TD Waterhouse - PRIVATE GIVING FOUNDATION PRIVACY CODE



	PRIVATE GIVING FOUNDATION PRIVACY CODE Private Giving Foundation's Privacy Code informs you of our commitment to and policy on privacy. It tells you the ways we help ensure that your privacy and the confidentiality of your information are protected. To review the full text of our Privacy Code, click here. Many of you have questions about how we are handling the information we obtain from you when you visit our websites. We developed an On-Line Privacy Policy to answer your questions about the information we collect when you visit the website of Privacy Giving Foundation and how we use it. To review the full text of our On-Line Privacy Policy, click here. Privacy Code Table of Contents The Private Giving Foundation Commitment to Privacy Our privacy policy Why we ask for your information TD Bank Financial Group - Serving you better 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 policy Who can answer your questions about privacy The Private Giving Foundation commitment to privacy Protecting your privacy and the confidentiality of your personal information is fundamental to the way we do business within Private Giving Foundation. We strive to provide you with the best customer service. To us, that includes treating you fairly and with respect. This Privacy Code informs you of our policy on privacy, and tells you about the ways we help ensure that your privacy and the confidentiality of your information are protected. Top Our privacy policy Our privacy policy applies to donors and other individuals. It consists of five key principles: 1. Collecting and using information Either before or when we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties. Your personal information is used to help us manage our programs, operations and risk within Private Giving Foundation. 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. Call Taping For our mutual protection and to confirm our discussions with you, we may monitor and/or record your telephone discussions with our representatives. 2. Releasing information We may provide your information to other persons: where we have your consent where the other parties are our suppliers or agents who assist us in serving you where we are required or permitted to do so by law or applicable regulators in the event we cease operations, but only to qualified donees as allowed by the Income Tax Act (Canada) 3. Protecting information We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time it is required for the purposes we explain. 4. Providing information access and accuracy We will give you access to the information we retain about you. We will make every reasonable effort to keep your information accurate and up-to-date. 5. Respecting and responding to your privacy concerns In this Privacy Code, we will explain your options for refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your information. In this Privacy Code, we will explain how we fulfill each of these important principles. Top Why we ask for your information We ask you for information to establish and serve you as a donor. We obtain most of our information about you directly from you. For example, to open a Donor-Advised Account or make a donation as a third party donor, we need your name, address, contact particulars, and some identification. We only collect the information we need and only use it for the purposes explained to you. We may use your information to: process your gifts (including considering and processing your grant recommendations, and issuing tax receipts) administer delivery of our charitable services; establish, maintain and manage our relationship with you, including setup and management of Donor-Advised Accounts and maintenance of an accurate record of your involvement; provide you with information regarding the operations of the Private Giving Foundation and offer you opportunities for further giving; verify your identity and protect against fraud; satisfy regulatory obligations and other legal requirements; and to create statistics about our operations and understand the current and future needs and preferences of donors Top TD Bank Financial Group¹ Serving you better Private Giving Foundation has entered into a service agreement with The Toronto-Dominion Bank ("TD") to perform or arrange for the administrative, recordkeeping, fundraising and certain other services for Private Giving Foundation. Your information is collected by and disclosed to TD for the purposes of providing these services on our behalf. With your consent, we may also share your information with the affiliates within TD Bank Financial Group for purposes of determining whether any products or services of TD Bank Financial Group are suitable for you and so that they can offer them to you in order to serve you better. This consent is optional and you can decide to withdraw it at any time. Please refer to the "Respecting your preference" section for more information. When we release your information As a general rule, all information concerning donors is held in strict confidence and, except in limited circumstances, is not disclosed to anyone unless authorized by the donor. We are not in the business of selling donor lists or information to others. However, we may release your information to parties outside Private Giving Foundation in certain circumstances, which include: • With your consent In administering the charitable services of the Private Giving Foundation, we may provide your information to other parties who are grant recipients where you have consented to being recognized and identified as the donor advisor recommending the grant. As noted above, with your consent we also share your information with TD Bank Financial Group to allow them to offer you their products and services. • For servicing purposes We provide information, only as necessary, without your consent, to our suppliers and agents. Where we disclose your information to organizations that perform services on our behalf, we will require those service providers to use such information solely for the purpose of providing such services and to have appropriate safeguards for the protection of that information. • When required or permitted to do so by law or applicable regulators We disclose your information to satisfy regulatory requirements related to our operation as a charitable organization and other legal requirements. We must give information in response to a valid demand, search warrant or other legally valid enquiry or order. We may also disclose information to an investigative body in the case of a breach of agreement or contravention of law - this helps prevent fraud or other criminal activity. • Cessation of Operations Should the Private Giving Foundation cease its operations, its assets will be transferred to qualified donees within the meaning of the Income Tax Act (Canada). The assets transferred may include the information we hold about you. Top How we protect your information We will protect your information with appropriate safeguards and security measures. We have thorough security standards to protect our systems and your information against unauthorized access and use. All our suppliers and agents, as part of their contracts with Private Giving Foundation, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. Employees of TD, who perform the administrative, recordkeeping and other services for Private Giving Foundation, are familiar with the procedures that must be taken to safeguard customer information, and it is specified in their employment agreements and regularly confirmed in writing. 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. We audit our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate. We retain your information only as long as it is required for the reasons it was collected. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form. Top Your right to access your information We will give you access to the information we have about you. Most of this information is in the form of your donation records. These are available to you through quarterly donor-advised account statements and annual tax receipts. If you require other information, simply contact or forward a written request to: Mail: Private Giving Foundation Canada Trust Tower, 161 Bay St, 3rd Floor Toronto, Ontario M5J 2T2 Fax: 416-983-4838 We will ask you for specific details such as your name, account number and name of the donor-advised account. 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, relates to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons. Top Keeping your information accurate We will make every reasonable effort to keep your information accurate and up-to-date. You can help by keeping us informed of any changes, such as if you move or change telephone numbers or grant preferences. If you find any errors in our information about you, let us know and we will make the corrections immediately, and make sure, if appropriate, they are conveyed to anyone we may have misinformed. Top Respecting your preference We will explain your options of refusing or withdrawing consent to the collection, use or release of your information, and we will record and respect your choices. If you don't want us to share information with TD Bank Financial Group, you can tell us so at any time. You may do so by contacting the branch or office or other contact point through which you donated to the Private Giving Foundation or by contacting us at the Private Giving Foundation address below. We will be pleased to explain this option and any consequences of refusing or withdrawing your consent, and record your choice. Top Addressing your concerns If you have any questions, concerns or problems about privacy, confidentiality or how a request for information was handled, you can take the following actions. If you choose to mail, fax or email us, please include your full name, address and telephone number. STEP 1 Contact us in one of the following ways: Telephone: 416-308-6735 Mail: Private Giving Foundation Canada Trust Tower, 161 Bay St, 3rd Floor Toronto, Ontario M5J 2T2 Fax: 416-983-4838 We'll work hard to provide an acceptable solution but if you are not satisfied, the Manager will become involved in the resolution of your problem or concern. STEP 2 Elevation to a Senior Officer If you are not satisfied with the solution you receive from the Manager in Step 1, the Manager will offer to elevate your problem - communicating all relevant details on your behalf - to a representative of the Senior Management Officer responsible for the Private Giving Foundation. If you prefer to elevate the problem yourself, the Manager will provide you with the contact information. STEP 3 Contact the TD Ombudsman If your problem or concern remains unresolved after Steps 1 and 2, you may contact the TD Ombudsman. If it is determined that your problem has not been addressed by the Senior Management Officer as described in Step 2, then the TD Ombudsman may direct your problem back to them for investigation and response. Within five days of receiving your enquiry, the TD Ombudsman will write or call to advise you of the actions being taken. You may contact the TD Ombudsman by: Mail: TD Ombudsman Toronto-Dominion Centre, P.O. Box 1 Toronto, Ontario M5K 1A2 Fax: 416-983-3460 Email²: td.ombudsman@td.com Telephone: 416-982-4884 or 1-888-361-0319 Top Our online privacy policy Visiting our information sites Cookies Email comments, questions or response You may have questions about how we are handling the information we obtain from you when you visit our websites. This online privacy policy will answer your questions about the information we collect when you visit the website of Private Giving Foundation, and how we use it. Visiting our information sites When you go directly to the information portion of our websites and move from page to page, read pages or download content onto your computer, we learn which pages are visited, what content is downloaded, and the address of websites that you visited immediately before coming to our websites. However, none of this is associated with you as an individual. It is measured only in aggregate. We use this information to find out how many people visit our websites and which sections of the sites are visited most frequently. This helps us to know what type of information is most useful to you so that we can improve our websites and make it easier for you to access information. We record the statistical information on the numbers of visitors to our websites, but no information about you in particular will be kept or used. Cookies A cookie is a small file containing certain pieces of information that a website creates when you visit the site. It can track how and when you use a site, which site you visited immediately before, and it can store that information about you. There are two common types of cookies, "session cookies" and "persistent cookies". Session cookies store information only for the length of time that you are connected to a website - they are not written onto your hard drive. Once you leave the website, the originator of the cookie no longer has the information that was contained on it. We use session cookies to track your visits within our site. We use that information to determine the type of information that you are looking for in our site and to improve our site. We use information about the site you visited immediately prior to our site to assess the viability of links to our site that we have created on third party sites. Email comments, questions or responses 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. We will not sell your email address to anyone outside Private Giving Foundation. We may use your email address to send you information about operations of Private Giving Foundation and opportunities for further giving that we believe may be of interest to you. If you don't want us to contact you by email with this kind of information, you may tell us so at any time. If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up). Remember that email sent over the Internet is generally unencrypted. We recommend that you use caution when forwarding free-format email messages to us and that you do not include confidential information (such as account numbers) in those messages, as they are not encrypted. Top Who can answer your questions about privacy? To review your options under the Private Giving Foundation Privacy Code, simply call toll-free: 1-800-851-0299 Top ¹ TD Bank Financial Group means The Toronto-Dominion Bank and its affiliates, who provide deposit, investment, loan, securities, trust, insurance and other products and services. ² Email disclaimer: For your protection, do not send confidential or personal information (e.g. account numbers) via email, as it is NOT a secure method of communication. If your request is urgent or requires disclosure of confidential or personal information for resolution, please call us. Top