Vanguard Careers Privacy Policy

Scope of this Policy

The Vanguard Group (Vanguard) is one of the world’s largest and most respected investment management families of companies, with investment funds, offices, and affiliates in the United States, Europe, Australia, Asia, Canada, and Mexico.

Vanguard’s global headquarters are located in the United States.

Vanguard Careers, (the “Site”), is a website owned by Vanguard. At Vanguard Careers, persons interested in employment with Vanguard may browse and apply for open positions within the Vanguard family of companies.

This Privacy Policy solely governs the collection, use, disclosure, and transfer personal information (“information”) that we collect at the Site; this Privacy Policy does not apply to any other website operated by Vanguard.

By visiting this Site, applying for an open posting, or otherwise providing information to Vanguard through this Site, you consent to the collection, processing, use, disclosure, and transfer of information about you as set forth in this

Privacy Policy. Please also refer to the terms and conditions, which are incorporated herein by reference, for additional information related to your use of this Site.

Information Collection
We collect information directly from you and about you when you visit our Site, browse our open positions, create an account, and apply for employment with Vanguard; as follows:

Account Creation: If you would like to apply for an open position through this Site, then you must first create an account. You may also create and save your account even if you do not apply for an open position by verifying your account within the account verification email. During the account creation process, we request the following information from you: your e-mail address. We also ask you to create a password to access your account. Information you provide during the account creation process will be stored within your account profile.

Employment Application: The information that we require you to submit as part of your employment application through this Site varies depending on the particular position and the Vanguard company to which you are submitting your

application. If you would like to apply for an open position through this Site, we may collect the following, where permitted or required by law:

  • your full name
  • postal mailing address
  • preferred telephone number
  • e-mail address
  • work history
  • educational background
  • language skills
  • professional licenses (e.g., bar membership)
  • legal residency status
  • national identification number
  • tax identification number
  • prior application to Vanguard
  • personal references and their contact information

Third Party Information: During the employment application process, we may learn information about third parties, such as the name and contact information of your references.

Information that We Collect Automatically: We use cookies and other tracking mechanisms to collect information about you as you use our Site. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while other cookies are used to enable a faster log-in process or to allow us to track your movement through our

Site (e.g., analytical cookies). Specifically, we may collect the following information about your use of the Site via these technologies: your browser type and operating system; web pages you view; links you click; your IP address; and the length of time you visit our Site. We may use this information in the aggregate or we may combine it with information about you.

There are two types of cookies: session-based and persistent-based cookies:

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to identify you during asession or while you are logged into the Site. This allows us to process your application and requests and to verify your identity after you have logged in as you move through our Site.
  • Persistent Cookies. Persistent cookies may remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about visitors to our Site,which may be combined with other user information.

The cookies used on our Site are categorized as follows:

  • Strictly Necessary. Strictly Necessary cookies let you enter and move around the website and use essential features. Without these cookies, services and information you have asked for cannot be provided. We use these Strictly Necessary cookies primarily to identify you as having confirmed your eligibility to log in and use our website and to make sure you connect to the right service on our website when we make any changes to the way the website works. Accepting these cookies is a condition of using the website, so if you prevent these cookies, we can’t guarantee your use of our website or how the security on our website will perform during your visit.
  • Performance Cookies. Performance cookies collect information about how you use our website, such as which pages you visit and any errors you experience. These cookies do not collect any information that could identify you and areonly used to help us improve how our website works and understand what interests our users. We use these performance cookies primarily for analytics, to provide statistics on how our website is used.

Some of our performance cookies are managed for us by third parties. However, we don’t allow the third party to use the cookies for any purpose other than those listed above.

Disabling Cookies. Most web browsers automatically accept cookies, but, if you prefer, you may edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have your browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable their web browser’s ability to accept cookies will be able to browse the Site; however, some Site features may not function if you disable cookies.

How We Use the Information You Provide

We use the information that you submit through our Site for employment- related purposes. Specifically, if you apply for an open position through our Site, then we use information about you to process your application. Your application will be processed initially in the United States and provided to the appropriate Vanguard entity for evaluation.

We also may use information about you in the aggregate for statistical and research purposes, such as to understand how persons use our Site, to analyze traffic and activity, and to support user preferences. We also may use information about you as required by law.

How We Disclose Information

We do not use information collected from you for marketing purposes, nor do we disclose information to third parties for marketing purposes. We may disclose information about you as necessary to assist us in processing your application and as required by law as described in this section.

Third Party Service Providers: We may share information about you with third party service providers to assist us in processing your application.

In Response to Legal Process/To Protect Vanguard: We may disclose the information that we collect from you to comply with, the law, a judicial proceeding or court order, or other legal process, such as in response to a subpoena. We also may disclose the information that we collect from you if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of this Privacy Policy or our Terms and Conditions of Use.

Information Security

We have implemented commercially reasonable precautions to protect our Site and the information that we collect from loss, misuse, and unauthorized access, disclosure, and alteration. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.

Access and Correction of Information About You

You may modify information stored in your account profile by logging into your account and updating your profile information. If you would like to update information that you have submitted on your application, please contact Vanguard Employment,

Transfer of Information

Information about you will be transferred to, processed, and stored in the United States. By applying for a position online through this Site, you consent to the transfer of information about you to the United States.

Contact Us

If you have any questions about this Policy or you would like to make a complaint, please contact us at Vanguard Employment,

Changes to this Policy

This Privacy Policy is current as of the Effective Date set forth above below. If we make a material change to this Privacy Policy, we will endeavor to provide a notice to persons who have established account profiles by sending a notice

to the email address on record.

Effective date – November 3, 2017