TD 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 or your authorized representative provide to us and we obtain from others within or outside TD, 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 your 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 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, help us collect a debt or enforce an obligation owed to us by you and 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 your information

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

• our suppliers, agents and other organizations 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 financial abuse, fraud, criminal activity, protect our assets and interests or manage or settle any actual or potential loss
• we buy a business or sell all or part of our business/assets or when considering those transactions
• you have provided your consent

3. Protecting your information

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

4. Providing your information access and keeping your information accurate

Upon request, we will give you access to the information we retain about you and 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 withdrawing consent to the collection, use and disclosure 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.

We ask you for information to enable us to complete your request and 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 request to 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 may 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, including discounts that may be of benefit to a particular age group, where permitted by law.

• Claim history

This information is important in helping us to assess your insurance profile and recommend the right coverage at the right price. We may obtain the information from a variety of sources, including other insurers, claims tracking databases, brokers, claims experts, investigative bodies, etc. We usually verify the information you provide when you buy your insurance, or at the time of the claim. If we need to obtain sensitive financial or medical information, we will ask for your specific consent.

• Information about your property

Whether you insure a car or a house, we need information to make sure we recommend the right insurance product. For example, we might disclose your information in order to obtain an appraisal of the value of your house in order to provide you with the insurance coverage you need.

• Financial information

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.

TDIGI may also verify information from a client’s credit report (credit score). This information is only one element among others, including your claims history and driving record, for example, that we review in the underwriting process where permitted by law, or claims process and to determine your eligibility to a payment plan.

Since an individual’s credit score is a strong claims predictor, the process of verifying this information allows us to access reliable information electronically and prepare a quote in minutes, whether you are doing business with us online or by telephone. While a request for credit history will appear in your file, there are no negative consequences to the request and it is not considered a credit check and does not in any way affect your credit score.

When TDIGI obtains your credit report, we usually do it via Equifax and/or TransUnion. You can reach these organisations at the following addresses:

TransUnion Canada
Consumer relations centre
PO Box 338
LCD 1
Hamilton, Ontario L8L 7W2

Equifax Canada Inc.
Consumer relations department
Box 190
Jean-Talon Station
Montréal (Québec) H1S 2Z2

• 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 are welcome to request an insurance quote by writing to us.

• In person

We may use video or photographic surveillance to monitor and/or record the activity that occurs in and around TDIGI premises. We use this information for security and investigation purposes relating to, among other things, theft, vandalism, damage to property and fraud.

Customers who prefer not to have their image collected can transact business with our advisors over the phone or by writing to us.

• 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. When speaking with one of our internet live chat agents, or communicating with us through social media, we may monitor and/or record our discussions for our mutual protection, to enhance customer service and to confirm our discussion with you.

• Through your mobile device

When using one of our mobile apps we may collect, use and disclose information collected from you or your mobile device as described in our Mobile Apps 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.

TDIGI 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 that you believe to be fraudulent, do not respond and do not open or click 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 then delete the email.

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

We may share information within TD to manage your total relationship with us including servicing your account and maintaining information about you, to manage and assess our risks and operations, including to collect a debt owed to us by you and to comply with legal or regulatory requirements.

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 your information within TD 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.

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.

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)
• 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, financial abuse, fraud, criminal activity, protect our assets and interests, or manage or settle any actual or potential loss or in the case of a breach of agreement or contravention of law.
  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 a business or sell parts of our businesses/assets or consider those transactions. As our businesses consist primarily of our customer relationships, information regarding the particular accounts or services being purchased or sold would generally be part of the business assets.
• Other situations where we have your consent
  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 also disclose your account information to a joint account holder, including information about the account prior to it becoming a joint account.

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 your 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 TDGI 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 or for legal or regulatory purposes. When your information is no longer needed for these purposes, we have procedures to destroy, delete, erase or convert it to an anonymous form.

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

Any request to TD Insurance, General Insurance to access your information should be sent to our Privacy Officer in writing at the following address:

TD Insurance, General Insurance
Privacy Officer
50 Place Crémazie
12th Floor
Montréal, Québec H2P 1B6

We will ask you for specific details such as account numbers.

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, from our records, about you 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.

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

Having accurate information about you enables us to provide you with better service and minimize the possibility that out-of-date information may be used to make a decision that 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.

We will explain your option to withdraw your 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 your TD Insurance Client Services Centre at 1-877-777-7136 (University students/Alumni & Professionals) or 1-866-361-2311 (others). Our staff will be pleased to explain your options and any consequences of 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 –

• Contact you by telephone, fax, text messaging, or other electronic means, and automatic dialing-announcing device, at the numbers you have provided us, or by ATM, internet, mail, email and other 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 preference into account.

• Share your information within TD in certain circumstances
• Contact you to participate in customer research and surveys

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.

Many concerns can be resolved right at the time when they occur. Discuss your concern with your TDIGI Representative who will be happy to help you.

Further steps you can take:

If the TDIGI Representative is not able to resolve your concern to your satisfaction or if, after the first step, you are still not satisfied that your concern has been resolved, TDIGI offers two more internal levels that can help you.

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 TD Insurance Customer Care Department.

How to contact us:

TD Insurance Customer Care Department
320 Front Street West, 3rd Floor
PO Box 1
Toronto ON
M5K 1A2
Canada

Phone

1-877-734-1288

Email

tdinscc@TD.COM

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

The Senior Customer Complaints Office 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.

• Phone: 1-888-361-0319 or 416-982-4884
• Email³: td.scco@td.com
• Mail: P.O. Box 1, Toronto-Dominion Centre Toronto, ON M5K 1A2
• Fax: 1-866-891-2410 or 416-983-3460

Include your full name, address, telephone number(s) and the details of your concern in your letter, email or fax.

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 Senior Customer Complaints Office.

General Insurance OmbudService (GIO)
4711 Young Street,
10th Floor
Toronto, ON M2N 6K8

This Online Privacy Code tells you how we handle the information we collect when you use our websites.

Our use of cookies

Cookies are snippets of data stored by a web browser (e.g. Chrome, Safari or Firefox). Your internet browsing activity can be collected and used to personalize your online experience when you search for information. Through the use of cookies and other technologies, TD Insurance can enhance your experience with personalized content and offers that may be relevant to you. This technology also enables TD Insurance's third-party advertising partners to assist us in presenting ads specific to your interests across the internet.

We may use cookies for the following purposes:

• to learn:
  • which pages you visit and how you interact with our websites; and
  • which websites, advertisements, and keywords used for searches brought you to our websites;
• to remember your language preference and automatically input your Access Card number or Connect ID if you choose this option on our login screen;
• to assist us in authenticating you and your computer, administer our secure websites and for fraud prevention or investigation purposes;
• to reduce the likelihood that any online offer that you have already responded to is not presented again;
• to personalize your experience, including:
  • for the purposes of delivering offers, advertisements and page content tailored to products and services that may be of interest to you based on your browsing of our TD Insurance⁴ websites. See the “Managing Your Cookies” section below for information about how to opt-out;
  • to contact you occasionally either by telephone, text messaging, or other electronic means and automatic dialing-announcing device, at the numbers you have provided us, or by fax, mail, email, or, and other methods; or all of these methods, with marketing offers that may be of interest to you based on the content you browse on our websites. If you prefer, you may choose not to have us contact you with marketing offers by contacting your TD Insurance Client Services Centre at 1 877-777-7136 (University students/Alumni & Professionals) or 1 866-361-2311 (Others)";
• to tailor our online advertising that may be delivered to you via third parties (see the “Our Advertising” section below for more information);
• to assist us with application support issues and to aid in fraud investigations; and
• to determine how many people visit our websites and which sections of the websites are visited most frequently. This helps us understand what type of information is most useful to our website visitors so we can improve our websites and make it easier for our website visitors to access information.

Managing your cookies

Personalization of TD Insurance content⁵ - You can opt-out of personalization on these websites using the Ad Choices & Personalization link, available at the bottom of our websites.

Essential cookies - TD Insurance uses cookies to make various features available through our websites, and to help ensure the security of your online browsing experience. Some cookies are required for various features of our websites. They also help ensure the security of your browsing experience. You cannot opt-out of the use of essential cookies, other than disabling the ability for your browser to accept cookies. If you choose to disable the cookies feature on your browser, some of our websites might not work properly and your experience may be less than optimal. For example, you will not be able to access any of our secured websites as cookies are used for security and multi-factor authentication, as well as for fraud prevention or investigation purposes. If you adjust your browser settings to refuse cookies, you may also still receive some of our generic TD Insurance-branded ads, but these will not be served to you based on your preferences or the products and services that you hold with us.

Our Advertising

We subscribe to the DAAC’s Self-Regulatory Principles for Online Behavioral Advertising, which promote consumer awareness and choice about how their information is used for Online Behavioral Advertising. We do not respond to "do not track" signals transmitted by web browsers or similar mechanisms.

Third Party advertising tracking - TD Insurance and third parties (our digital partners⁶ ) may use cookies for the purposes of delivering tailored TD Insurance advertising to you on third party websites. TD Insurance uses cookies and other technologies that track online behavior. We are able to track which of our ads you interact with on third-party websites and your activity on TD Insurance Branded sites. This enables us to provide ads that are more relevant to you.

You can view a list of our third party ad partners and opt-out of our interest-based advertising on third-party websites through the TRUSTe⁷ tool. Opting out will block these third parties from other sites you may visit as well.

Manage internet-based ads

Depending on your marketing preferences, we may collect and use information about your relationship with us to help determine which ads or offers to present to you on third party sites, such as social media or webmail sites with which you have a relationship. To opt-out of receiving such relationship-based ads, you can update your settings on your social media or webmail sites or, where the third party websites provide an opt-out, through the TRUSTe tool. Opting out will block these third parties from other sites you may visit as well. If you click on one of our ads on a third party website, cookies may also be used to track the effectiveness of our online advertising and for the purposes of delivering ads that may be relevant to you in the future.

Click the AdChoices icon on the ad and follow the instructions, or visit http://youradchoices.ca/choices/. Please note that if you opt-out, you may still see some of our generic TD Insurance-branded ads, but these will not be served to you based on your inferred interests or web browsing activity on our TD Insurance websites.

You can also opt-out of having our digital partners use information about your current or future usage of our websites to tailor TD Insurance advertisements via the Manage internet-based ads link.

Search engine interest-based tracking - You can also opt-out of interest-based search engine ads. Just select the notification icon after the URL within the ad text. You may still see our generic TD Insurance branded ads after you opt-out. These are not linked to your interests or browsing history.

Responding to surveys online

When you submit your response online to a survey question, we receive your answer or any opinions or information that you volunteer. We may also use your response to improve our products or services.

Data collection through our digital properties

When you visit our websites, we may also collect:

• your Internet protocol (IP) address;
• your Internet service provider (ISP) and the region from which you’re connecting to our websites; and
• attributes related to the device and browser you are using to connect to our websites (e.g. operating system type and version, current language, browser version and plug-ins, screen resolution etc.).

We use this information for the purposes of optimizing our websites and the content we make available, and to help secure your connection to our websites and for fraud prevention and investigation purposes.