Last Updated: November 12, 2021

The Vanguard Charitable Endowment Program of Malvern, Pennsylvania ("Vanguard Charitable" or "we" or "us") shares your concerns about maintaining the privacy of personal information collected in our recordkeeping systems and on the Internet. The following privacy policy (the "Privacy Policy") sets forth Vanguard Charitable's information gathering and dissemination practices for all Personal Data collected by us. The Privacy Policy applies to all individuals and organizations in contact with Vanguard Charitable and its employees, including potential donors, current donors, and those individuals authorized to access donor accounts pursuant to the Interested Party Account Access Authorization form (collectively, referred to herein as "you"), through the vanguardcharitable.org website (the "Site"), other means of contact in connection with the Site, including telephone and email, or when you otherwise communicate or interact with Vanguard Charitable. If you reside in Europe please refer to Annex 1, “European Data Privacy Laws” of this Privacy Policy as well, which includes additional rights in relation to your Personal Data.  By your use of the Site, you consent to be governed by this Privacy Policy. We may modify this Privacy Policy at any time. We will post this Privacy Policy, as amended, on the Site. Your continued use of the Site will constitute your agreement to the terms of our then-effective Privacy Policy. No other act, document, usage or custom will be deemed to amend or modify this Privacy Policy.

When you donate to Vanguard Charitable and/or have contact with its employees, including use of the non-public areas of the Site, you may provide us with (1) personally identifiable information, including your name, mailing and email addresses, telephone number, including a text-enabled cellular/wireless telephone number, user id, or other contact information in which you are identified or from which you can be identified; and (2) financial information specifically linked to your account (collectively, “Personal Data”).

As explained further under “Tracking Tools,” each time you visit the Site, we may automatically collect certain types of information. Some examples of automatic information we may collect are as follows:

• Your IP address, MAC address, browser type, operating system, device-identifying information, type of computer, and type of Web browser software, the specific webpages visited during your connection, and the domain name from which you accessed the Site.
   
• Information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data.
   
• We may use “cookies” of different types to recognize your computer. A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Site or other sites.
   
• We may use web beacons, match scripts, pixel tags or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, or links in the email utilized. In some instances, these technologies may allow us to match activities with particular users.

Vanguard Charitable respects your Personal Data and will not disclose it to any unaffiliated third party, except as described in this Privacy Policy in the following limited circumstances: 

1. as expressly authorized elsewhere by you or your authorized representative. Please note that permission from one account advisor or an interested party to share information with a designated representative of the Vanguard Group, Inc. or other authorized third parties applies to the entire account;
2. to comply with applicable laws, regulations, court orders or other valid legal processes, to protect the rights or property of Vanguard Charitable, to investigate or prevent fraud, and/or in responding to complaints or safety or security concerns;
3. in order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you or a transaction(s) on your account to companies, individuals, or groups that are not affiliated with Vanguard Charitable. For example, if you ask to transfer assets from another financial institution to Vanguard Charitable, we may need to provide certain information about you to that company to complete the transaction;
4. to service providers and advisors designated by Vanguard Charitable for the limited purposes of providing the applicable services, or for research and analysis or similar purposes to better serve you and/or the philanthropic community. For example, if you experience a technical problem, we may need to provide certain information about you or your account to one of our third-party technology vendors to diagnose or troubleshoot. Any third parties to whom Personal Data is disclosed will be bound by agreements between Vanguard Charitable and the authorized service providers that protect the confidentiality of your Personal Data; and/or
5. to any successor to Vanguard Charitable's business or any acquirer of Vanguard Charitable's principal assets.

Vanguard Charitable may use your Personal Data to help us better serve your philanthropic interests, to personalize your Site experience, to suggest Vanguard Charitable's services or educational materials that may be of interest to you, to better serve you in responding to your inquiries or requests, to enforce agreements with you and our policies, to administer the Site and communicate notices, updates and other information regarding the Site, or to provide you with other services in connection with your account.

Our website uses a variety of technologies to collect information that helps us understand how our Site is used. Cookies are tiny pieces of information that we ask your Internet browser to store and remember. You can set your browser to refuse cookies, but some portions of the Site may not work properly if you refuse cookies. We use "session" cookies to track your session (which is the time you are within the password-protected area of the Site). The session cookie lets us know that you have logged on, and it allows us to identify you as you move from page to page. For the password-protected area of the Site, it also acts as a timer; we log you out after a certain period of inactivity to guard against unauthorized access to your account information. Session cookies are strictly temporary and are deleted from your computer automatically when you log out.

A web beacon, also known as a pixel tag, is a tiny transparent image embedded in a web page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your computer. Web beacons allow us, directly or through 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.

In connection with access to, marketing of or use of the Site or our services, we may collect, either directly or through third-party service providers (including through use of cookies and web beacons), certain technical, navigational and other activity or device related information, such as the advertisement presented, IP address, operating system, device and browser type, the web page linked or visited, dates, times and durations of visits, location-based data or diagnostic location information, contextual information and demographic information. 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, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.

We may use third-party service providers to place advertisements for us on other sites, help us measure brand awareness and the effectiveness of our online advertising and for other marketing purposes, and to improve or deliver our services. We and our service providers may use data collected on the Site or when you open emails from Vanguard Charitable, together with other information we and/or they have or collect about you or your Vanguard Charitable relationships, to improve or deliver our services or for marketing purposes, including serving ads to you on other sites as you browse the web. We do not provide any personally identifiable information about our users to these service providers unless such service providers are required to anonymize such information in connection with its authorized use and to maintain the confidentiality of any personally identifiable information. All Personal Data collected on the Site is used exclusively by Vanguard Charitable, or by our service providers on our behalf, and is not shared with unaffiliated third parties (except as otherwise described in this Privacy Policy).

Our use of cookies and web beacons is limited. We don't use them to pull other data from your hard drive or to view data in cookies or other similar data files created by other sites. We will not share the information in these files or give others access to it--except in accordance with this privacy policy. You can change your cookie preferences by activating the setting on your web browser that allows you to delete or refuse the setting of cookies. If you delete or reject cookies, you may be unable to register for or log in to the Site, some pages of the Site might not function properly, and the Site experience will not be tailored to you from visit to visit.

Vanguard Charitable or its designated service providers may collect and share non-personally identifiable information about the users of the Site and participants in other activity in aggregate form with third parties, including our vendors, for statistical analysis purposes, to improve the content or the services offered through the Site or for other commercially reasonable business purposes.

In some situations, we may use forms of online communication that are intended to provide security and privacy when you access or amend your account information, initiate online transactions, or send "secure" messages. Although Vanguard Charitable takes reasonable precautions to assess the reliability of such technology, it relies on the statements of the vendors of those products and services as part of its security evaluation. Vanguard Charitable does not warrant against any damage, loss or unauthorized disclosure of information even if the functionality of the Site or any services or communication are labeled as, or otherwise implied to be, "secure."

We also restrict access to your Personal Data to those authorized Vanguard Charitable staff members (associates) or Vanguard Charitable's designated service providers who have a need for these records. As an added measure, we endeavor not to include Personal Data in non-secure emails that we may send you via the Internet. Please note that although Vanguard Charitable has endeavored to create a secure and reliable Site for users, and employs reasonable precautions to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction, the confidentiality and security of any communication or material transmitted to or from the Site or in other paper and electronic communication cannot be fully guaranteed.

We may transfer your Personal Data into and/or out of the United States, and you hereby consent to any such transfer.

We maintain a social media presence, such as a Twitter feed. You can interact with us through social media, such as by posting content and sharing material from our Site, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at social media sites. We may use the information for the same types of purposes we describe throughout this Privacy Policy. Your use of social media sites is primarily governed by the site operators’ privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.

Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of such information and the names and addresses of those businesses with which we shared such information for the immediately prior calendar year (e.g., requests made in 2016 will receive information regarding 2015 sharing activities).

To obtain this information from us please send an email message to questions@vanguardcharitable.org with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, Vanguard Charitable and the Site do not recognize DNT.

Under Age 13

Our Site is not specifically directed toward children, and we do not knowingly collect Personal Data from persons under the age of 13 on our Site without verifiable parental consent. If a child has provided us with Personal Data, a parent or legal guardian of that child may send an email message to questions@vanguardcharitable.org with “Request for Child Information Removal” on the subject line and the name and age of the child in the body of the message. We will then make reasonable efforts to delete the child’s information from the database that stores information for the Site, provided that we may retain and use any information in connection with the operation of the account. You can update or remove information, which you have submitted, through your account.

Under Age 18

Minors under 18 years of age may have the Personal Data that they provide to us through the Site deleted by sending an email to questions@vanguardcharitable.org requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

Vanguard Charitable does not endorse, and is not responsible for, the privacy practices or the content of any third-party websites, including those linked to and from the Site. If you have any questions regarding this Privacy Policy or you would like to review, update, or remove your Personal Data, you may contact us. Please note that complete removal may not be immediate, however, and in some instances, archival copies may be impossible to delete, and Vanguard Charitable may retain a copy of Personal Data, in accordance with this Privacy Policy, for commercially reasonable business purposes, including to enforce agreements with you and our policies.

Email:

questions@vanguardcharitable.org

Phone:

888-383-4483

Fax:

866-485-9414

Mailing address:

Vanguard Charitable

P.O. Box 9509

Warwick, RI 02889-9509

If you are a European resident, you have certain rights in relation to your Personal Data under the applicable European data privacy laws. This section only applies to such users. Under applicable European data privacy laws, Vanguard Charitable is the data controller. We collect Personal Data from sources such as public registers, social media, publicly accessible websites and also pay for access to data subscription services such as Wealthfront.

Rights to Control Personal Data

Applicable European data privacy laws gives certain users the right to access their Personal Data. Your right of access can be exercised in accordance with the European data privacy laws. If you would like to request a copy of your Personal Data being held by us, or request that it is deleted or to update and/or correct your Personal Data or request that we provide a copy to another data controller of your Personal Data that you have provided to us, please contact us. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request. There are certain exemptions and restrictions of these rights under the European data privacy laws that enable personal information to be retained, processed or withheld from access and we will inform you of these if applicable. If you would like to exercise any of these rights, please use the contact information in the main Privacy Policy.

We use your Personal Data for the following key purposes:

• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications. Such communications are designed to make your experience of our Site more efficient and may include, but are not limited to: communications about our organization and other notifications including important news that could affect your relationship with us. Where required under applicable data privacy laws, we will not send you marketing communications without your prior consent; 
• for legal purposes: we may use and share Personal Data for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or subpoenas or for litigation purposes;
• for our legitimate interests and those of a third party: we may use your Personal Data to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests;
• for our business purposes: we may use your Personal Data to help us manage the objectives of our organization;
• for other purposes: subject to applicable law, we may use your Personal Data for additional purposes in connection with the Site or our organization, where you have provided your prior consent

International Transfers

Your Personal Data may be transferred to the US (which may have less stringent data privacy laws compared to those in your country of residence) and we also transfer your Personal Data to the recipients described in this Privacy Policy including those recipients located in countries which may also have a less stringent standard of data privacy laws compared to those in your country of residence. Where this occurs, you acknowledge and where required, consent to such transfer.

Sharing your Personal Data

We share your Personal Data with third parties to help us use your Personal Data, as described in the above policy and in addition, we may need to share your Personal Data with our professional tax, legal, audit or financial advisors. We may also share your Personal Data when we receive requests for information in the context of legal disputes, investigations regulatory inquiries or similar requests.

Tracking Tools (“Cookies”)

Please refer to the section entitled “Tracking Tools" (e.g. cookies) and Anonymized Data” in the Privacy Policy for details of cookies used to collect data. Please note that if you choose to block or delete cookies, certain features of our Site may not operate correctly. For more information, see www.allaboutcookies.org.

Retention of Personal Data

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and applicable legal requirements.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Complaint Process

If you have any concerns regarding how we are handling your Personal Data, please contact us. We will strive to deal with your concerns promptly. If you wish to complain about the handling of your Personal Data outside of Vanguard Charitable, you have the right to raise a complaint with a supervisory authority in your country of residence if applicable under European data privacy laws.