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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, 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").
Disclosure and Use of Personal Data
(1) as expressly authorized elsewhere by you or your authorized representative. Please note that permission from one account advisor to share information with a designated representative of the Vanguard Group, Inc. 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, 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.
Tracking Tools (e.g., "cookies") and Anonymized Data
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.
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."
Access to Personal Data
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.
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 email@example.com 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 e-mail 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.
If a child has provided us with Personal Data, a parent or legal guardian of that child may send an email message to firstname.lastname@example.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.
Mailing address: Vanguard Charitable, P.O. Box 9509, Warwick, RI 02889-9509
European Data Privacy Laws
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
We use your Personal Data for the following key purposes:
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”)
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.
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.
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.