College Savings Iowa and Vanguard are committed to protecting your privacy. See how we do it.
All providers of personal financial services are now required by federal law to inform their customers of their policies regarding privacy of customer information.
College Savings Iowa, a college savings plan created and administered by the State of Iowa, may be considered a provider of personal financial services for purposes of this new federal law.
Accordingly, this notice is being provided to you, as a Participant of College Savings Iowa, to inform you of our policies regarding privacy of Participant information.
Types of nonpublic personal information we collect
We collect nonpublic personal information about you that is provided to us by you or obtained by us with your authorization. This includes information that we receive from you on applications and other forms.
Parties to whom we disclose information
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Permitted disclosures include, for instance, providing information to our employees and to related service providers who need to know the information to assist us in providing services to you. In all such situations, we stress the confidential nature of the information being shared.
Protecting the confidentiality and security of current and former participants' information
We retain records relating to services that we provide so that we are better able to assist you with your college planning needs and, in some cases, to comply with governmental reporting requirements. In the case of former Participants, we will continue to adhere to the privacy policies and practices as described in this notice.
In order to guard your nonpublic personal information, we maintain physical, electronic, and procedural safeguards that comply with our privacy standards.
Your personal and financial information is very important to us. Please call 888-672-9116 if you have any questions.
Our commitment to you
As a Vanguard investor, you have entrusted to our care not only your hard-earned money but your personal and financial data as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests.
Because your personal and financial data are your private information, we hold ourselves to the highest standards in their safekeeping and use.
This means, most importantly, that we do not sell client or prospective client information—whether it is your personal information or the fact that you are or may become a Vanguard client—to anyone.
Instead, we use your information primarily to complete transactions that you request or to make you aware of other financial products and services that we offer or sponsor.
The personal information we collect about you
You provide personal information when you complete a Vanguard account application. (If you enter information in an online application, we may store the information even if you do not complete or submit the application.) You also provide personal information when you request literature or a transaction that involves Vanguard or one of the Vanguard-affiliated companies.
In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
Personal information collected from any source may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions.
The information we collect about you may be transferred to or stored by Vanguard or our service providers in the United States or elsewhere, as permitted by law.
How we handle your personal information
We do not sell personal information about current or former clients or their accounts to third parties. Nor do we share personal information about clients or prospective clients, except when needed to complete transactions at your request or to make you aware of financial products and services that we offer. Here are the details:
- In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Vanguard. For example, if you ask to transfer assets from another financial institution to Vanguard, we will need to provide certain information about you to that company to complete the transaction.
In order to alert you to other financial products and services that Vanguard offers or sponsors, we may share your information within the Vanguard family of affiliated companies, to the extent permitted by law.
This would include, for example, sharing your information within Vanguard to make you aware of new Vanguard funds or other investment offerings, or the brokerage services offered through Vanguard's brokerage companies, or the asset management and trust services offered through Vanguard's trust companies and registered investment advisors inside Vanguard.
In certain instances, we may contract with nonaffiliated companies to perform services for us. Where necessary, we will disclose information we have about you to these third parties. In all such cases, we provide the third party with only the personal information necessary to carry out its assigned responsibilities, and only for that purpose.
And we require these third parties to treat your personal information with the same high degree of confidentiality that we do.
- Finally, we will release information about you if you direct or authorize us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to prevent fraud).
Cookies, web beacons, and online privacy
Our concern for the privacy of our shareholders naturally extends to those who use our Personal Investors website, vanguard.com.
Our website uses some of the most secure forms of online communication available, including data encryption, transmission encryption, user names and passwords, adaptive authentication techniques, and back-end fraud and account monitoring.
These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
Our website uses a variety of technologies to collect information that helps us understand how our site is used. A cookie is a small file of letters and numbers that is stored on the hard drive of your computer. Cookies may expire at the end of a web session or persist in order to store your settings and preferences.
A web beacon, also known as a pixel tag, is a tiny transparent image embedded in a webpage or an e-mail to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your computer.
Cookies also help us to understand how people use our site so that we can improve site structure, functionality, and content. Web beacons allow us, directly or through our 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 website, or how frequently users search for a particular term on our website.
You can change your cookie preferences by activating the setting on your web browser that allows you to delete or refuse the setting of cookies. If you delete or reject cookies, you may be unable to register for or log on to our website, some pages of the site might not function properly, and the site experience will not be tailored to you from visit to visit.
Please consult your web browser's help documentation for more information about deleting or blocking cookies.
This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We also analyze this information, with the assistance of our service providers, to improve our web design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.
We and our service providers may use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information about the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click on any links in the email.
These technologies enable us to gauge the effectiveness, relevance, and value of our e-mail communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Vanguard relationships.
If you are a Vanguard investor who has registered for secure access to your accounts on vanguard.com, we are able to combine the information we collect about your usage of our website during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your web session.
We can also identify your computer or device on each visit to our website even if you don't log on, and link information about that visit, as well as 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 website and the effectiveness of our online advertising, as well as to identify Vanguard products and services that may be of interest to you.
We may use third-party service providers' technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your use of our website through different devices may be combined.
By making these connections, we may be able to better understand the relevance of our content and the impact of our advertising and to customize that content and advertising to you.
In certain cases, we may use third-party service providers to place advertisements for us on other websites, and to help us measure brand awareness and the effectiveness of our online advertising.
We and our service providers may use data collected on this site or when you open emails from Vanguard, together with other information we have about you and your Vanguard relationships, to serve ads to you on other sites as you browse the web.
In some cases, our service providers are able to combine information about your use of our website with information obtained from other websites and advertising service companies in order to serve advertisements for Vanguard products and services that may be relevant to you based on your activity on Vanguard and non-Vanguard websites.
We do not provide any information to these service providers that could personally identify our users or clients, and they do not collect such information for us. All information collected on our website is used exclusively by Vanguard, or by our service providers on our behalf.
Vanguard uses the Ghostery assurance service to comply with the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance. As part of this service, Vanguard's targeted advertisements on other websites are delivered with icons that help consumers understand how their data are being used and provide choices for consumers who want more control.
For information about online behavioral advertising and to indicate your choices, you may visit aboutads.info/choices. Opting out of behavioral, or interest-based, advertising means that you will no longer receive ads targeted to you by the companies listed on the consumer choice page, but you may still receive targeted ads from other providers or based on the particular website that you are viewing.
Also, if your browser is set to reject cookies when you visit the AdChoices opt-out page, or if you subsequently clear your browser cookies, your opt-out may no longer be effective.
How we safeguard your personal information
Within Vanguard, we restrict access to information about you to those Vanguard employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with information you request, or notifying you of new products and services.
To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.
What you can do
For your protection, we strongly recommend that you do not provide your account information, user name, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately.
We'll keep you informed
Under the terms of the contract between Upromise and College Savings Iowa, Upromise is required to treat all participant information confidentially. Upromise is prohibited from using or disclosing such information, except as may be necessary to perform its obligations under the terms of its contract with College Savings Iowa.