The TD Insurance, General Insurance 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), including TD Insurance, General Insurance² (TDIGI) as a member of TD.

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

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

General Insurance Privacy Code

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 Mobile Apps Privacy Code
Privacy Agreement

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 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, to contact you about products or services you may be interested in having with us, to help us collect a debt or enforce an obligation owed to us by you 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 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 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.

Why we ask for your information

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.

  • 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 or claims process.

    TDIGI never uses credit information to refuse to issue, or cancel a policy, or to determine your financial ability to pay the premium. Because 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.

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 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 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.

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.

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).

  • 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 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.

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 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 TDIGI 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.

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.

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
12 th 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 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 provide 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 preferences

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 leaving us a message at 1 866 323 0266 or by contacting our client services centre. 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

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 TDIGI Representative

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.

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 TD Insurance Customer Care Department.

How to contact us:

TD Insurance Customer Care Department
120 Adelaide St W.
PO Box 1
Toronto ON
M5H 1T1
Canada

Phone
1-877-734-1288

Email
tdinscc@TD.COM


Please include your full name, address and telephone number.

STEP 3
Contact the TD Insurance Ombudsman

If you have been through the first two steps and you still feel your concern has not been resolved, please contact the TD Insurance Ombudsman. The office of the TD Insurance Ombudsman 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 TD Insurance Ombudsman, the office will conduct a thorough and impartial investigation and work to reach a fair and reasonable resolution.

The TD Insurance 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 Insurance Ombudsman, contact

  • Phone: 416-773-4715 or 1-866-337-3314 ext. 4715
  • Email³: ombudsman@tdinsurance.com
  • Mail: 3560 Victoria Park Ave, 9th floor
    Toronto, ON M2P 3P7
  • Fax: 416-774-3196

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).

General Insurance OmbudService (GIO)
10 Milner Business Court
Suite 701
Toronto, Ontario M1B 3C6

Our Online Privacy Code


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

Our use of Cookies


A cookie is a small amount of data that is stored by your web browser when you visit certain websites. Cookies may be used to track the activities of your browser as well as provide you with a consistent, more efficient experience.

We may use cookies for purposes such as:

  • 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:
    • 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.
    • 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 to understand what type of information is most useful to our website visitors so that we can improve our websites and make it easier for our website visitors to access information.

Essential Cookies – TD uses cookies to make various features available through our websites, and to help ensure the security of your online 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 disable the ability for your browser to accept cookies, some of our websites may not function properly or optimally. 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 Advertising


Interest-based Ads on Third Party Websites Using Cookies – TD and our digital partners⁴ may use cookies for the purposes of delivering tailored TD advertising to you on third party websites. 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.
You can opt-out of our interest-based advertising presented to you on third party websites based on your past use of our websites through the TRUSTe tool available at: http://preferences.truste.com/truste/. You can opt out of interest-based advertising on search engine ads by clicking on the notification icon found in the ad on the search engine results page. 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 retail-branded websites.

Relationship-based Ads on Third Party Websites –
Depending on your marketing preferences, we may use your contact information for the purposes of enabling the delivery of tailored TD ads on third-party websites such as social media or webmail sites with which you have a relationship. To opt-out of receiving such relationship-based ads update your settings on your social media or webmail sites.


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.


Technical Information


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.


Our Mobile Apps Privacy Code

This Mobile Apps Privacy Code tells you how we handle the information we obtain from you when you use our mobile apps. If you are using your mobile device, such as a mobile phone or tablet, to access TD websites, please refer to our Online Privacy Code.

What information we collect and how we use it

Depending on the TD mobile 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, IP address, device ID, mobile country code, and Integrated Circuit Card Identifier.

We may use your information to provide or enhance the app-specific products or services you request from us or to improve the functionality of our TD apps.

We may also use and disclose your information as described in the Privacy Agreement located on our website.

Please note that the ability to collect certain personal information is controlled by your device, for example geolocation. Please refer to the documentation for your device regarding how to allow or block the collection of location or device information. If you choose not to provide location or certain device information, some services you request may not operate effectively.


Defined Terms

  • Device ID:
    A unique number that identifies your device.
  • Geolocation:
    Approximate physical location of your device.
  • Integrated Circuit Card Identifier:
    A unique serial number that identifies your SIM Card.
  • IP Address:
    A unique numerical label that identifies your device and allows it to communicate over a computer network.
  • Mobile Country Code:
    A three digit number that indicates the country in which your mobile device is registered. For example, 302 is the mobile country code for Canada.
  • Transactional data:
    data related to the transactions you are conducting including your financial data such as your credit card number, nickname and expiry date, account information you may provide and other information arising from your use of the app.


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.

² The TD Insurance home and auto products are underwritten by TD General Insurance Company in Ontario and by Primmum Insurance Company and TD Home and Auto Insurance Company in the rest of Canada.

The TD Insurance Meloche Monnex program for members of participating professional and alumni groups is underwritten by Security National Insurance Company. It is distributed by Meloche Monnex Insurance and Financial Services inc. in Quebec, by Meloche Monnex Financial Services Inc. in Ontario and by TD Insurance Direct Agency Inc. in the rest of Canada.

The TD Insurance Meloche Monnex program for members of participating employer groups and other Associations is underwritten by Primmum Insurance Company. The program is distributed by Meloche Monnex Insurance and Financial Services inc. in Quebec and TD Insurance Direct Agency Inc. in the rest of Canada.

³ Email or fax disclaimer: For your protection, do not send confidential or personal information (e.g. Access Card number, account numbers, etc.) via email or fax, 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.

⁴ The digital partners we use for interest-based advertising through cookies include:

  • Google DART for Advertisers (DFA)
  • Google Adwords
  • Facebook

®/ 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.


 

TD Privacy Agreement


Our Privacy Agreement explains how we collect, use and disclose your personal information and outlines your options to withdraw or refuse your consent. For more information, please also read our Privacy Code. For additional privacy terms and conditions specific to your product or service, please refer to the Privacy Agreement provided to you with such product or service.

In this Agreement, the words "you" and "your" mean any person, or that person's authorized representative, who has requested from us, or offered to provide a guarantee for, any product or service offered by us in Canada. The words "we", "us" and "our" mean TD Bank Group ("TD"). TD includes The Toronto-Dominion Bank and its world-wide affiliates, which provide deposit, investment, loan, securities, trust, insurance and other products or services. The word "Information" means personal, financial and other details about you that you provide to us and we obtain from others outside TD, including through the products and services you use.

You acknowledge, authorize and agree as follows:

COLLECTING AND USING YOUR INFORMATION

At the time you begin a relationship with us and during the course of our relationship, we may collect Information including:
  • details about you and your background, including your name, address, date of birth, occupation and other identification
  • records that reflect your dealings with and through us
  • your preferences and activities.

This Information may be collected from you and from sources within or outside TD, including from:
  • government agencies and registries, law enforcement authorities and public records
  • credit reporting agencies
  • other financial or lending institutions
  • organizations with whom you make arrangements, other service providers or agents including payment card networks
  • references or other information you have provided
  • persons authorized to act on your behalf under a power of attorney or other legal authority
  • your interactions with us, including in person, over the phone, at the ATM, on your mobile device or through email or the Internet
  • records that reflect your dealings with and through us.

You authorize the collection of Information from these sources and, if applicable, you authorize those sources to give us the Information.

We will limit the collection and use of Information to what we require in order to serve you as our customer and to administer our business, including to:
  • verify your identity
  • evaluate and process your application, accounts, transactions and reports
  • provide you with ongoing service and information related to the products, accounts and services you hold with us
  • analyze your needs and activities to help us serve you better and develop new products and services
  • help protect you and us against fraud and error
  • help manage and assess our risks, operations and relationship with you
  • help us contact a debt or enforce an obligation owed to us by you
  • comply with applicable laws and requirements of regulators, including self-regulatory organizations.
DISCLOSING YOUR INFORMATION

We may disclose Information, including as follows:
  • with your consent
  • in response to a court order, search warrant or other demand or request, which we believe to be valid
  • to meet requests for  information  from  regulators, including self-regulatory organizations of which we are a member or participant, to satisfy legal and regulatory requirements applicable to us
  • to suppliers, agents and other organizations that perform services for you or for us, or on our behalf
  • to payment card networks in order to operate or administer the payment card system that supports the products, services or accounts you have with us (including for any products or services provided or made available by the payment card network as part of your product, services or accounts with us), or for any contests or other promotions they may make available to you
  • on the death of a joint account holder with right of survivorship, we may release any information regarding the joint account up to the date of death to the estate representative of the deceased, except in Quebec where the liquidator is entitled to all account information up to and after the date of death
  • when we buy or sell all or part of our businesses or when considering those transactions
  • to help us collect a debt or enforce an obligation owed to us by you
  • where permitted by law.
You may not withdraw your consent for these purposes.

Within TD we may also share Information world-wide, other than health-related Information, to allow other businesses within TD to tell you about products and services. In order to understand how we use your Information for marketing purposes and how you can withdraw your consent, refer to the Marketing Purposes section below. SHARING INFORMATION WITHIN TD

Within TD we may share Information world-wide, other than health-related Information, for the following purposes:
  • to manage your total relationship within TD, including servicing your accounts and maintaining consistent Information about you
  • to manage and assess risks and operations, including to collect a debt owed to us by you
  • to comply with legal or regulatory requirements.
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ADDITIONAL COLLECTIONS, USES AND DISCLOSURES

Social Insurance Number (SIN). If requesting products, accounts or services that may generate interest or other investment income, we will ask for your SIN for revenue reporting purposes. This is required by the Income Tax Act (Canada). If we ask for your SIN for other products or services, it is your option to provide it. When you provide us with your SIN, we may also use it as an aid to identify you and to keep your information separate from that of other customers with a similar name, including through the credit granting process. You may choose not to have us use your SIN as an aid to identify you with credit reporting agencies.
 
Credit Reporting Agencies and Other Lenders. For a credit card, line of credit, loan, mortgage or other credit facility, merchant services, or a deposit account with overdraft protection, hold and/or withdrawal or transaction limits, we will exchange information and reports about you from credit reporting agencies and other lenders at the time of and during the application process, and on an ongoing basis to review and verify your creditworthiness, establish credit and hold limits, help us collect a debt or enforce an obligation owed to us by you, and/or manage and assess our risks. You may choose not to have us conduct a credit check in order to assess an application for credit. Once you have such a facility or product with us and for a reasonable period of time afterwards, we may from time to time disclose your Information to other lenders and credit reporting agencies requesting such Information, which helps establish your credit history and supports the credit granting and processing functions in general. We may obtain Information and reports about you from Equifax Canada Inc., Trans Union of Canada, Inc. or any other credit reporting agency. You may access and rectify any of your personal information contained in their files by contacting them directly through their respective websites www.consumer.equifax.ca/ and www.transunion.ca/. Once you have applied for any credit product with us, you may not withdraw your consent to this exchange of Information.

Fraud. In order to prevent, detect or suppress financial abuse, fraud, criminal activity, protect our assets and interests, assist us with any internal or external investigation into potentially illegal or suspicious activity or manage, defend or settle any actual or potential loss in connection with the foregoing, we may collect from, use and disclose your Information to any person or organization, fraud prevention agency, regulatory or government body, the operator of any database or register used to check information provided against existing information, or other insurance companies or financial or lending institutions. For these purposes, your Information may be pooled with data belonging to other individuals and subject to data analytics.

Insurance. This section applies if you are applying for, requesting prescreening for, modifying or making a claim under, or have included with your product, service or account, an insurance product that we insure, reinsure, administer or sell. We may collect, use, disclose and retain your Information, including health-related Information. We may collect this information from you or any health care professional, medically-related facility, insurance company, government agency organizations who manage public information data banks, or insurance information bureaus, including MIB Group, Inc. and the Insurance Bureau of Canada, with knowledge of your Information.

With regard to home and auto insurance, we may also obtain Information about you from credit reporting agencies at the time of, and during the application process and on an ongoing basis to verify your creditworthiness, perform a risk analysis and determine your premium.

We may use and disclose your Information to:
  • determine your eligibility for insurance coverage
  • administer your insurance and our relationship with you
  • determine your insurance premium
  • investigate and adjudicate your claims
  • help manage and assess our risks and operations.

We may share your Information with any health-care professional, medically-related facility, insurance company, organizations who manage public information data banks, or insurance information bureaus, including the MIB Group, Inc. and the Insurance Bureau of Canada, to allow them to properly answer questions when providing us with Information about you. We may share lab results about infectious diseases with appropriate public health authorities.

If we collect your health-related Information for the purposes described above, it will not be shared within TD, except to the extent that a TD company insures, reinsures, administers or sells relevant coverage and the disclosure is required for the purposes described above. Your Information, including health-related Information, may be shared with administrators, service providers, reinsurers and prospective insurers and reinsurers of our insurance operations, as well as their administrators and service providers for these purposes.

Marketing Purposes. We may also use your Information for marketing purposes, including to:
  • tell you about other products and services that may be of interest to you, including those offered by businesses within TD and third parties we select
  • determine your eligibility to participate in contests, surveys or promotions
  • conduct research analysis, modeling and surveys to assess your satisfaction with us as a customer, and to develop products and services
  • 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 respect to these marketing purposes, you may choose not to have us:
  • contact you occasionally either by telephone, fax, text message, ATM, internet, mail, email, or all of these methods, with offers that may be of interest to you
  • contact you to participate in customer research and surveys.

Telephone and Internet Discussions. When speaking with one of our telephone service representatives, internet live chat agents, or messaging 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.
MORE INFORMATION

This Agreement must be read together with our Privacy Code which includes our Online Privacy Code and our Mobile Apps Privacy Code. You acknowledge that the Privacy Code forms part of the Privacy Agreement. For further details about this Agreement and our privacy practices, visit www.group.tdinsurance.com/en/privacy or contact us for a copy.

You acknowledge that we may amend this Agreement and our Privacy Code from time to time. We will post the revised Agreement and Privacy Code on our Website listed above. We may also make them available at our branches or other premises or send them to you by mail. You acknowledge, authorize and agree to be bound by such amendments.

If you wish to opt-out or withdraw your consent at any time for any of the opt-out choices described in this Agreement, you may do so by contacting us at
1 866 323 0266. Please read our Privacy Code for further details about your opt-out choices.

Questions and Answers

Why do you collect personal information and how is it used?

We ask you for personal information in order to establish your insurance needs and provide you with the best possible service. The information we collect is used in the normal course of business to assess your insurance needs, communicate with you, apply the underwriting and rating criteria, issue insurance documents and settle your claims. It is kept in your file.

Either before, or at the time 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 use it only for those purposes. We will obtain your consent first if we wish to use your information for any purpose other than assisting you with your insurance needs, and before collecting information from third parties.

What personal information do you collect?

We obtain most of your personal information directly from you. The information we ask for depends on which product or service you request. For every product or service, we need your name, address and other identification information, including:

  • Birth date

    This helps us identify you and ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products, services or discounts that may apply to a particular age group.

  • Claims 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

    Financial information, such as a bank account number or a credit card number, is mainly collected for payment purposes. For example, because the majority of our clients opt to pay using Pre-Authorized Chequing, we will usually require an account number to process payments. When a payment is made by cheque or money order, we may contact a client’s bank to verify it.

    We may also verify information from a client’s credit report. This information is only one element among others, including your claims history and driving record, for example, that we review in the underwriting or claims process.

    We will never use credit information to refuse to issue, or cancel a policy, or to determine your financial ability to pay the premium. The process of verifying credit 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. There are no negative consequences to the request for a credit history by an insurance company. It is not considered a credit check and does not in any way affect your credit rating.

    When we obtain 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 only in specific cases to determine whether you have special medical conditions that may affect your coverage or claim.

    In these cases, we only collect the information we need for the purposes explained to you. If ever we wish to use it for other purposes in future, we will ask you for your consent at that time and explain why.

    Is my personal information shared with your affiliated companies?

    The TD Insurance Meloche Monnex program is underwritten by TD General Insurance Company, Primmum Insurance Company and TD Home and Auto Insurance Company.

    TD Insurance Meloche Monnex is a trademark of The Toronto-Dominion Bank and a trade name of Primmum Insurance Company, TD Home and Auto Insurance Company and TD General Insurance Company.

    The TD Insurance Meloche Monnex is a member of the TD Bank Financial Group, one of the leading financial services organizations in Canada. With your consent, we will share your information within the TD Bank Financial Group to help us serve you better and ensure we meet your expectations. It is important to note that you can withdraw your consent at any time.

    Sharing your information allows us to instantly recognize you as a client of the TD Bank Financial Group, no matter when or where you contact us. It also helps us to understand your financial needs by allowing us to review what TD Bank Financial Group products you have and how you use them. With this information, we may offer you other TD Bank Financial Group products and services – including special promotions – that we believe will be of interest to you.

    Note: Any health information provided to us in connection with an insurance product is never shared.

Is personal information released to third parties?

Under no circumstances do we sell client lists or personal information to others. When information about you is released, it is always with your consent, unless we are required or permitted to do so by law.

  • To serve you better

    We provide a limited amount of information, only as necessary, to our personnel and select representatives (suppliers and agents), for activities such as marketing campaigns or satisfaction surveys.

    For example, we may share your information with suppliers like body shops, car rental agencies, cleaning firms, appraisers, mailing houses or information technology firms, but only for the purposes of assisting you with your insurance needs.

  • When required or permitted by law

    In cases where your personal information is required or permitted by law, we must provide the information in response to a valid demand, search warrant or other legally valid enquiry or order. We may exchange information with third parties such as police forces or independent claims experts in the event of an enquiry with respect to a loss. We may also disclose information to an investigative body in the case of a breach of agreement or contravention of law in order to help prevent fraud, money laundering or other criminal activity.

  • Transfers of a business

    As TD Insurance Meloche Monnex continues to grow, we may acquire new businesses or sell parts of our existing business. As part of these transactions, personal client information and information regarding the insurance product or service purchased would generally be among the transferred business assets.

Does TD Insurance Meloche Monnex ask for personal information from third parties?

With your consent, we may obtain information about you from third parties, such as previous insurers, government organizations who manage public information data banks, or insurance information bureaus (according to provincial laws).

Obtaining additional information from these third parties helps us to verify the information provided, evaluate your needs and assess your eligibility for our products and services or for our group rates.

For example, for automobile insurance, we need to know your driving history. For this reason, we may obtain a Motor Vehicle Report. We will not do this without your consent; however, it is important to note that if you do not give your consent, we may not be able to insure you.

How is my personal information protected?

We maintain rigorous security standards to protect our systems and your personal information against unauthorized access and use.

All of our personnel and select representatives (suppliers and agents) 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 enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required.

All of our personnel are familiar with the procedures that must be taken to safeguard client information. We understand that protecting the confidentiality of your information is more than a formality – it’s an integral part of our job. It is spelled out in our employment agreements and regularly confirmed in writing.

We audit our procedures and security measures regularly to ensure that they are being properly managed and that they remain effective and appropriate.

We retain your information only as long as it is required, and only for the reasons it was collected.

The length of time we keep 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 as long as is legally necessary in order 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.

How can I access the information in my file?

To access the information in your file, you should send your request, in writing, to our Privacy Officer at the following address:

TD Insurance Meloche Monnex
Privacy Officer
50 Place Crémazie
Floor 12
Montréal, Québec
H2P 1B6

We will respond to your request within 30 days. Please note that we may not be able to provide personal information found in your file which contains references to third parties, or information that is subject to legal privilege, contains confidential information proprietary to TD Insurance Meloche Monnex, relates to an investigation of a breach of an agreement or a contravention of the law, or cannot be disclosed for other legal reasons.

Who do I contact if I want to withdraw my consent?

You have the right to withdraw your consent at any time.

We will be pleased to explain your options and record your choices, as well as explaining any consequences associated with a decision to refuse or withdraw your consent. If you do not want us to share your personal information within the TD Bank Financial Group or contact you with product information, you can tell us so at any time, by leaving us a message at 1-866-823-4737.

Who do I contact if I have questions or concerns?

  1. If you have any questions or concerns about a privacy or confidentiality issue, please do not hesitate to contact our Privacy Officer in writing at the following address:

    TD Insurance Meloche Monnex
    Privacy Officer
    50 Place Crémazie
    Floor 12
    Montréal, Québec H2P 1B6

  2. If your problem or concern still remains unresolved, you may contact one of the following:

    General Insurance OmbudService (GIO)
    55 St. Clair Avenue West
    Suite 255
    Toronto, Ontario M4V 2Y7

    Office of the privacy commissioner of Canada
    112 Kent Street
    Place de Ville
    Tower B
    Floor 3
    Ottawa, Ontario K1A 1H3
    www.privcom.gc.ca

  3. You can also contact the appropriate provincial body that oversees such concerns.