Mobile App Privacy Policy
This Privacy Policy applies to the processing of personal data in connection with the UK Personal Investor App (“App”) provided by Vanguard Asset Management Limited (“Vanguard”, “we”, or “us”). The App provides clients access to their Vanguard portfolio. This Privacy Policy sets out how we use and disclose your personal data, your rights and how to contact us with any questions or concerns.
Personal data we collect about you
“Personal data” means any information about an individual from which that person can be identified. The personal data about you we process in connection with the App are:
- Identity data, such as name, Vanguard and/or third party user ID(s), email address(es), and password.
- Technical and navigational information, such as: device type; operating system; user agent string; internet connection; mobile network provider; date/time of visit; time since last visit; web pages viewed; links clicked; IP address; and your general geographic location (e.g. city or postcode).
- User experience feedback.
How we use your personal data and legal basis
We use your personal data to create and manage your registration for the App and to provide the features of the App to you; and for our business purposes.
The legal bases for these activities are:
- We need to process your personal data to perform the contract to provide our services to you, or in order to take steps at your request prior to entering into the contract.
- We have legitimate interests in using your personal data and these interests are not overridden by your rights and interests. These legitimate interests are to measure and improve the App experience, design and functionality, and to enhance our ability to serve you and your accounts.
Who we share your personal data with
Your data may be shared between Vanguard group entities where necessary for the activities described. We work with third-party service providers and others to provide the App to you. These third parties may process your personal data in the course of their work. We limit the personal data provided to the third parties to what is necessary to perform their functions, and we require third-party service providers to agree to comply with applicable laws, and to maintain the confidentiality of your personal data.
Data security and retention
We use certain physical, organisational and technical safeguards that are designed to improve the integrity and security of your personal data. We recommend that you take steps to protect against unauthorised access to your password and device by, among other things, choosing a robust password that nobody else knows or can easily guess, and keeping your username and password private. For additional information, see our Online Security Policy.
Your personal data is retained in line with Vanguard’s retention policies, which vary according to the type of personal data and purpose of processing. For example, Sentry data is kept for 30 days and Adobe Analytics data is kept for 36 months after which they are deleted.
Tracking and analytics
We use Sentry and Adobe Analytics. You can set your preference to enable or disable these functions in the ‘Tracking and analytics’ page on the Profile screen. Sentry is used to analyse app errors, fix problems and ensure the stability and quality of the App, and to improve it. Error reports may be sent to Vanguard in the event of crashes and technical errors, which contain, e.g., data on the operating system, App details and device type. If you allow us to track your activity on the app using Adobe Analytics, we use the technical and navigational data collected for App analytics, to measure and improve the App experience, design and functionality, and to enhance our ability to serve you and your accounts.
Cookies
If you submit a survey, then a “strictly necessary” session cookie is placed on your device to ensure the correct operation of the survey tool.
Your rights and how to contact us
You have the right to access, rectify, port, and erase your personal data and to restrict and object to certain processing of your personal data. For further information about your rights and other details of processing, please see privacy policy.
If you have any questions or concerns about the processing of your personal data, please contact the Data Protection Officer for the data controller, Vanguard Asset Management Limited, by mail at Vanguard Asset Management Limited, 4th Floor The Walbrook Building, 25 Walbrook, London EC4N 8AF, or by email at privacy@vanguard.com.
February 2024