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TD Securities
 

Europe & Asia-Pacific Privacy Policy

Protecting privacy is fundamental to the way TD Bank Group, of which TD Securities is part, does business. TD Securities is committed to safeguarding the personal information we collect and use about individuals and we will only process that information in accordance with all applicable laws.

 

This Policy applies to the following TD entities:

 

Name Country Address
Toronto Dominion Bank, London Branch United Kingdom 60 Threadneedle Street, London, EC2R 8AP
TD Bank Europe Limited United Kingdom 60 Threadneedle Street, London, EC2R 8AP
TD Securities Limited United Kingdom 60 Threadneedle Street, London, EC2R 8AP
Toronto Dominion Bank, Singapore Branch Singapore 1 Temasek Avenue, #15-02 Millenia Tower, Singapore, 039192
Toronto Dominion (South East Asia) Limited Singapore 1 Temasek Avenue, #15-02 Millenia Tower, Singapore, 039192
TD Securities (USA) LLC, Singapore Branch Singapore  1 Temasek Avenue, #15-02 Millenia Tower, Singapore, 039192 
Toronto Dominion Bank, Hong Kong Branch Hong Kong Suite 2210, Two Pacific Place, 88 Queensway, Hong Kong, China
TD Global Finance Limited Ireland Level 2 Plaza 2, Custom House Plaza, International Financial Services Centre, Dublin #1
Toronto Dominion Australia Limited Australia c/o PricewaterhouseCoopers, Darling Park Tower 2, 201 Sussex Street, Sydney NSW 2000

 

In this Policy, any reference to “TD Securities”, “we”, “us” or “our” includes each of the entities listed above. Any reference to “personal information” means any personal data or details from which you may be identified either alone or in conjunction with any other information we may have or be able to access either that you provide to us and/or we obtain from others within or outside TD Bank Group.

 

This Privacy Policy does not apply to TD Securities’ use of personal information collected for any internal purposes such as staff administration. Any such use is covered in separate policies available internally within TD Bank Group. It applies to all other processing of personal information by TD Securities.

 

This Privacy Policy sets out:

  • what personal information we may collect and hold;
  • the purposes for which your personal information may be collected, held, used and disclosed;
  • how we collect and hold your personal information;
  • how we protect your personal information;
  • who we may share your personal information to (including overseas recipients);
  • how you may access and correct your personal information; and
  • how you can contact us.

 

1. The Personal Information We May Collect and Hold

 

TD Securities collects personal information that it believes is reasonably necessary for our primary business functions and/or activities. We generally only collect personal information in the course of

  • working with you as someone associated with an existing or potential corporate or institutional client (e.g. an owner, beneficial owner or their close family members in limited circumstances, a key contact, employee, director or representative); or
  • engaging service providers and professional advisers of TD Securities.

Personal information we collect about you would typically include:

  • Your name and contact details;
  • Your role/position/title, your employer and your area of responsibility; 
  • If applicable, certain identifying information such as address, occupation and a copy of your identification document(s) (for example, your passport) as required by laws and regulations addressing anti-money laundering and related matters.

 

2. The Purposes for Which TD Securities Collects, Holds, Uses and Discloses Personal Information

 

We only collect, hold, use and disclose personal information about you for the purpose for which it was disclosed to us or purposes related to our primary business functions and/or activities which you would reasonably expect us to use it for without your permission.

 

In general, TD Securities collects, holds, uses and discloses personal information for the following essential and necessary purposes:

  • complying with laws and regulations regarding anti-money laundering, anti-terrorist financing, financial abuse, fraud and any other criminal activity, including participating in internal and external investigations if any of these or any other suspicious activities are suspected; 
  • complying with any other legislative and regulatory requirements and requests to which we are subject;
  • engaging service providers, contractors or suppliers relating to the operation of our business; and
  • other primary business-related purposes such as accounts, record keeping and the potential transfer of business interests.

We also collect, hold, use and disclose your personal information for the following optional purposes, though if you do not agree to processing for these purposes then we may not be able to provide you or our corresponding client with our products and services:

  • maintaining contact with our clients and other contacts; 
  • keeping our clients and contacts informed of our services, products and events; and
  • providing financial products or services that have been requested.

 

3. How We Collect and Hold Your Personal Information

 

Whenever it is reasonable and practicable to do so, we will collect personal information about you when you provide it to us or it is provided to us with your authority (for example, by way of forms, face to face meetings, telephone calls, faxes, letters, email and other communications).

 

Occasionally we may collect your personal information from a third party, in particular from authorized, regulatory, public sources such as government regulators, industry self-governing bodies and other publicly available records. This will be most common when we are complying with our legal obligations regarding money laundering and other financial crime. If appropriate, in these circumstances we will either notify you of our sources or seek your consent to their use.

 

We generally hold personal information within paper or electronic files, including emails. This may also include electronic recordings of telephone calls where we are obliged by law or industry regulation to record such calls. We may in some circumstances store personal information with a third party data storage provider. Your personal information may also be held in a secure archiving facility. We will take reasonable steps to ensure that all personal information that we hold or is held on our behalf is protected from misuse and loss and from unauthorised access, modification and disclosure. Please refer to “How we protect your information” below.

 

TD Securities does not use any government-issued identifiers (such as national insurance numbers, tax file numbers or NRICs) as its own identifier.

 

 

4. How We Protect Your Personal Information

 

We have in place a number of technical and organization measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. These include but are not limited to:

  • personal information is only accessible by limited, relevant members of staff, and all staff are bound by duties of confidentiality;
  • all electronic information is held on systems that incorporate firewalls, password-controlled access and virus protection procedures; and 
  • all staff receive annual training regarding data protection and information handling. 

We keep your information for no longer than is necessary for the purpose for which it was collected. When we no longer require your personal information, we will securely destroy and/or delete it from our systems as far as is reasonably and technically possible.

 

While we will always use our best efforts to protect your personal information, please be aware that we cannot guarantee its security, particularly if it is sent over the internet or through any other unsecure channel. 

 

 

5. How We May Share Your Personal Information

 

TD Securities may from time to time disclose personal and sensitive information to:

  • other TD entities within the TD Bank Group, in which case your personal information will be collected, used, disclosed, managed and stored in accordance with this Privacy Policy or local privacy law, whichever has the highest standards of protection. TD Bank Group is headquartered in Toronto, Canada and its main offices are in Australia, Barbados, Bermuda, Hong Kong, Ireland, Luxembourg, Netherlands, Singapore, the United States and the United Kingdom;
  • third party service providers (for example, when we have outsourced certain functions to specialist providers). We will only provide such information as is necessary for the service provider to carry out their function and it will be subject to confidentiality clauses in the applicable services agreement, as well as other clauses reflecting our obligations to you as the controller of your personal information. These service providers may be located in jurisdictions other than that in which your information was collected. When we transfer personal data to third parties in jurisdictions other than yours, TD Securities takes such steps as are reasonable in the circumstances to ensure that the third party does not breach this Privacy Policy or any and all applicable privacy laws. If there is any conflict between these various laws, the law with the highest standard shall prevail;
  • excluding sensitive information and limited to your personal information only, to the financial services industry media and associations, for the purposes of networking and conference organisation and market surveys and awards;
  • regulatory authorities in any jurisdiction in which TD Securities operates, upon their request; or
  • as otherwise required by any applicable laws.

We may share your personal information in other ways if you have expressly consented in advance to that sharing.

 

We do not rent or sell your personal information to third parties.

 

 

6. Access to Personal Information

 

You have the right to request access to the personal information about you in TD Securities’ possession and to request its correction. Subject to confirming your identity and any other requirements required by law, TD Securities will provide you with access to your personal information within a reasonable time frame and in accordance with the local applicable law. Under certain circumstances and where we are permitted to by the local applicable law, we may not provide you with access to certain information. If this occurs, we will explain why in writing to you when we respond to your request. If we deny your request for access on any basis, we will again explain the reasons for this decision in writing to you.

 

To request access please contact the Chief Privacy Officer for TD Securities, Europe and Asia Pacific who will co-ordinate your request. The contact details are set out in the “Contacting us” section below. TD Securities may charge the reasonable costs of providing you with access to your personal information, subject to any limit imposed by local law.

 

 

7. Correction of Personal Information

 

We endeavour to ensure that the personal information that we collect, hold, use or disclose is accurate, complete (in the context of the processing we carry out) and up-to-date. If you believe that any of your personal information that we hold is not accurate, complete or up-to-date, please contact us using the details below and provide us with supporting documents explaining how and/or why our records are incorrect.

 

If we agree that your personal information requires correcting we will take reasonable steps to do so. If we do not agree, we will provide you with the reasons for not correcting your personal information. We will keep a record of your request and our reasons for not agreeing with you.

 

 

8. Requests to Stop Processing

 

You are entitled to ask us at any time to stop processing your personal information, either entirely or specifically in relation to certain purposes such as marketing.

 

If you wish to us to stop processing for specific purposes, for example if you wish to stop receiving any marketing e-mails or other communications from TD Securities, please contact us either on the details set out below or through your usual TD Securities’ contact and ask us to stop / not to send you any further material.

 

If you wish us to stop processing your personal data entirely, please contact us either using the details below or through your usual TD Securities’ contact. Please be aware that if you ask us to stop processing your information for the optional purposes, we may not be able to continue to assist you. For example, we would not be able to contact you about the products or services you or our corresponding client already receive from us, or we would not be able to send you information about other products, services, events or research.

 

We may not be able to stop processing your information where we are required to do so by law (for example, for financial crime-related purposes) or any other necessary purpose. However, if this is the case, we will write to you and explain this.

 

We will endeavour to respond to your request within a reasonable period of time from when we receive it.

 

 

9. Contacting Us

 

If you would like more information about how we manage your personal information or to request access to or correction of your personal information as processed by any of the data controllers listed above, please contact:

 

Chief Privacy Officer, Europe and Asia Pacific
TD Securities
60 Threadneedle Street, London  EC2R 8AP
Privacy.EAP@tdsecurities.com

 

 

10. Complaints

 

If you wish to raise any concerns about a breach or potential breach of your privacy, please contact our Chief Privacy Officer in writing on the details set out above. We will make every effort to resolve your complaint internally and within a reasonable timeframe, escalating it where appropriate. We will inform you of the outcome of our resolution of your complaint.

 

If you are not satisfied with the outcome of your complaint, you may be able to lodge a complaint with your local Privacy regulator. Each regulator may have a different process for lodging complaints and we encourage you to contact your local regulator first to check this. We have set out the contact details for the Privacy regulators in the jurisdictions which this Privacy Policy covers below:

 

Country Regulator Contact Details
Australia Office of the Australian Information Commissioner Inside Australia: 1300 363 992
Outside Australia: + 61 2 9284 9749
enquiries@oaic.gov.au
Hong Kong Privacy Commissioner for Personal Data +852 2827 2827
enquiry@pcpd.org.hk
Ireland  Data Protection Commissioner Inside Ireland: 1890 252 231
Outside Ireland +353 57 868 4800
info@dataprotection.ie
Singapore Personal Data Protection Commissioner +65 6377 3131
info@pdpc.gov.sg
United Kingdom Information Commissioner’s Office +44 303 123 1113

 

This Privacy Policy is reviewed at least once a year. It was last updated on 11 August, 2016.

    December 16, 2017
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