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 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.
• 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 or other 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.

• Preferred name
  If you provide us with a preferred name or chosen name, over time this will be used to communicate with you in person, digitally, by phone, and via mail, including on certain account-related and regulatory communications. In some cases, it will be necessary to continue to use your legal name, for example, on account statements.

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 confirm our discussions with you.

Customers who prefer not to have their calls taped can transact business at a branch location, through EasyWeb® online 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 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 through EasyWeb online 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.
  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 discussions 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.
  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 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.

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.

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, 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 or asset
  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 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 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.

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

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, 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 options of 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 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 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 preferences into account.
• Share your financial information within TD in certain circumstances.
  We can restrict access to your profile such that only certain groups within TD have access to your account number(s) and balance(s).
• Contact you to participate in customer research and surveys.

At TD, we take your complaints seriously and are committed to helping resolve your complaint about TD or the service you’ve received.

Usually, the best way to address the complaint is to raise the issue as soon as it comes up with the person you are dealing with. Even if you don’t notice the issue right away, you can always get in touch with us at any time to voice your complaint. Please use any one of the contact options provided below.

Before you begin:

• Have any supporting documents available.
• Consider what solution you think is appropriate

To help us serve you better, please follow these three steps:

You can escalate your complaint in the following ways:

1. Ask the individual you are dealing with in Step 1 to escalate on your behalf.
2. Escalate the complaint directly with Customer Care, using the following contact information.

For your own security and safety, never send your account numbers, PINs, user names, passwords or any other confidential information by e-mail.

Personal Banking, Business Banking & Lending Services

(Includes TD Canada Trust, TD Auto Finance, TD Financing Services Inc. (TDFS) – Credit Cards)
Phone: 1-888-661-9029
Email: customer.care@td.com
Mail: Customer Care, Toronto-Dominion Centre,
P.O. Box 1, Toronto, ON M5K 1H6

For mbna complaints that are not insurance related, use the contact information below:

Mail: Attention: MBNA Customer Relations, 1600 James Naismith Drive, Ottawa, Ontario K1B 5N8
Phone: 1-877-405-6262 (toll-free)
E-mail: customerrelations@td.com

For mbna complaints related to insurance:

Mail: TD Insurance Customer Care, 320 Front Street W., 3rd Floor, Toronto, ON M5V 3B6
Phone: 1-877-734-1288
E-mail: TDINSCC@td.com

Insurance Services

(TD Insurance)
Phone: 1-877-734-1288
Email: tdinscc@td.com
Mail: Customer Care, Toronto-Dominion Centre,
P.O. Box 1, Toronto, ON M5K 1A2

If you are not satisfied with the resolution provided from Customer Care in Step 2, you can proceed to Step 3 to escalate to the Senior Customer Complaints Office.

TD Investment Services Inc.

Phone: 1-888-661-9029
Email: customer.care@td.com
Mail: Canadian Personal Banking Customer Care, Toronto-Dominion Centre, P.O. Box 1, Toronto, ON M5K 1A2

TD Wealth Management & Direct Investing Services

(Includes TD Wealth and TD Direct Investing)
Fax: 1-877-725-9525
Email: td.waterhouse@td.com
Mail: Client Complaint Resolution Team,
P.O. Box 5999, Station F, Toronto, ON, M4Y 2T1

For complaints relating to TD Investment Services Inc. and TD Wealth Management & Direct Investing Services, our response in Step 2 will summarize your complaint and our findings, and will contain a reminder about escalation options available to you, including Step 3, should your concerns not be addressed to your satisfaction.

If you are not satisfied with the resolution provided in Step 2, you can proceed to Step 3 to escalate your concern to the Senior Customer Complaints Office (an affiliated service that is a voluntary process described in Step 3) and/ or the Ombudsman for Banking Services and Investments (OBSI). For residents of Québec, you may proceed to Step 3 to escalate your concern to the Autorité des marchés financiers (AMF).

You may immediately escalate your complaint to the OBSI directly if we do not provide you with a response within 90 days of your complaint. If you wish to escalate your complaint to the OBSI directly because we have not provided you with a response within 90 days of your complaint, and we later provide you with a response, you must do so within 180 days of our response.

If your complaint relates to TD Private Banking or TD Private Trust, you may escalate your concern to the Senior Customer Complaints Office. If you are not satisfied with the response of the Senior Customer Complaints Office or you do not receive a response from the Senior Customer Complaints Office after 56 days have passed since you raised your complaint in Step 1, you may escalate your complaint to the ADR Chambers Banking Ombuds Office (ADRBO).

If your complaint relates to Wealth Insurance Services, you may escalate your concern to the Senior Customer Complaints Office if you are not satisfied with our response. If you are not satisfied with the response from the Senior Customer Complaints Office, you may escalate your complaint to the OmbudService for Life & Health Insurance (OLHI).

TD Securities Inc.

If you are not satisfied with the resolution provided by your relationship manager, you can contact TD Securities Inc. Compliance at the email address below or proceed directly to Step 3.

Email: TDSINSTEQCOMP@tdsecurities.com

TD Asset Management Inc.

In the event a problem or concern is not resolved with your relationship manager or TDAM associate, it can be escalated to TDAM’s Managing Director, Head of Institutional Distribution.

Phone: 1-888-834-6339/ 416-983-0055
Email: inst.info@tdam.com
Mail: TD Asset Management Inc., 161 Bay Street, 34th Floor, Toronto, ON M5J 2T2

If you are not satisfied with the resolution provided by the Managing Director, Head of Institutional Distribution and/or we did not provide you with a response within 90 days of the date you filed your complaint, please proceed to Step 3. For residents of Québec, you may proceed to Step 3 to escalate your concern to the Autorité des marchés financiers (AMF).

If you are not satisfied with the resolution provided in Step 2, please proceed to Step 3.

At Step 3, there are several escalation options that may provide further review of your concern or additional information.

Escalate to the Senior Customer Complaints Office

The Senior Customer Complaints Office is an impartial body within TD responsible for reviewing customer complaints that remain unresolved after the completion of the first two steps of TD’s Customer Problem Resolution Process.

The Senior Customer Complaints Office will investigate complaints and act as a liaison between customers and all business areas within TD Bank Group in Canada. While the Senior Customer Complaints Office does not report directly to any business areas in order to protect the office's impartiality, it is not an independent dispute resolution service. The mandate of the Senior Customer Complaints Office is to review your concerns and provide a response that is objective and unbiased.

When escalating to the Senior Customer Complaints Office, please be sure to provide us with your contact information, details of your concerns, and your proposed resolution. You can send your complaints to:

Email²: td.scco@td.com
Mail: Attn: Senior Customer Complaints Office P.O. Box 1, Toronto-Dominion Centre, Toronto, ON M5K 1A2

If you have questions about the Senior Customer Complaints Office's process, or require assistance in escalating your complaint you can reach us at 1-888-361-0319 or visit our website below for more information: https://www.td.com/to-our-customers/scco.jsp

The use of the Senior Customer Complaints Office is voluntary. The estimated time that the Senior Customer Complaints Office takes to review and provide a response to matters varies; however, complex investigations may take longer to resolve. Please note that statutory limitation periods may continue to run while the Senior Customer Complaints Office reviews a complaint, which could impact the ability to commence a civil action.

For Personal Banking, Business Banking & Lending Services, Private Banking, Private Trust Complaints

You can submit your complaint to ADRBO for review once you have received a response in writing from the Senior Customer Complaints Office and wish to escalate, or after 56 days have passed since you raised your complaint in step 1.

ADR Chambers Banking Ombuds Office (ADRBO)
Website: www.bankingombuds.ca
Phone: 1-800-941-3655
Email: contact@bankingombuds.ca
Mail: 31 Adelaide Street East, P.O. Box 1006 Toronto, ON M5C 2K4

For Insurance Complaints

Ombudsman for Life & Health Insurance
Website: www.olhi.ca
Phone: 1-888-295-8112
Mail: 20 Adelaide Street East, Suite 802, P.O. Box 29, Toronto, ON M5C 2T6 Attention: General Manager

General Insurance OmbudService
Website: www.giocanada.org
Phone: 1-877-225-0446
Mail: 4711 Yonge Street, 10th Floor, Toronto, ON M2N 6K8

Escalate in Writing to the Ombudsman for Banking Services and Investments (OBSI)

You may also escalate your complaint to the OBSI if you escalated your concern to the Senior Customer Complaints Office and are not satisfied with the response you received. You must escalate your complaint to OBSI within 180 days after receipt of our Step 2 response. The services of the OBSI are independent of TD and free.

In the case of concerns regarding TD Wealth Management (excluding Private Banking and Private Trust), TD Direct Investing, TD Securities Inc., TD Investment Services Inc., and/or TD Asset Management Inc., you may escalate your complaint to the OBSI directly if you are not satisfied with our Step 2 response or if we do not provide you with a response within 90 days of your complaint.

Ombudsman for Banking Services and Investments (OBSI)
Website: www.obsi.ca
Phone: 1-888-451-4519
Email: ombudsman@obsi.ca
Mail: 20 Queen Street West, Suite 2400, P.O. Box 8, Toronto, ON M5H 3R3

Quebec Residents

If you are a resident of Quebec and you have a concern relating to TD Insurance, TD Investment Services Inc., Private Investment Counsel, TD Wealth Insurance Services, Private Trust or TD Asset Management Inc. you may have your file transferred directly to the Autorité des marchés financiers (AMF) for review. The contact information for the AMF is listed under the Industry Regulators and Additional Resources section below.

Industry Regulators and Additional Resources

The following independent services may provide you with information and a further review of your complaint. These agencies may contact TD to facilitate their investigation and work toward a resolution.

Financial Consumer Agency of Canada
Website: www.fcac-acfc.gc.ca
Phone: 1-866-461-3222
Mail: 427 Laurier Avenue W, 6th Floor, Ottawa, ON K1R 1B9

The Mutual Fund Dealers Assoc. of Canada
Website: www.mfda.ca
Phone: 1-888-466-6332
Email: complaints@mfda.ca
Fax: 416-361-9073
Mail: Attn: MFDA Complaints, 121 King Street West, Suite 1000 Toronto, ON M5H 3T9

Investment Industry Regulatory Organization of Canada (IIROC)
Website: www.iiroc.ca
Phone: 1-877-442-4322
Email: investorinquiries@iiroc.ca
Mail: 121 King Street West, Suite 2000 Toronto, ON M5H 3T9

Office of the Privacy Commissioner of Canada (OPCC)
Website: www.priv.gc.ca
Phone: 1-800-282-1376 Fax: 1-819-994-5424
Mail: 30 Victoria Street, Gatineau, QC K1A 1H3

Autorité des marchés financiers (AMF)
Website: www.lautorite.qc.ca
Phone: Quebec City: 418-525-0337
Montreal: 514-395-0337
Other Regions: 1-877-525-0337
Mail: 800, square Victoria, 22e étage C.P. 246, tour de la Bourse, Montréal (Québec) H4Z 1G3

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 can enhance your experience with personalized content and offers that may be relevant to you. This technology also enables TD'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 Canadian retail-branded, TD Wealth, TD Direct Investing and TD Asset Management websites. See the “Managing Your Cookies” section below for information about how to opt out;
  • if you successfully login to EasyWeb or WebBroker, we may personalize your experience based on your customer relationship with us. For example, we may display information and offers about products and services that we feel may be relevant to you based on which products and services you hold with us. This personalization may occur even after you have logged out. 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 ATM, 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 or personalized advertisements based on your online behaviour through one of the methods outlined in this paragraph by contacting the branch or office where your account is held or by calling us at 1-800-430-6095;
• 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 content³ – 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 uses cookies to make various features available through our websites, and to help secure your online browsing experience. Some cookies are required for various features of our websites. They also help secure 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 to accept cookies, 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-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 adverstising

We subscribe to the Digital Advertising Alliance of Canada's self regulatory principles for online behavioural advertising, which promote consumer awareness and choice about how their information is used for online behavioural advertising. We do not respond to "do not track" signals transmitted by web browsers or similar mechanisms.

Third Party advertising tracking – TD and third parties (our digital partners⁴ ) may use cookies and other information for the purposes of delivering tailored TD advertising to you on third party websites and to identify other people with similar interests. TD uses cookies and other technologies that track online behaviour. We are able to track which of our ads you interact with on third-party websites and your activity on TD-branded sites. This enables us to provide ads that are more relevant to you and to other people with similar interests. If you click on one of our ads online, including to contact us by phone, your mobile phone number and cookie related data may be shared with our digital partners and used to track the effectiveness of our advertising and for the purposes of delivering ads that may be relevant to you in the future.

We have also enabled the following Google Analytics Advertising Features:

• Re-Marketing with Google Analytics
• Google Analytics Demographics and Interest Reporting

You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-On. You may opt out of ad serving on Google’s opt-out page.

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 TRUSTe⁵ 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 and to identify other people with similar interests 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 or opt out of our use of your information to identify other people with similar interests, you can update your settings on your social media or webmail sites or, where the third-party websites provide an opt-out option, 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.³

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-branded ads, but these will not be served to you based on your inferred interests or web browsing activity on our TD Canadian retail-branded, TD Wealth, TD Direct Investing and TD Asset Management 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 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-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 Google Maps to provide location-based services (e.g. to help find a TD branch nearby) that you request. When using services offered by Google on TD websites (e.g. Google Maps, Branch Locator), you agree to the collection, processing and storing of the data that is automatically gathered by Google LLC., its representatives and/or third parties. For more information, please visit https://cloud.google.com/maps-platform/terms

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.

We also collect your usage information, including your typing and cursor patterns, while you are logged into your account such as EasyWeb. We use this information for fraud prevention purposes.

Please note the ability to collect certain personal information is controlled by your device. For example your device may control the ability to disclose your device's geolocation or provide access to your contacts, photos and/or camera. Please refer to the documentation for your device regarding how to allow or block the collection of location or certain device information. If you choose not to provide location or certain device information, some services you request may not operate effectively.

This Mobile Apps Privacy Code tells you how we handle the personal information we obtain from you when you use our mobile apps. If you are using a mobile device to access TD websites via mobile browser, please refer to our Online Privacy Code.

Information we collect

Depending on the specific TD app you use, we may collect the following information from you or your device as you use the mobile app: personal information you input into the app, financial information, transactional data, mobile phone number, geolocation (if enabled on your device), mobile country code, contact list (if enabled on your device), IP address, photos and/or camera, other device-related information such as the make and model of your device, its operating system, mobile device identification number (IMEI), MAC address, non-personal Device Identifier (AAID, IDFA), information about the screen size, and the date and time of your use. Please refer to your specific app for additional, applicable information.

How we use this information

We may use this information to provide or enhance the app-specific products or services, to facilitate the operation of our apps, to help us understand how our users use our apps, for our internal analytics and reporting, authentication and security (including fraud prevention), and to improve the functionality of our TD apps.

We may also use and disclose this information as described in the Privacy Agreement located on td.com.

We may disclose your information to our suppliers and agents who assist us in providing mobile app services to you. These suppliers and agents may be located in Canada or other jurisdictions and may access, use or disclose your information to meet legal or regulatory obligations, including responding to requests from government, regulators, courts and law enforcement authorities, in those jurisdictions.

We may also, in alignment with our digital partners (e.g. ad networks) use your non-personal device identifier, Apple Identifier for Advertiser (IDFA) or Google Advertising ID (AAID) for the purposes of delivering TD advertising to you on third-party apps.

If you click on one of our ads on a third- party app, cookies and/or your mobile marketing identifier may also be used to track the effectiveness of our advertising and for the purposes of delivering ads that may be relevant to you in the future.

You can opt-out of our interest-based advertising presented to you on third-party apps through the TRUSTe tool available at: http://preferences.truste.com/truste/4, or by referring to the advertising settings of your mobile device. If you opt out, you may still see some of our generic TD-branded ads on third-party apps.

Please note the ability to collect certain personal information is controlled by your device. For example your device may control the ability to disclose your device's geolocation or provide access to your contacts, photos and/or camera. Please refer to the documentation for your device regarding how to allow or block the collection of location or certain device information. If you choose not to provide location or certain device information, some services you request may not operate effectively.

Why we collect this information

The following chart lists the type of information we collect and why:

Android app permissions

When you download TD’s app on an Android device, depending on your software version, you will be asked to accept some permissions either the first time you download the app, or at the time you access specific features within the app. The following chart lists the Android permissions requested by the TD app and why: