PRIVACY POLICY

Vanguard Equity (“VEF”) recognizes the importance of protecting your personal and financial information when you visit our website located at www.vefllc.com “Website”. The following information is designed to help you understand the information collection practices at this Website.

By visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Website. Please review theTerms and Conditions to learn of other terms and conditions applicable to your use of this Website.

Changes to this Privacy Policy

VEF reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Such changes shall be effective immediately upon posting. We suggest that you review this policy periodically for changes. The current version of this Privacy Policy can be accessed from the link on our homepage, or at the bottom of our other Website pages. You acknowledge that by accessing our Website after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

Information Collection and Use

Personally Identifiable Information: The personally identifiable information you submit to our Website is used only to service your account and/or to provide you with information on VEF products and services. The types of personal information that may be collected at our Website include: name, address, e-mail address and telephone number. We will not sell, share or rent your personally identifiable information to others in contravention of this Privacy Policy. Please contact us by email or telephone as specified below to update your account information whenever such information ceases to be complete or accurate.

Additionally, if you are accessing parts of this Website that are password protected, then (a) once you submit your password and enter, this Website will recognize who you are and collect all information that you submit, including all electronic information (including all transaction information), and (b) any information collected about you from this Website may be associated with other identifying information that we have about you.

Aggregate Information: We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your Internet Protocol (IP) address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

Cookies: Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website.

Cookies help us to provide customized services and information. We use cookies on this Website for the following purposes:

  • Analytical purposes:Analytical cookies allow us to recognize, measure and track visitors to the Website. This helps us to improve and develop the way the Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of the site that are of the most interest to them.
  • Usage preferences:Some of the cookies on the Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of the site to the individual user.
  • Terms and conditions:We use cookies on the Website to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it avoids a user from repeatedly being asked to consent to the same terms.
  • Session management:The software that runs the Website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, authenticate users and determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.
  • Functional purposes:Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

To make full use of the Website, your computer or mobile device will need to accept cookies, as the site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on the Website.

If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com.  Please note that, if you disable Flash cookies, some site functionality may not work.

Privacy Preferences: This Website may contain information, including P3P privacy policies (“Privacy Preference Information”), intended to work with your selected privacy preferences. While we have tried to make such Privacy Preference Information included within this Website conform to this full-text of this Privacy Policy, this Privacy Policy is the definitive statement of the privacy policies and practices for this Website.

Service Providers: We may use internal or external service providers to operate our Website and employ other persons to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personally identifiable information you submit through the Website, but only for the purpose of performing their duties. These personnel are not permitted to use your personally identifiable information for any other purpose.

Business Transfers: If all or some of the business, stock or assets of VEF are acquired or merged with another business entity, we will share all or some of your information with this entity to continue to provide service to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, you may decline such use at such time.

Security

No data transmission over the internet can be 100% secure, so VEF cannot ensure or warrant the security of any information you submit to us on this Website. However, VEF seeks to protect your personal information when you transact business on our Website by requiring the use of a browser software program that supports industry standard SSL encryption with 128-bit key lengths. The “128-bit” designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security.

Contact Us

If you have any questions about this Privacy Policy or our privacy related practices, or if you would like a copy of VEF’s Regulation S-P privacy policy, please contact us.