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Effective date: July 2016

Vanguard Privacy Policy

Introduction

Vanguard Investments Australia Ltd, The Vanguard Group, Inc., and Vanguard-affiliated companies ("Vanguard," "we," or "us") value the privacy and security of information about Vanguard's clients and potential investors. Vanguard entities may collect and retain certain information in order to provide a variety of financial products and services to our customers, including investment management and financial advice. In this privacy policy ("Policy"), we describe how Vanguard collects, uses, and discloses information.

By visiting or using the websites operated by Vanguard entities that link to this privacy policy (the "Sites") or otherwise providing information to Vanguard, you consent to the collection, processing, use, and disclosure of information about you as set out in this Policy, including transfers to third parties and other countries. Your use of our services and the Sites, and any dispute over privacy, is subject to this Policy and our Terms and Conditions of Use, including applicable limitations on damages and the resolution of disputes.

The information that we collect is controlled by Vanguard Investments Australia Ltd, which is headquartered at Level 34 Freshwater Place, 2 Southbank Boulevard, Southbank Vic AU 3001 1300 655 10100. This information also may be collected by or transferred to, and therefore controlled by, The Vanguard Group, Inc., which is headquartered in the United States at 100 Vanguard Boulevard, Malvern, Pennsylvania 19355-2331. As discussed below in the section titled "Cross-Border Transfer of Information," information that we collect may be transferred to and processed in the United States, Canada, the European Union, Switzerland, Hong Kong, Japan, Singapore, or another jurisdiction outside your country of residence, which may have less stringent data protection laws than in your country of residence. To the extent permitted by law, we will not be responsible under the laws of your country of residence for the conduct of any parties to whom we disclose your personal information outside that country, and you may not be able to seek redress under those laws.

Information Collection

Vanguard may collect, process, use, and disclose both Personal Information and Other Information when we provide a service to you (including opening an account, engaging in a transaction, speaking with us on the telephone, providing us with your business card or registering to attend an event) or in connection with your use of the Sites. For purposes of this Policy, "Personal Information" is any information that alone or together with other information in Vanguard's possession relates to an identified or identifiable person, such as name, phone number, e-mail address, financial account information, and online account information such as username and password. "Other Information" is any additional information that is not Personal Information. In this section, we describe our information-collection practices, including the types of Personal and Other Information that we collect. In subsequent sections of this Policy, we describe how we use and disclose Personal and Other Information.

We may combine the Personal and Other Information with information collected from or about you from third parties or in other contexts. This may include information collected online, such as through our e-mail exchanges with you; from publicly available sources, such as your company website if you are a financial adviser; from the registrar for our exchange-traded funds so that we can provide information about products or services that may be of benefit; or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined information in accordance with this Policy. If you do not wish to provide information to Vanguard, we may be unable to provide certain services to you.

Some personal information is collected, used, and disclosed pursuant to applicable laws including laws relating to identification verification, tax reporting and withholding, and money laundering (e.g. in Australia, the Anti-Money Laundering and Counter-Terrorism Financing Act, Taxation Administration Act, Corporations Act, Income Tax Assessment Act, and Privacy Act).

What Personal Information do we collect

Vanguard may collect the following Personal Information from or about you:

Personal Information we collect directly from you, such as when you register to use the Sites or request information from us: Vanguard may collect and maintain Personal Information about you, and about any person or entity on whose behalf you are acting, that you provide to us on the Sites, such as when you register to use the Sites, obtain a product or service from Vanguard, request information or materials from us, or otherwise interact with us. The types of Personal Information we collect vary based on your particular interaction with us, but could include:

Personal Information for your account: Depending on the type of account, and to the extent permitted by law, we may collect the following Personal Information from you or about you when you open an investment account, establish a business relationship with Vanguard on behalf of yourself or another individual or entity, or manage your account on the Sites:

We also may collect Personal Information for your account from third parties authorised to disclose your Personal Information, such as from your employer or from companies that provide identification verification services.

Information about Third Parties: We may collect information from you regarding other individuals related to your account. By disclosing information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives as outlined above, you warrant that you have the consent of those parties to such collection, use, and disclosure of their information as described in this Policy.

Information from telephone, e-mail, online chat, or text message communications with Vanguard: If you communicate with Vanguard by telephone, e-mail, online chat, or text message, Vanguard may keep a record of that communication. In accordance with applicable law, Vanguard also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.

Information you provide to public websites or social media platforms that relate to Vanguard or our products or services: We may also collect information about you from public websites or social media where you have communicated in relation to Vanguard or our products or services.

Information contained in surveys: Vanguard or a Vanguard service provider may ask you to complete surveys for research and client satisfaction assessment or similar client service-related purposes. You are not required to respond to those surveys, and any information collected by Vanguard or on Vanguard's behalf that you provide in response to those surveys is at your discretion.

If you do not provide the Personal Information requested, we may not be able to process an application, provide services to you, or provide you with information about our products and services.

What Other Information do we collect automatically?

Our Sites use a variety of technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect Other Information that helps us understand how our Sites are used. Specifically, when you visit the Sites, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including: your computer or device type; operating system version; browser type and version; user agent string; Internet connection type; mobile network provider; date and time of your visit; time since your last visit; web pages you view; links you click; searches conducted on the Sites; the internet protocol (IP) address used to access our Sites; your general geographic location (e.g., your city, state, post code, or metropolitan region); and the website visited before our Sites. For more information about the information that is collected, please see the section below titled "Third-Party Analytics and Interest-Based Advertising." We also may use similar tracking technologies in e-mails that we or third parties send to you, as further described below. To learn more about how our Sites use cookies, please visit the Vanguard Cookie Policy.

If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of the Sites may not operate correctly. For further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/. Information about how to opt out of the use of cookies for certain purposes (such as interest-based advertising) is discussed below in the section titled "Third-Party Analytics and Interest-Based Advertising."

We may combine Other Information with additional information that we have collected about you, including, where applicable, your name and other Personal Information. When we combine Other Information with Personal Information, we treat all of the combined information as Personal Information. If you have registered for secure access on our Sites or accessed an e-mail we have sent you that includes a web beacon or sets a cookie, we are able to combine the information we collect about your usage of our Sites with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our Sites, even if you do not log on, and link information about that visit, as well as about Vanguard ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Sites and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see the section below titled "Third-Party Analytics and Interest-Based Advertising."

Use and Disclosure

How do we use Personal and Other Information?

We use the Personal and Other Information that we collect for the purposes described in this Policy, for the purposes for which it was provided to us, as required by law, and for our business purposes, including:

To whom do we disclose Personal and Other Information?

We may disclose Personal and Other Information to third parties for the following purposes, as permitted by law:

Affiliates: We may disclose Personal and Other Information to Vanguard Affiliates for the purposes described in this Policy. Vanguard Affiliates may contact you by e-mail, where permitted by law, to make you aware of Vanguard's product and service offerings.

Service Providers: We may disclose Personal and Other Information to our service providers, who use it to perform tasks on Vanguard's behalf. Among other things, these service providers help us manage and improve the Sites, provide Vanguard services, mail disclosures and statements to you, and administer your accounts. Our service providers may collect, process, and retain information about you, in accordance with the laws of your country, directly on behalf of Vanguard. Vanguard's service providers include:

Customer Agents: We may disclose Personal Information to your agents or representatives, including:

Legal Purposes: We may use and disclose information about you as we believe reasonably necessary to protect the rights and property of Vanguard and Vanguard Affiliates, including to establish legal claims or defenses, to obtain legal advice, to defend our legal rights, to protect our rights or property and those of Vanguard Affiliates, to protect against fraud and abuse, to protect other users of our services and our Sites, and to protect the life, body, or property of others (individuals or entities). We also may disclose information about you in order to comply with a judicial proceeding, court order, or other legal process, such as in response to a court order or subpoena, or where otherwise required by law. We may disclose information to authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorised to act.

Sale or Other Transfer of the Company: We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitisation, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, as permitted by applicable law. By agreeing to the terms of this Privacy Policy, you are consenting to this disclosure.

Market Research: We also may provide information to market research companies or Vanguard Affiliates for the purpose of assessing information about our business or client base. We may provide our clients' or prospective clients' contact details to market research companies to undertake research on behalf of Vanguard. For example, we may run client satisfaction surveys or run focus groups on proposed products.

Marketing: We may also provide information to third parties who assist Vanguard in providing market insights and information about products, services, or other marketing material that may be of interest to you.

Direct Sharing through Third-Party Websites and Services: The Sites may enable you to share information directly with websites or online services operated by third parties. For example, the Sites contain features that allow you to share articles or content through Facebook, Google Plus, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and the public more generally. These websites and services may also set and/or access a cookie on your device. Because these third-party websites and services are not operated by Vanguard, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Policy.

Competitions, Contests, and Promotions: Vanguard may use an agency to run competitions, contests, or promotions on the Vanguard Sites or elsewhere, and if you choose to participate, we or third parties may request your name, address, telephone number, e-mail address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations. In compliance with the relevant regulations, it may also be necessary to publish details of the winners of competitions in appropriate news media.

Aggregated Information: From time to time, Vanguard may share aggregated information about users of the Sites or Vanguard's products and services, such as sharing reports on the usage of the Sites or Vanguard's services for regulatory reporting or marketing purposes.

Third-Party Analytics and Interest-Based Advertising

We partner with third parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on the Sites. In particular, the Sites use Adobe Analytics and Google Analytics to help collect and analyse certain information for the purposes discussed above. The information generated about your use of the Sites may be transmitted to and stored by Adobe Analytics and Google Analytics on servers outside your country of residence. You may opt out of the use of cookies by Adobe Analytics here. You may opt out of the use of cookies by Google Analytics here.

We also partner with third parties to provide targeted advertising services that are customised based on your online activities over time and across unaffiliated websites ("Interest-Based Advertising"). These third parties may use cookies and web beacons to collect information about your activity on our Sites, and they may combine it with information about your activity on other, unaffiliated websites. For example, third parties may use the fact that you visited the Sites to target ads for Vanguard services to you on non-Vanguard websites. In addition, our third-party advertising providers might use information about your use of the Sites to help target non-Vanguard advertisements based on your online activity in general.

For more information about Interest-Based Advertising and how to opt out, please visit the Australian Digital Advertising Alliance (ADAA) opt-out page, available at http://www.youronlinechoices.com.au/opt-out/.

Although our Sites currently do not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies, and not this Policy.

Cross-Border Transfer of Information

Vanguard generally maintains centralised servers and systems in the United States and may maintain servers and systems elsewhere. These servers and systems are managed by or on behalf of The Vanguard Group, Inc. or Vanguard Affiliates in or outside the United States. Vanguard also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, the Personal and Other Information that we collect through or in connection with the Sites may be transferred to and processed in the United States, Canada, the European Union, Switzerland, Hong Kong, Japan, Singapore, or another jurisdiction outside your country of residence for the purposes described above, pursuant to methods permitted by the laws of your country of residence for ensuring that information about you will be adequately protected. This list may be updated from time to time. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this Privacy Policy, using the Sites, or by providing any Personal or Other Information to us, you expressly consent to such transfer and processing.

Information Quality

Vanguard relies on the accuracy of the information provided by its clients and others. We take reasonable efforts to ensure that Personal Information collected by us or on our behalf is accurate, up to date, and complete, in accordance with applicable law. If any information about you changes or you have any concerns regarding the accuracy of information about you held by Vanguard, you should contact us at the address provided in the "Contact Us" section below.

Information Security and Retention

We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Information from loss, misuse, and unauthorised access, disclosure, alteration, and destruction in accordance with applicable law. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorised access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.

Vanguard retains Personal Information for as long as necessary to provide our services to you, to fulfill the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.

Choices, Access, and Correction of Information

We provide you with the ability to access, review, correct, delete, or inquire about information that we hold about you, as required and permitted under applicable law. You also may have a right to oppose or limit the collection and processing of your information as described in this Policy, or to revoke your consent, although we may be unable to provide services to you if you oppose this processing or if you revoke consent.

If you would like to access, review, correct, delete, or inquire about your information, place limitations on the collection or processing of your information, or revoke your consent, please send us a request at the address or e-mail provided in the "Contact Us" section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete. Please note that we may need to take additional steps, such as to verify your identity, before we can grant your request. As permitted by law, we will notify you of the basis for any denial of your request.

You may opt out of the use of your information for analytics and online interest-based advertising by following the steps detailed above in the section titled "Third-Party Analytics and Interest-Based Advertising."

Contact Us

If you have any questions relating to this Policy, wish to request access to or correction of Personal Information we hold about you, or have concerns about the way in which we have handled information about you, please do not hesitate to send us an e-mail at clientservices@vanguard.com.au. You also may contact us by sending a message to:

Vanguard Investments Australia Ltd
Attn: Client Services
Level 34
Freshwater Place
2 Southbank Boulevard
Southbank Vic AU 3001
1300 655 101 (8.00am to 6.00pm Monday to Friday, Melbourne, Australia time)

If you raise any concerns about how we have handled your Personal Information, we may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and resolve your issue. We will keep records of your request and any resolution of your issue. We will fully investigate any complaint you lodge with us and seek to provide a response as soon as practicable and, in general, no later than 30 days after receipt of the initial complaint.

If you are not satisfied with the outcome of your complaint, you may refer the matter to external dispute resolution or the Office of the Australian Information Commissioner. We will provide you with further details when we respond to your complaint.

Changes to This Privacy Policy

We will post changes to this Policy on our Sites along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, you will be provided with appropriate notice.