PRIVACY POLICY

Vanguard Vaults understands your concerns about the privacy of data you may submit through this Vanguard Vaults Web site. This Privacy Policy provides you information about what type of information is gathered and tracked on the Web site, how the information is used, and with whom the information is shared. You may also want to review Vanguard Vaults' Privacy Principles which set forth the Company's commitment to protecting our customers' and employees' privacy, online and offline. In the event that any inconsistencies should arise with respect to this policy and the Privacy Principles concerning online privacy, the terms of this policy shall prevail.

Unless you provide it to us voluntarily or the information is collected via cookies in the manner described in this policy, Vanguard Vaults does not collect personally identifiable information about you (including, but not limited to, your name, address, telephone number, and e-mail address) in connection with your use of this Web site.

Please read this policy carefully to learn how you can verify the accuracy of any personally identifiable information we have concerning you and how you can request that Vanguard Vaults delete or update your information.

What information do we ask you to submit?

In order to accommodate your information request, we ask you to submit your name, title, company affiliation (if any), mailing address, telephone number and e-mail address. At your option, you may also provide us with the best time at which to contact you and other relevant comments (if a comment field exists for the information you have requested). In addition, Vanguard Vaults may, from time to time, share your information with marketing consultants, in which case, the consultants shall be prohibited from using your information except with respect to assisting Vanguard Vaults in the sale of its services and products, and the consultants shall also be required to comply with the terms of this policy.

How will we use your information?

We will use the information you submit (a) to answer your specific inquiry; (b) at your option, to send you additional materials relating to Vanguard Vaults and services that may be of interest to you; (c) in the administration of the Web site; and (d) as otherwise described in this policy.

Do we use cookies and other tracking mechanisms?

When you visit this site, information about your browser type, operating system, IP address, and the domain name from which you access this site (e.g., yahoo.com) is collected. In addition, we may collect information about your browsing behavior, such as the number of times you have visited the site, the date you visited the site, and the amount of time you spent viewing the site. This information is used solely for our internal purposes in managing the site and improving its functionality.

If you have selected the "Choose a Country" button, your country and language preferences will be saved via the use of a cookie that will be used to identify you when you return to the site. Cookies are blocks of data that are placed on your computer and that are sent by your Web browser to our computer when you visit this site. The cookies that are placed on your computer have unlimited duration. If you delete or otherwise choose not to use cookies, you will still be able to use our site, but you will need to re-select any preferences that you previously made (such as language and country).

To whom do we disclose your information?

Subject to applicable law, we and our service providers (as defined below) disclose and share your personal information:

Among Vanguard Vaults and its Affiliates
To unaffiliated third parties that are under contract to perform services for or on behalf of Vanguard Vaults (Service Providers), and are required to uphold and maintain policies with respect to privacy and the treatment of your personally identifiable information (e.g., vendors hosting the investor relations or other aspects of this Web site)
To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division
To other persons as permitted or required by applicable law or regulation

Any access to such information will be limited to the purpose for which such information was provided to us or our Service Providers. Vanguard Vaults, its Affiliates and Service Providers are located throughout the world. Accordingly, your information may be sent to countries which have a different level of privacy protection than the United States of America (USA) or your country of residence. For instance, if you inquire about services Vanguard Vaults provides in France and in Brazil, Vanguard Vaults will forward your inquiry to the Vanguard Vaults location in such countries. Vanguard Vaults will, at your request, provide you with details of companies and countries to which your information has been sent.

Links and third-party Web sites

This policy applies only to this Web site. This site includes links to both our Affiliated Web sites and to non-affiliated Web sites, including access to content, products and services of such Affiliated and non-affiliated sites. In some cases, these other sites are made available via "seamless experience" technology, and may appear to be part of our Web site. Although some of the entities controlling these sites are under contract with Vanguard Vaults, we urge you to familiarize yourself with the individual privacy and other terms for each linked Web site prior to submitting your personally identifiable information.

How may you opt out or request changes?

You are entitled to request that Vanguard Vaults:

Cease processing your personal information for the purposes of direct marketing
Correct any errors in that information
Update that information as required

If you would like to receive a copy of the personal information we have about you as submitted to us via this Web site, or if you wish to opt out of receiving marketing related communications from us, please send a request to Info@VanguardVaults.com. If this information is incorrect or incomplete, please let us know, and we will make every reasonable effort to correct or update it promptly (unless we require further information from you in order to fulfill your request). You may also ask us to remove your name and other personal information from our databases. In each of the foregoing cases, we will make all reasonable efforts to honor your request promptly, subject to legal and other permissible considerations.

How will we notify you if this policy changes?

Vanguard Vaults may, in its sole discretion, update this policy at any time and from time to time, by posting the amended policy on this Web site. After the changes take effect, all newly collected personal information will be subject to the terms of the revised policy and all previously collected personal information will be handled in accordance with your response to our opt-in notice (in accordance with the revised policy if you opt in and in accordance with the previous policy if you do not opt in).

If no material changes have been made to this policy that affect our treatment of your personal information, the amended policy shall be effective upon posting, and your access to or use of the site following an update shall be deemed consent to the revised policy. If you have asked to receive marketing and other materials, and you regularly receive electronic communications from us, amendments to this policy may be sent to you via e-mail. We urge you to refer back to this page regularly and especially prior to providing any personal information via this Web site. This policy may not be otherwise amended without the written consent of Vanguard Vaults. This Policy was last updated January 8, 2005.

How do we protect your information and where is it stored?

Vanguard Vaults takes seriously the security of the information it collects. Vanguard Vaults has therefore implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the data concerned.

Personal information which you submit via the site is stored on servers in the USA, and these servers are subject to Vanguard Vaults' IT security policies and procedures. If you are located in another jurisdiction, you should be aware that your personal information once submitted will be transferred to our servers, and the USA currently does not have uniform data protection laws.

Children

Vanguard Vaults does not want to collect personal information from minors (children under 15 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted personal information via this Web site, we will notify the user that we may not accept his or her personal information.

VANGUARD VAULTS' WHISTLEBLOWER PROGRAM

Disclosures made pursuant to Vanguard Vaults' Whistleblower Program are covered by Vanguard Vaults' Code of Ethics and Business Conduct in lieu of this privacy policy.

Questions regarding this policy

If you have questions concerning this Policy, please contact our Director of Privacy at (916) 686-8286

Top