This Privacy Policy for California Residents supplements the information contained in Vanguard’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.

Disclosures about your Personal Information

As described in the General Privacy Policy, to support your relationship with Vanguard or your use of our products and services, we may have collected and disclosed, for a business purpose, information from the following categories in the last twelve months:

• Information necessary to provide you with access to and use of our websites, products and services.
• Information necessary to respond to your request for information, order or support.
• Information about your use of Vanguard software or services.
• Business contact information of clients, prospects, partners and suppliers.
• Information about visitors to our sites and locations.
• Information collected for marketing and business intelligence.

This includes Personal Information defined by the CCPA as:

• Identifiers such as IP address, mobile device ID and cookies.
• Personal information under the Customer Records provision of the California Civil Code such as your name, postal address, email address or payment information you provide to purchase a Vanguard product or service.
• Commercial information related to purchases of Vanguard products or services.
• Internet/network activity information relating to your interactions with Vanguard websites, client portal, or applications.
• Audio, electronic and visual information such as visitors’ presence on security systems at Vanguard offices.
• Professional information such as your employer name and job title.
• Inferences about your consumer preferences.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From your employer during the course of business.

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and employer’s secure account with us.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users are among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Vanguard has not disclosed personal information for a business purpose to third parties, including identifiers, California customer records personal information categories, protected classification characteristics under California or federal law, commercial information, Biometric information, intranet or other similar network activity, geolocation data, sensory data, non-public education information, or inferences drawn from other personal information.

In the preceding twelve (12) months, Vanguard has also not disclosed personal information for a business purpose to third parties, including commercial information and professional or employment related information to a third party.

We do not sell personal information.

Your Rights and Choices

In addition to the rights granted under the General Privacy Policy, as a California resident, you have the right to:

Know your Personal Information
You can request specific pieces of Personal Information, or information about the categories of Personal Information that Vanguard hold about you by submitting a request to legal@go2vanguard.com

Request Deletion of your Personal Information
You can request a deletion of the Personal Information that Vanguard holds about you by submitting a request to legal@go2vanguard.com

We will delete or deidentify personal information, not subject to one of these exceptions in the CCPA, from our records and will direct our service providers to take similar action.

Non-discrimination
If you choose to exercise any of these rights, we will not deny goods or services to you or provide you a different quality of service.

Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Additional Disclosure
As permitted under HIPAA, Vanguard may disclose Deidentified Patient Information (as those terms are defined under CCPA) that has been deidentification methods described in HIPAA.

How to Contact Us
If you have any questions or comments about this notice, the ways in which Vanguard collects and uses your information described here and in the General Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at info@go2vanguard.com

If you need to access this Policy in an alternative format due to having a disability, please contact legal@go2vanguard.com.