The types of nonpublic personal information Vanguard collects and processes depends on the product or service you request from Vanguard or from affiliated or non-affiliated third parties who may request products and services on your behalf. This information can include but may not be limited to any of the following:

• Contact information (such as name, phone number, address, e-mail address);
• Social security number or taxpayer identification number;
• Driver’s license number or other government identification number (or a full copy);
• Bank and routing information from checks or electronic payment methods;
• Loan information contained on a loan or other real estate disclosure form provided by a settlement agent (such as an attorney) in a real estate transaction.

Vanguard may collect non-public personal information about you in person, over the phone, through facsimile (fax) transmission or other electronic communication, such as e-mail or through Vanguard’s website or other portal, and on applications or other forms submitted to Vanguard.

Vanguard may also collect or receive personal information about you from others involved in your transaction such as the real estate agent, attorney or lender and through standard real estate settlement forms, such as state tax forms.

Vanguard may also collect or receive personal information about you from affiliates or non-affiliated service providers, consumer reporting agencies and regulators in connection with or in relation to products or services Vanguard provides to you, law enforcement action and regulatory reporting and investigation.

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Vanguard uses both public and nonpublic personal information during the course of routine business in order to provide products and services.

Vanguard does not share non-public personal information about you to any affiliate or non-affiliated third party that is not expressly permitted by law. Even where sharing such information is permitted under the law, you may be able to opt out of such sharing by providing written notice to Vanguard. Reasons why and with whom Vanguard might share your personal information are as follows:

Internally:

To enable Vanguard’s personnel to perform everyday business purposes, including but not limited to processing orders, maintaining accounts, preparing for and responding to court orders and legal investigations and routine audits

Externally:

To third party contractors or service providers from whom Vanguard obtains a product or service on your behalf related to the settlement process To law enforcement or other governmental authority in connection with investigation, or civil or criminal matters or to respond to subpoenas or court orders For reasons of communicating with financial service providers engaged in banking, consumer finance, securities and insurance Communicating with parties involved in a specific loan transaction or real estate closing such as an attorney or the bank/lender Communicating with non-financial companies such as direct mail companies and other fulfillment service providers For marketing purposes in order to offer Vanguard’s product(s) and service(s) to you For Vanguard’s affiliates to market to you For non-affiliates to market to you For Vanguard’s affiliates’ or non-affiliate third party providers’ everyday business purposes, information about your order(s) To enforce this privacy notice

Can you limit our sharing? Yes, federal law gives you the right to limit Vanguard’s sharing in certain cases. You can limit Vanguard’s sharing of your personal information to affiliates and non-affiliated third party service providers for reason of marketing products and services to you. Vanguard does not make a practice of providing or selling non-public personal information such as name lists to any non-affiliated third party for their own direct marketing use but may in future make joint marketing

arrangements with an affiliate or non-affiliate in order to promote future products and services. You cannot limit Vanguard’s sharing of personal information with Vanguard’s affiliates or non-affiliated third parties in cases wherein the information is necessary to provide our products or services to you or on behalf of a third party with whom you are engaged as a customer such as your lender. In such cases Vanguard may also be obligated to abide by the privacy practices of the financial institution with whom you are a customer which may also additionally limit our use of your personal information. In certain cases Vanguard may contact you in order to obtain your permission to share information with non-interested parties to your loan and settlement transaction, such as your real estate agent.

Reasons why Vanguard may share some personal information in the normal course of business, as allowed by law, may include but are not limited to, verifying your identity for reason of complying with state or federallymandated forms, for reason of insurance underwriting contractual requirements or ensuring proper delivery of specific products or services.

To limit Vanguard’s sharing:

Call Vanguard’s Corporate Office at (315) 422-6031 Visit Vanguard Online at www.vgrti.com Mail in the form provided below

Please note: If you are a new customer, Vanguard can begin sharing your information 30 days from the date you received this notice. When you are no longer our customer, Vanguard can continue to share your information as described in this notice, however, you can contact us at any time to limit our sharing.

For Questions or Complaints Contact:

Patrick J. Corbett, President & CEO, 407 South Warren Street, Syracuse, New York 13126; (315) 422-6031 x 004.

Stephen Champlin, VP Brand, Product & Technology, 407 South Warren Street, Syracuse, New York 13126; (315) 422-6031.

Your content goes here. Edit or remove this text inline or in the module Content settings. You can also style every aspect of this content in the module Design settings and even apply custom CSS to this text in the module Advanced settings.

Your content goes here. Edit or remove this text inline or in the module Content settings. You can also style every aspect of this content in the module Design settings and even apply custom CSS to this text in the module Advanced settings.