanguard, in the United States, Mexico, or countries other than your country of residence. As a result, the Personal and Other information that we collect through or in connection with the Sites is transferred to and processes in the United States (or other countries) by Vanguard for the purposes described above, pursuant to methods permitted by the laws of your country of residence for ensuring that information about you will be adequately protected pursuant to this Policy.

Service providers: We transfer Personal and Other Information to our service providers, who use it to perform tasks on Vanguard's behalf and for the maintenance or fulfillment of the legal relationship between Vanguard and you. These service providers help us manage and improve the Sites, and provide Vanguard services. Our service providers may collect, process, and retain information about you, in accordance with the laws of your country, directly on behalf of Vanguard. Vanguard's service providers include:

  • Any organization involved in providing, managing, or administering the Sites, related systems, or other Vanguard services, such as administrators, mail houses, email senders and providers, and technology service providers; and
  • Vanguard's auditors, consultants, legal advisers, and other professional advisers.

Legal purposes: We may use and disclose Personal and Other Information about you as we believe reasonably necessary to protect the rights and property of Vanguard, including to establish legal claims or defenses, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of Vanguard Affiliates, to protect against fraud and abuse, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order 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. We may use and transfer information about you as set forth and authorized in the corresponding applicable data protection law.

Regulatory Reporting: From time to time, Vanguard may share aggregated information about users of the Sites or Vanguard's products and services, such as sharing reports on the usage of the Sites or Vanguard's services for regulatory reporting.

Sale or other transfer of the company: We reserve the right to transfer information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitization, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, for the maintenance or fulfillment of the legal relationship between Vanguard and you, as permitted by applicable law. To guarantee business continuity and provided that all legal requirements and data processing principles are met

Customer agents: At your direction, we may transfer Personal Information to your agents or representatives. Your agents and representatives may act as an independent controller based on their relationship with you. For purposes of this Policy, Vanguard considers the following categories of persons to be customer agents:

  • Your financial adviser;
  • Any administrator or trustee for a fund or trust to which your investment balance is to be transferred or rolled over;
  • Your legal representative or attorney; and
  • Other financial institutions that hold an account in your name or on which you are authorized to act.

Market research: We also may provide information to market research companies 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; when doing so, we comply with all the required legal formalities. For example, we may run client satisfaction surveys or run focus groups on proposed products.

Direct sharing through third-party websites and services: The Sites may enable you to share information directly with websites or online services operated by third parties. For example, the Sites contain features that allow you to share articles or content through Facebook, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to users of those websites or services and the public more generally. These websites and services may also set and/or access a cookie on your device. Because these third-party websites and services are not operated by Vanguard, we are not responsible for the content or practices of those websites or services. The collection, use, and transfer of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Policy.

Competitions, contests, and promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Sites or elsewhere, and if you choose to participate, we or third parties acting on our behalf 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.

Third-party service providers for marketing purposes: We transfer Personal and Other Information to our marketing service providers. These service providers help us manage and improve our marketing strategies and campaigns. Our service providers may collect, process, and retain information about you, in accordance with the laws of your country, directly on behalf of Vanguard.

In the event that you do not agree with any of the transfers of Personal Data and Other Data established in this section, you may request that they not be carried out, within the limits permitted by the applicable regulation, by exercising your ARCO rights.

 

Third-party analytics and Interest-Based Advertising

We partner with third parties to collect the Personal and Other Information discussed above to engage in analysis, auditing, research, and reporting. When you visit our Sites, 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 the Sites. We use these cookies to identify you as having confirmed your eligibility to enter and use our Sites, and to make sure you connect to the right service on our Sites when we make any changes to the way the Sites work. These cookies are also used to help us improve how our Sites work and understand what interests our users, and for error management, to help us improve our Sites by measuring any errors that occur. In particular, the Sites use Adobe Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of the Sites may be transmitted to and stored by Adobe Analytics on servers outside your country of residence. You may opt out of the use of cookies by Adobe Analytics here.

We also partner with third party service providers to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (Interest-Based Advertising, such as Google Ads) and to help us measure brand awareness and the effectiveness of our online advertising. These third parties may 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 or when you open emails from Vanguard, together with other information we have about you and your Vanguard relationships, to serve Vanguard ads to you on other sites as you browse the web. For example, third parties may use the fact that you visited the Sites to target ads for Vanguard products and services to you on non-Vanguard websites. In addition, our third-party advertising providers might use information about your use of the Sites to help target non-Vanguard advertisements based on your online activity in general.

For more information about Interest-Based Advertising and how to opt out, please visit:

Although our Sites currently do 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.

 

Personal Information quality

Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Information collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by Vanguard, you should contact us at the address provided in the Contact us section below.

 

Information security and retention

We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with applicable law.

Vanguard retains Personal Information for as long as necessary to provide our services to you, to fulfill the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy. We are obliged to retain certain information to ensure accuracy and for legal, regulatory, fraud prevention and legitimate business purposes.

The Sites may contain links to sites operated by partner networks, advertisers, and other companies not affiliated with Vanguard. Vanguard does not sponsor or endorse the linked sites or any products or services offered by them. If you follow a link to any of these sites, you'll be subject to the site's privacy policy, which you should read and understand before using the site or its products or services.

 

Choices, access, and correction of information (ARCO Rights)

We provide you with the ability to access, review, rectify, correct, cancel, delete, oppose, or inquire about information that we hold about you, as required and permitted under applicable law. You also may have a right to oppose or limit the collection and processing of your information as described in this Policy, or to revoke your consent as permitted by applicable law. Please bear in mind that we may be unable to provide services to you if you oppose the processing or if you revoke consent.

If you would like to access, review, rectify, correct, cancel, delete, oppose, or inquire about your information, place limitations on the collection or processing of your information, or revoke your consent, please send us a request at the address or email provided in the Contact us section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, rectify, correct, cancel, oppose, or delete. Please also make sure to include: (i) a copy of a governmental identification that confirms your identity; (ii) an email or mailing address to send you our answer; (iii) the right you would like to exercise; (iv) information that facilitates locating your Personal Information; (v) if you would like to correct or update your Personal Information, indicate what the correction should be. We will provide you with an answer letting you know if your request is acceptable or not within twenty business days following the receipt of your request. If your request is acceptable, you will be able to effectively exercise your right within fifteen business days following the receipt of the answer we sent you. We will provide you access to your Personal Information via email or physically, at the choice of Vanguard. Please note that we may need to take additional steps, such as to verify your identity, before we can grant your request. As permitted by law, we will notify you of the basis for any denial of your request.

If you would like Vanguard to stop sending promotional communications to your email address, you may opt out of receiving them by following the "unsubscribe" instructions at the bottom of each communication.

You may opt out of the use of your information for analytics and online interest-based advertising by following the steps detailed above in the section titled Third-party analytics and Interest-Based Advertising.

 

Children's privacy

The Sites are 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 Sites or sending any information about themselves to anyone over the Internet.

 

Contact us

If you have any questions relating to this Policy, 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 Mexico

VIGM, S.A. de C.V. Asesor en Inversiones Independiente
Attn: Data Protection Officer
Pedregal 24, 15th Floor
Molino del Rey
México City, 11040
México
+52 55 91567529

If you raise any concerns about how we have handled your Personal Information, we may request additional details from you regarding your concerns, and may need to 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.

 

Changes to this privacy policy

We will post changes to this Policy on our Sites along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, we will endeavor to provide you with notice by contacting you at the email address on record or, where permitted by law, by posting on this Site.

Effective October 2023