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Privacy and Security

TD Privacy Code

Protecting Your Privacy

The TD Bank Group commitment to privacy

Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business within TD Bank Group1 (TD).

We strive to provide you with the best customer service. To us, that includes treating you fairly and with respect.

The TD Privacy Code informs you of the ways we help protect your privacy and the confidentiality of your information.



 Table of Contents

Our Privacy Code
Why we ask for your information
How we obtain your consent
Why we share your information
Why we ask others for information about you
When we release your information
How we protect your information
Your right to access your information
Keeping your information accurate
Respecting your preference
Addressing your concerns
Our Online Privacy Code

Our Privacy Code

Our Privacy Code informs you of the practices we have in place relating to the management of personal information at TD in Canada. The word “information” means personal, financial and other details about you that you provide to us and we obtain from others within or outside our organization, including through the products and services you use.

This Code applies to any person who has requested from us, or offered to provide a guarantee for, any product or service offered by us in Canada. This includes individuals carrying on business alone or in partnership with other individuals and signing officers of our business customers. It consists of five key principles:

1. Collecting and Using Information

Either before or when we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties such as credit bureaus.

Your personal information is used to help us manage products and services you have with us, contact you about products or services you may be interested in having with us, and to manage operations and risk within TD. Your information is also used in order to satisfy valid information requests from regulators and other organizations or individuals who are legally entitled to make such requests.

2. Releasing information

We may provide your information to other persons in situations where –

  • our suppliers or agents, who assist us in serving you, need the information
  • we are required or permitted to do so by law or applicable regulators and self-regulatory organizations
  • we want to prevent, detect or suppress fraud or criminal activity, protect our assets and interests or manage or settle any actual or potential loss in connection with fraud or criminal activity
  • transfers of a business are involved
  • you have provided your consent

3. Protecting information

We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time it is required for the purposes we explain.

4. Providing information access and accuracy

Upon request, we will give you access to the information we retain about you. We will make reasonable efforts to keep your information accurate and up-to-date.

5. Respecting and responding to your privacy concerns

We will explain your options for refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your information.

In this Code, we explain how we fulfill each of these important principles.

Why we ask for your information

We ask you for information to establish and serve you as our customer.

We collect the information we need and only use it for the purposes explained to you.

When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your information. We will indicate clearly which information would help us to serve you but is optional for you to provide.

We obtain most of our information about you directly from you.

At the time you begin a relationship with us and during the course of our relationship, we may collect information about you. The information we ask for depends on which product or service you want. For every product or service, we need your name, address, birthdate, occupation and some identification. Here is why we need some of the information we ask you to provide.

Birthdate

This helps us identify and authenticate you. We may also use it to determine your eligibility for products and services that may be of interest to you.

Social Insurance Number (SIN)

Your SIN is required for products which earn investment income, in order to comply with the Canada Revenue Agency’s income reporting requirements. Providing your SIN for credit products, or when applying for products online that do not earn investment income, is optional. If you provide us with your SIN, we also use it to keep your information separate from that of other customers with a similar name, including information we obtain with your consent through the credit approval process.

Employer name and address

This is required when a new account is opened or when you apply for credit in order to comply with anti-money laundering regulations.

Financial information

This is used to assess your eligibility for any credit product, for example, a TD Canada Trust Credit Card, line of credit or other loan. We also use it to help ensure that the advice we give you or the investments you purchase (in the case of mutual funds or brokerage or investment accounts) are appropriate for you. We may collect information from you and service providers with whom you make arrangements to provide those services (for example when you set up bill payments through your account). We will use your information, including transaction records that reflect your business dealings with and through us, to analyze your activities to help us serve you as a customer and meet your needs.

Health information

This is required for some insurance products to ensure you are eligible for coverage, and may also be used to investigate and adjudicate your claims, and to help manage and assess our risks.

The health-related information you provide in connection with an insurance product will never be shared within TD. However, it may be shared with administrators, service providers and reinsurers of the insurance operations to process your insurance transactions.

We also collect information during our interactions with you.

Over the Phone

We may monitor and/or record your telephone discussions with our representatives for our mutual protection, to enhance customer service and to confirm our discussions with you.

Customers who prefer not to have their calls taped can transact business at a branch location, through EasyWeb® Internet banking or through automated teller machines.

In Person

We may use video or photographic surveillance to monitor and/or record the activity that occurs in and around TD premises such as at our retail branch offices or ATMs. We use this information for security purposes such as theft, vandalism, damage to property and fraud.

Customers who prefer not to have their image collected can transact business through EasyWeb Internet banking or EasyLine® telephone banking.

Through the Internet

When you are using one of our websites, we may monitor and/or record your browsing habits as described in our Online Privacy Code.

Through Email

When you send us an email or when you ask us to respond to you by email, we learn your exact email address and any information you have included in the email.

We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further.

TD will not ask you to provide personal information or login information, such as username, passwords, PINs, IdentificationPlus® security questions and answers or account numbers, through unsolicited email.

If you receive an email claiming to be from TD and that you believe to be fraudulent, do not respond and do not open or click on any links or open attachments contained within the email. Please notify us immediately by forwarding a copy of the email to us at phishing@td.com and delete the email immediately after notifying us.

How we obtain your consent

It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your personal information.

Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain information, inquire about or apply for products or services from us. We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.

Why we share your information

We may share information within TD to manage our credit and business risks and operations, comply with legal or regulatory requirements, and service your account.

Your information may be shared, stored or accessed in Canada or other jurisdictions or countries. Your information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.



Sharing information lets us recognize your total relationship with TD, no matter when or where you contact us or which one of us you contact. It allows us to have up-to-date information about you and in some circumstances, changes to your information can be made once and be effective for all your products or services with TD. Sharing your information within TD also helps us determine your preferences and allows us to review whether any other products or services are suitable for you so that we may offer them to you – including special promotions that we believe will be of interest to you.

In order to understand when you can withdraw your consent, refer to the "Respecting your preference" section.

Why we ask others for information about you

With your consent, we may obtain information about you from third parties, including credit reporting agencies.

Obtaining additional information about you from parties outside TD helps us assess your eligibility for our products.

For credit products, for example, we need to know your creditworthiness. For this reason, we may contact other lenders or credit reporting agencies to get information about you and your credit history. We may also contact employers or other personal references to verify information that you have given us. We will not do this without your consent, but please remember that if you do not give your consent we may not be able to extend credit products to you.

When we release your information

We do not sell or rent customer lists or personal information to others. However, we may release your information to parties outside TD in certain circumstances, which include –

For servicing purposes

We give a limited amount of information, only as necessary, to our suppliers and agents; for example, cheque printers and bank card manufacturers who provide goods and services to you, through us. These suppliers and agents may be located in Canada or other jurisdictions or countries and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.

When required or permitted to do so by law or applicable regulators and self-regulatory organizations

We may release information in response to a search warrant, court order or other demand or inquiry which we believe to be valid. This may include requests from regulators, including self-regulators, who are responsible for ensuring TD is in compliance with applicable regulations (e.g. The Office of the Superintendent of Financial Institutions and the Investment Industry Regulatory Organization of Canada).

To protect our interests

We may also disclose information to any person or organization, including an investigative body, in order to prevent, detect or suppress fraud or criminal activity, protect our assets and interests, or in the case of a breach of agreement or contravention of law. This helps prevent fraud, money laundering or other criminal activity.

We may also disclose information to help us collect a debt owed to us by you.

Transfers of a business

As TD continues to develop and grow, we may buy or sell parts of our businesses. As our businesses consist primarily of our customer relationships, personal customer information and information regarding the particular account or service being purchased or sold would generally be one of the transferred business assets.

Other situations where we have your consent

For example, we will disclose your credit history with us to other lenders or credit reporting agencies in order to support the credit process. We release only the information required to identify you, as well as facts from our credit records about your repayment history. We may disclose your account information to a joint account holder, including information about the account prior to it becoming a joint account.

How we protect your information

We will protect your information with appropriate safeguards and security measures.

We have security standards to protect our systems and your information against unauthorized access and use.

For example, our systems have been designed to ensure that your Personal Identification Number (PIN), password and other access codes are always private and confidential. For your protection, your access codes are known only to you – our employees cannot gain access to them and they will not ask you to reveal them.

All our suppliers and agents, as part of their contracts with TD, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose.

When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required. All employees of TD are familiar with the procedures that must be taken to safeguard customer information. And to us, protecting the confidentiality of your information is more than a procedure – it’s part of our job. It is specified in our employment agreements and regularly confirmed in writing.

We audit our procedures and security measures regularly to help ensure that they are being properly administered and that they remain effective and appropriate to the sensitivity of the information. We retain your information only as long as it is required for the reasons it was collected.

The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your right to access your information

Upon request, we will give you access to the information we have about you. If requested, we will assist you in making your request.

Most of this information is in the form of your transaction records. These are available to you through your account statements or passbook updates, by visiting the branch or office where your account is held, or by accessing your account through our EasyWeb Internet banking, EasyLine telephone banking, Green Machine® ATMs and WebBroker® Internet brokerage service.

If you require other information, simply contact or forward a written request to the branch or office where your account is held. We will ask you for specific details such as branch and account number.

We will advise you in advance if a minimal charge will be required for conducting the search and we will respond to your request within 30 days.

Please note that we may not be able to provide information about you from our records which contains references to other persons, is subject to legal privilege, contains confidential information proprietary to TD, relates to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons.

If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. If we relied on information from a third party, such as a credit bureau, to make the decision, we will provide you with the name and address of the third party.

Keeping your information accurate

We will make reasonable efforts to keep your information accurate and up-to-date.

Having accurate information about you enables us to give you better service and minimize the possibility that out-of-date information may be used to make a decision which impacts you. We have procedures and practices in place to help us maintain the accuracy of your information. For most updates, we rely on you for information. You can help by keeping us informed of any changes, such as if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections immediately, and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Respecting your preference

We will explain your options of refusing or withdrawing consent to the collection, use or release of your information, and, given reasonable notice, we will record and respect your choices.

In most cases you are free to refuse or withdraw your consent at any time. You may do so by contacting the branch or office where your account is held or by calling us at 1-800-430-6095. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.

There are several privacy preferences available to you, subject to legal, business or contractual requirements. If you prefer, you may choose not to have us –

  • Use your Social Insurance Number with credit reporting agencies as an aid to identify you
  • Conduct a credit check in order to assess your creditworthiness and/or to perform a risk analysis
    In doing so, however, we may not be able to extend services to you. Once you have a credit product with us, we will share your credit experience on an ongoing basis with other lenders and credit reporting agencies. You cannot withdraw your consent for this sharing of information as it is necessary to support the credit process.
  • Contact you occasionally either by telephone, fax, Internet, mail, email or ATM, or all of these methods, with marketing offers that may be of interest to you
    This does not include messages or other information about promotional offers we provide on, or enclose with, your written or electronic account statements, or that we may discuss while talking with you. Any marketing campaigns that are already underway may not immediately take your preferences into account.
  • Share your financial and account information with other members of TD
    This does not apply if you have requested a product or service that is jointly offered by more than one member of TD.
  • Contact you to participate in customer research and surveys

Addressing your concerns

If you have any questions or concerns about privacy, we encourage you to let us know. If you choose to mail, fax or email2 us, please include your full name, address and telephone number.

We've developed a resolution process that can deal with most concerns in a single, simple step.

Step 1
Talk to Your TD Representative

Many concerns can be resolved right at the time when they occur. Discuss your concern with your TD Representative who will be happy to help you. If the TD Representative is not able to resolve your concern to your satisfaction, they will engage a Manager or the TD group that is responsible for your account.

How to contact us:

TD Canada Trust
Visit your branch or:

  • Phone:1-866-222-3456
  • Email2:customer.service@td.com
  • Mail: TD Canada Trust Customer Feedback
    Toronto-Dominion Centre
    P.O. Box 193, Toronto, ON M5K 1H6
  • Fax:1-877-983-2932

TD Waterhouse

  • Discount Brokerage:1-800-465-5463
  • Financial Planning:1-866-646-7888
  • Institutional Services:1-866-563-6212
  • Private Client Services:1-866-280-2022
(Includes Private Banking/Private Trust/Private Investment Counsel and Private Investment Advice)For additional contact information for TD Waterhouse, please visit www.tdwaterhouse.ca

Other Areas of TD

  • Phone:1-800-430-6095
  • Email2:customerfeedback@td.com
  • Mail: TD Canada Trust Customer Feedback
    Toronto-Dominion Centre
    P.O. Box 193, Toronto, ON M5K 1H6
  • Fax:1-877-983-2932

Further steps you can take

If, after the first step, you are still not satisfied that your concern has been resolved, TD offers two more internal levels that can help you.

STEP 2
Elevate Your Concern

If you have contacted us and are not satisfied with the resolution that has been suggested, your concern can be referred to a representative of the Senior Management Team by simply talking to your branch. Alternatively, you can elevate your concern using the contact information below.

For TD Canada Trust escalations, contact:

  • Phone:1-800-430-6095
  • Email2:customerfeedback@td.com
  • Mail: TD Canada Trust Customer Feedback
    Toronto-Dominion Centre
    P.O. Box 193, Toronto, ON M5K 1H6
  • Fax:1-877-983-2932

For TD Waterhouse escalations, contact:

  • Email2:td.waterhouse@td.com
  • Mail: Client Support Group
    77 Bloor Street West, 10th Floor
    P.O. Box 5999, Stn. F, Toronto, ON M4Y 2T1
  • Fax:1-877-725-9525

For Other Areas of TD escalations, contact:

  • Phone:1-800-430-6095
  • Email2:customerfeedback@td.com
  • Mail: TD Canada Trust Customer Feedback
    Toronto-Dominion Centre
    P.O. Box 193, Toronto, ON M5K 1H6
  • Fax:1-877-983-2932

STEP 3
Contact the TD Ombudsman

If you have been through the first two steps and you still feel your concern has not been resolved, please contact the TD Ombudsman. The office of the TD Ombudsman acts as an independent body that mediates between customers and different TD groups to resolve outstanding concerns. When you refer a concern to the TD Ombudsman, the office will conduct a thorough and impartial investigation and work to reach a fair and reasonable resolution.

The TD Ombudsman does not normally investigate concerns regarding bank policies, including credit granting policies or risk management decisions; levels of interest rates, service charges or fees that apply to all customers; or matters where legal action has already commenced or has been concluded.

For the TD Ombudsman, contact

  • Phone:416-982-4884 or 1-888-361-0319
  • Email2:td.ombudsman@td.com
  • Mail: P.O. Box 1, Toronto-Dominion Centre
    Toronto, ON M5K 1A2
  • Fax:1-866-891-2410
Include your full name, address, telephone number(s) and the details of your concern in your letter, email or fax.

STEP 4
Additional resources – External Agencies

The following independent services can provide you with information and a further review of your complaint if you do not accept the decision of the TD Ombudsman. You can also contact these services if you have waited more than 90 days for a resolution after elevating your concern (Step 2).

For TD Canada Trust complaints, contact:

For TD Waterhouse complaints and complaints for
Other Areas of TD, contact:

  • Phone:416-287-2877 or 1-888-451-4519
  • Email2:ombudsman@obsi.ca
  • Mail: The Ombudsman for Banking Services
    and Investments (OBSI)
    401 Bay Street, Suite 1505
    P.O. Box 5
    Toronto, ON M5H 2Y4
  • Fax:1-888-422-2865

You can submit your complaint to OBSI for review either 90 days following the submission of the complaint to TD Waterhouse or once you have received a response and wish to escalate.

Office of the Privacy Commissioner of Canada (OPCC)

The OPCC investigates privacy complaints under the Personal Information Protection and Electronic Documents Act (PIPEDA).

If your complaint or inquiry concerns a privacy issue, please contact the OPCC as follows:

  • Mail: The Office of the Privacy
    Commissioner of Canada
    112 Kent Street, 3rd Floor
    Ottawa, ON K1A 1H3
  • Telephone:1-800-282-1376
  • Fax:613-947-6850
  • Website:http://www.privcom.gc.ca


Our Online Privacy Code

Many of you have questions about how we handle the information we obtain from you when you visit our websites. This Online Privacy Code will answer your questions about the information we collect and how we use it.

Our use of Cookies

A cookie is a small file containing certain pieces of data that a website creates when you visit the site, either from a computer or a mobile device. When you visit a website, a cookie may be used to track the activities of your browser as well as provide you with a consistent, more efficient experience.

There are three common types of cookies that we use: "session cookies," "persistent cookies" and "Flash cookies."

Session cookies store information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, they expire and are no longer active.

Persistent cookies are more permanent and store information on your hard drive. Persistent cookies can be re-read when you return to the site that placed them on your hard drive.

Flash cookies are data files that a website creates when you visit the site and are most often used to enhance your web-browsing experience. For more information about Flash cookies or to learn how to remove Flash cookies, please visit www.adobe.com

On our websites we use session, persistent and Flash cookies in the following ways.

We use session cookies –

  • to learn:
    • which pages are visited and what action you have taken;
    • the address of the websites and advertisements that link directly to our sites;
    • the keywords used for searches that brought you to our websites;
    • about the browser version and operating system you use;
    • your Internet protocol (IP) address; and
    • your Internet service provider (ISP) and the region from which you're connecting to our site.
  • as a type of digital signature to identify your current session to our web server.

We use persistent cookies in the following ways –

  • to remember your language preference and automatically input your Access Card number or Connect ID if you choose the option on our login screen;
  • to assist us in authenticating you and your computer and to administer EasyWeb and WebBroker IdentificationPlus;
  • to reduce the likelihood that any online offer which you have already responded to is not presented again when you login to our Internet banking site;
  • to analyze which products and services you have used which allows us to optimize our sites and to provide a more personalized experience while you utilize TD websites. Once you have successfully logged into EasyWeb or WebBroker, we associate you with a TD internal identifier that identifies you as our customer. Although the TD internal identifier allows us to know who you are, the cookie will never contain information that would allow a third party to know who you are, such as your name, address, telephone number or email address. This internal identifier enables us:
  • to monitor your browsing habits on our website in order to learn which advertisements are best for you and deliver online marketing offers and advertisements tailored to you or that may be of interest to you;.
  • to help manage our site Personalization and to contact you occasionally either by telephone, fax, mail, email or ATM, or all of these methods, with marketing offers that may be of interest to you based on your browsing habits on our website;. If you prefer, you may choose not to have us contact you with marketing offers or personalized advertisements based on your online behaviour by contacting the branch or office where your account is held or by calling us at 1-800-430-6095.

We use both session and persistent cookies to –

  • assist us with application support issues and to aid in fraud investigations; and
  • determine how many people visit our websites and which sections of the sites are visited most frequently. This helps us to understand what type of information is most useful to our website visitors so that we can improve our websites and makes it easier for our website visitors to access information. We record statistical information on the numbers of visitors to our websites.

We limit the use of Flash cookies to –

  • act as a back-up for EasyWeb and WebBroker IdentificationPlus; and
  • store information such as IP address and browser type. The information is collected to assist us in authenticating you and your computer.

Managing Your Cookies

If you prefer not to accept cookies, you may adjust your browser settings to notify you when a cookie is about to be sent or you may configure your browser to refuse cookies automatically. If you would like to learn more about your cookie options, please refer to your browser’s documentation or online help for instructions.

If you choose not to accept cookies, some TD websites may not function properly or optimally. For example, you will not be able to access any of our secured sites as cookies are used for security and multi-factor authentication, as well as for fraud prevention or investigation purposes. Also, if you adjust your browser settings to refuse cookies, you may still receive some online advertising from us, but that advertising will not be based on your preferences or products that you hold with us.

Spotlight Tags

Spotlight tags help us to manage some of our online advertising and report on activities that happen after a web user sees or clicks on one of our online ads. The spotlight tag enables us to learn which advertisements bring users to our website.

Ad Management Partners

We use ad management partners, 24/7 Real Media, Inc. and Doubleclick to assist us with delivery and monitoring of our advertising. For more privacy information about our partners and their opt-out policies, go to –

  • 24/7 Real Media, Inc., www.247realmedia.com/EN-US/privacy-policy.html
  • Google Inc., www.doubleclick.net/us/corporate/privacy

Some of the digital ads TD places on external websites use behavioural remarketing (a form of online targeted advertising based on a consumer’s previous Internet actions). When you click on one of these ads, a third party cookie is placed on your device. This persistent cookie together with web beacons are used to monitor whether you have previously clicked on a TD digital ad and your related activities on our website. This process does not associate this cookie with a particular individual, only a device. When your device is used to revisit an external website that displays TD ads, the presence of this cookie on the device may be used to trigger the display of additional TD ads. You may opt-out by clicking here: http://preferences.truste.com/truste/. Please note this does not opt you out of being served generic advertising.

Web Beacons are small transparent graphic images embedded in web pages that, when combined with Cookies, help provide a website operator the ability to monitor usage and effectiveness of a website.

Online Authentication Process

When you purchase a new product online or register for a secure online service, the application you complete includes an online authentication process. The online authentication process utilizes a third party information service to confirm your identity. The information that you provide in your application will be compared against the information contained in your consumer credit report for the sole purpose of validating your identity and will not affect your credit rating or credit file. The online authentication process also uses Flash cookies, JavaScript and 1 x 1 pixel images to identify the device you are using to access our site. This is used in combination with the consumer credit report comparison to protect both you and the Bank from fraud.

Responding to surveys online

When you submit your response online to a survey question, we learn your answer or any opinions or information that you volunteer.

For a survey, we may publish results in aggregate on our websites. We may also use your response to improve products or services of TD. Based on your participation in a survey, we may forward information about our offers on products and services that we believe may be of interest to you.


1 TD Bank Group means The Toronto-Dominion Bank and its affiliates, who provide deposit, investment, loan, securities, trust, insurance and other products and services.
2Email disclaimer: For your protection, do not send confidential or personal information (e.g. Access Card number, account numbers, etc.) via email, as it is NOT a secure method of communication. If your request is urgent or requires disclosure of confidential or personal information for resolution, please call us. All trade-marks are the property of their respective owners. ®/ The TD logo and other trade-marks are the property of The Toronto-Dominion Bank or a wholly-owned subsidiary, in Canada and/or other countries.



How to Contact Us

  • Speak to a representative at your branch or business unit
  • Telephone: 1-800-430-6095

  • Mail: Customer Feedback, Toronto-Dominion Centre, P.O. Box 193, Toronto, ON M5K 1H6
  • Fax: 1-877-983-2932
  • Email Us*:
    customerfeedback@td.com
  • Questions related to TD Auto Finance (Canada): 1-866-694-4392
  • Questions related to TD Insurance: 1-888-791-5346