Private Giving Foundation Privacy Policy
Thank you for trusting us with your information. This Privacy Policy explains how, and why, Private Giving Foundation (PGF) handles your personal information.
You agree to this Privacy Policy when you:
• open a PGF account and
• otherwise interact with us
This Privacy Policy will apply:
• when you ask to begin a relationship with us
• during the course of our relationship and
• for a period of time after the end of our relationship
We may give you additional privacy terms for a product or service when you sign up for or use that product or service.
In this Privacy Policy:
The words "PGF", "we", "us" and "our" mean Private Giving Foundation.
The word "TD" means TD Bank Group.
PGF has a service agreement with TD to perform and arrange for the administrative, recordkeeping, and other required services for PGF. Your information is collected by and disclosed to TD for the purposes of providing these services on our behalf.
The words "you" and "your" means anyone who opens a PGF account.
The word "information" means your personal information.
We rely on your consent to collect, use, retain, and share your information. This Privacy Policy outlines your options, where available, to refuse or withdraw your consent.
WHY & HOW WE COLLECT YOUR PERSONAL INFORMATION
Beginning & maintaining a relationship with us
We need to collect certain information about you to manage our programs, contact you about products or services you may be interested in and manage operations and risk within PGF. This may include your contact information, information about whether you are eligible for our products and services, and records that reflect our overall relationship with you. We may also need other information depending on the product or service we’re providing.
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.
Information We Collect From You
The information we may collect includes:
Contact information such as your:
• name
• mailing address
• phone number
• email address
• preferred language
Information you give us about others, such as:
• your joint account holder
• account successor
See the "Interacting with PGF online" section below for more details on information we collect through our website.
We do not collect information from minors or those we know do not have legal capacity, without their legal guardian’s consent, unless required or permitted by law.
Information From Other Sources
We may collect information about you from sources within TD or outside of TD. These sources include:
• government and law enforcement agencies and registries
• public records, such as bankruptcy or criminal records
• fraud prevention agencies and investigators and other organizations to detect or prevent fraud
• your joint account holder or any person who has the legal authority to act on your behalf
• companies, organizations, partners and financial institutions you have accounts with, when we buy or sell all or part of a business, or a set of assets. Or who transfer or assign to us any of your loans, leases or other obligations owed to them. Or when we consider those transactions
• your interactions with us, including in-person, over the phone, or through email or the Internet.
HOW WE USE YOUR PERSONAL INFORMATION
Providing our products and services to you and managing our business
We use your information to help us deliver and manage our products and services, including when we:
• verify your identity
• communicate with you
• 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 PGF and offer you opportunities for further giving
• comply with regulatory reporting obligations
• prevent and detect fraud
We use your information for the purposes of serving you and to administer our business, and we may use technology to analyze your information, including to:
• verify your identity
• provide you with ongoing service and information on the products and services you hold with us
• train staff and confirm our discussions with you
• develop and improve our products and services or identify new or different products and services that may be of interest and appropriate for you
• understand your needs and give you personalized service
• create statistics about our operations and understand the current and future needs and preferences of donors and identify trends in how our products and services are used
• help manage and assess our risks, operations, and relationship with you
We may pool your information with other peoples’ information for research and to create statistical reports. These reports will not identify you.
Engaging with you
We use your information to communicate with you. We use it to improve and request feedback on our products and services and communications with you. You have choices about which promotional messages you receive.
We use your information to enhance our relationship with you. For example, to:
• Improve live communications with you – We may collect and use certain information when you talk to one of our telephone service representatives. When you do these things, we may monitor or record our discussions. We do all this for our mutual protection, to identify trends, train staff, and confirm our discussions with you.
• Check your eligibility for additional products and services – We use your information to see if you are eligible for additional TD products or services that may meet your needs and be appropriate for you. We also use it to personalize our offers.
• Share promotions – To tell you about, and offer, other products and services that may interest you and be appropriate for you. This includes products and services offered by other businesses within TD. This also includes product and services offered by third parties we select.
• Contests or surveys – To see if you are eligible to participate in contests. To administer these contests. To send you surveys or promotions.
• Contact you – By telephone, mail, email, or any other method. We will use the numbers and addresses you provided to us.
You can opt out of receiving offers. You can also choose how we contact you for marketing campaign purposes. To exercise your choice, please:
• contact us by phone 1-833-917-0; 381 (option 1) (option 3) or by email at TD.PrivateGivingFoundation@td.com
• to unsubscribe from receiving commercial electronic messages from TD Bank Group, go the following web address: www.td.com/tdoptout
Please note that changing your preferences may not stop you from receiving offers for a marketing campaign that is already underway when you contact us.
PGF will not send you an unsolicited email to ask you to provide information or login information, such as username, passwords, PINs, IdentificationPlus® security questions and answers, or account number.
If you receive an email claiming to be from PGF and you think it's fraudulent, don't respond to it. Don't open or click any links. Don't open attachments in the email. Please notify us immediately. Forward a copy of the email to us at phishing@td.com. Then delete the email.
Legal compliance and security
We must use your information to comply with laws, regulations, and industry rules. We must also use it to prevent and investigate crime.
Complying with sanctions and financial crime laws – We must use your information to comply with:
• financial crime laws
• anti-money laundering laws
• sanction laws
Preventing fraud and other crimes – We use your information to prevent, detect or suppress:
• financial abuse
• fraud
• criminal activity
• security risks
We also use your information to:
• assist us with any internal or external investigation into potentially illegal, fraudulent, or suspicious activity
• manage, defend or settle any actual or potential loss
• protect our assets and interests
In order to do these things, we may share your information with any person or organization, including any:
• fraud prevention agency
• regulatory or government body
• the operator of any database or registry used to check information provided against existing information
• any entities engaged in the insurance or financial lending business
When we do share your information for these purposes, we may sometimes pool your information with data belonging to other individuals.
Other regulatory compliance – We will use your information to comply with all laws and regulations. We will also use it to comply with the rules, demands, and guidance from regulators. This includes self-regulatory organizations.
Interacting with PGF online
When you interact with PGF online, we collect, use and disclose your information to:
• deliver our services
• improve and personalize your experience
• prevent fraud
• customize how we advertise on third party websites and apps
Use of Web Based and Tracking Tools:
We, and third parties that we select, use certain technologies and tracking tools on our websites and apps to deliver our service, improve and personalize your experience, and prevent fraud. As one example, we use cookies. Cookies are snippets of data stored by a web browser (For example, Chrome, Safari or Firefox web browsers). We also use pixels, beacons, Software Development Kits (SDKs) and other technologies. We call these "web based tools".
Essential Web Based Tools:
We use essential web based tools to provide the functionality and security of your online experience, and to help us detect, prevent and investigate fraud. For example, this allows us to remember your language preferences and provide a secure connection.
These tools may collect information about your usage of our website and apps, including your typing and cursor patterns while you are using our secure sites and apps.
You can't opt-out of the use of these tools, but you may be able to disable the ability for your browser to accept them. If you disable them, some of our websites might not work properly and you may not get the best experience. For example, you will not be able to access our secure websites. This is because we use these tools for security purposes on our secure websites.
Non-essential Web-Based Tools:
Performance
We, as well as third parties we select, collect and use non-essential web based tools to tell us about the performance and usage of our sites and apps. These tools help us to understand which pages you go to most often and if you encounter errors or performance issues. These tools also help us measure and analyze the traffic on our online services by establishing statistics and traffic volumes (e.g., pages visited or features used).
Targeting
We, as well as third parties we select, collect and use your online browsing and activity on our websites and apps to better understand your interests and provide you with personalized content and offers. This may also include information about the products or services you are applying for.
This information may be used by those third party companies in accordance with their respective privacy policies.
This information may also be used to build a profile of your interests, to personalize your content and present you with relevant offers, including on third party sites.
You may review a list of third parties and their privacy policies by using the "Manage Online Experience" preference centre by scrolling to the bottom of the TD webpage and clicking "Manage online experience".
You have choices about how we use non-essential web based tools. To update your preferences, use the "Manage online experience" preference centre by scrolling to the bottom of the TD webpage and clicking "Manage online experience".
If you adjust your browser settings to refuse web based tools, you may still receive generic PGF ads.
Online Advertising:
We subscribe to the Digital Advertising Alliance of Canada's Self-Regulatory Principles for Online Behavioural Advertising. These principles promote consumer awareness and choice about how organizations use consumer information for online behavioural advertising.
Online Behavioural Advertising – We are able to track which of our ads you interact with on third party websites. We may also collect and use information about your relationship with us (such as types of accounts, transactional information or how you bank) to help provide tailored TD ads or offers to you. If you click on one of our ads on a third party website, we may use web based tools. We use web based tools to track how effective our online advertising is. We may also use web based tools to deliver ads that may be relevant to you in the future.
To learn more about online behavioural advertising and the icon you might see on websites and online ads, you can visit the TRUSTe’s online opt-out tool. It is available at: http://preferences.truste.com/truste/4.
We have enabled these Google Analytics Advertising Features:
• Re-Marketing with Google Analytics, and
• Google Analytics Demographics and Interest Reporting
We use Google Analytics to better understand your use of our website. The tool collects information about user behaviour, which includes how many times a user visits our website, what pages they visit and where they were referred from. Advertising identifiers for mobile devices, as well as generalized location, gender and age group information may also be collected. Google may use the data collected for their own purposes, including to contextualize and personalize the ads on their own advertising networks.
To learn more about how Google uses data when you visit websites using Google Analytics, click here. You may opt out of Google Analytics tracking. To do this, install the Google Analytics Opt-Out Browser Add-On. You may opt out of ad serving on Google’s opt-out page.
You can view your settings and opt-out of receiving relationship-based ads by updating your settings on your social media or webmail sites.
Search engine interest-based tracking
• We advertise on search engine results pages. Search engines may use several factors to decide which ads to place, including your search terms and browsing history.
• You can opt-out of interest-based search engine advertising. Just select the notification icon after the URL within the ad text to adjust your settings. You may still see our generic TD-branded ads after you opt-out. These are not based on your interests or browsing.
Responding to surveys online
• We place surveys on third-party websites. When you respond to an online survey, we may use your answers or any opinions or information that you volunteer to improve our products or services or to contact you.
SHARING INFORMATION WITHIN TD
We share information within TD
We are committed to legendary customer service. We strive to give you streamlined services, eliminate repetition and annoyances for you. To help us manage your total relationship with us, we share your information within TD (except where the law doesn't allow it). In some cases, this includes sharing your information with our affiliates in other countries.
We may share your information within TD, including sharing with our affiliates, in Canada and outside of Canada, for these purposes to:
• manage your total relationship within TD, including servicing all your products and services and maintaining consistent information about you
• understand your needs and give you personalized service
• determine whether any products or services of TD are suitable for you and so that they can offer them to you in order to serve you better
• identify trends to improve our products and services
• manage and assess our risks and operations. This includes to collect a debt owed to us by you
• comply with legal and regulatory requirements
• allow other businesses within TD to tell you about their products and services
If you do not want other businesses within TD to contact you about their products and services, please contact us by phone at 1-833-917-0381 (option 1) (option 3) or by email at TD.PrivateGivingFoundation@td.com
To unsubscribe from receiving commercial electronic messages from TD Bank Group, please go the following web address: www.td.com/tdoptout
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.
PGF and TD SERVICE PROVIDERS
We use service providers for many reasons. For example, they help us serve and communicate with you. They support our business operations, help us develop products, and make service enhancements. They help us to market our products and services. They help us to comply with the law.
Our service providers may only access and use your information to provide the services under their agreement with us. In some cases, our agreements allow these service providers to use the data to improve their service. For example, to develop tools that prevent fraud. We carefully assess our service providers’ security practices. We also require that they keep your information confidential and destroy it when no longer required.
Our service providers include those who support us with:
Technology, such as:
• website hosting
• mobile apps
• telephone and electronic communications
• data storage and analysis
• our internal systems
• security and software
• online advertising
Customer Service, such as:
• transaction processing
• customer inquiries
• creating account statements and cards
• application processes insurance products and claims
• mailings
Legal and Financial Compliance, such as:
• accounting
• auditing
• tax filings
• investigations
• debt collection
• business transactions
• legal claims
Risk Management, such as:
• anti-fraud
• insurance information agencies
• identity authentication services
DISCLOSING YOUR PERSONAL INFORMATION
Providing our products and services to you
We may disclose your information to third parties. We disclose to these parties to help us deliver the products and services you request and to manage our business and risks. We don't sell or rent your information.
We may disclose your information:
• When required or permitted to do so by law or applicable regulators and self-regulatory organizations. We may release information to satisfy regulatory requirements related to our operation as a charitable organization, or in response to a search warrant, court order or other demand or inquiry which we believe to be valid.
• 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 fraud or criminal activity, protect our assets and interests, or in the case of a breach of agreement or contravention of law. This helps prevent fraud, money laundering or other criminal activity.
• Cessation of operations. Should PGF 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.
• Other situations where we have your consent. In administering the charitable services of the PGF, 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.
Managing our business, risks and legal compliance
We will disclose your information to third parties to manage our business and legal obligations. For example, when we engage with others to:
• deliver a product or service
• prevent fraud or investigate misconduct
Preventing fraud and protecting our interests
We may disclose your information in order to:
• prevent, detect or suppress financial abuse, fraud, and criminal activity
• protect our assets and interests
• investigate potentially illegal or suspicious activity
To do any of the above, we may disclose your information, individually or pooled with other people’s information, to any:
• person or organization
• investigative body
• fraud prevention agency
• regulatory or government body
Financial abuse and protection – We may disclose your information if we think you might be a victim of fraud, financial abuse or other illegal activity. We may disclose it to:
• law enforcement, government authorities or their agents
• other financial institutions or organizations
• a family member
• joint account holder
• your legal representative
Court orders, regulatory demands and other legal compliance – We will disclose your information to third parties where the law requires us to do so. For example, to comply with court orders or legal and regulatory obligations. We may also disclose your information to third parties where the law permits us to do so.
For example, we disclose your information to:
• Canadian and international tax authorities to report revenue
• Regulators, courts, law enforcement and other organizations to respond to requests that we believe to be valid. For example, a court order, search warrant or other demand or request
• Regulators and self-regulatory organizations to comply with legal and regulatory requirements that apply to us
Sometimes we need to comply with legal obligations that apply to you or us outside Canada. For example, you may hold securities issued by an issuer in the European Union. If you do, regulations in the European Union may require us to disclose your contact and holdings information to the issuer.
PROTECTING YOUR PERSONAL INFORMATION
Security Measures
We have internal policies and security standards to help protect our systems and your information against unauthorized access and use. We retain your information only for the time we need it. And we only use it for the purposes that we explain to you.
Our agents and service providers are bound by contracts to keep your information confidential and must not use it for any unauthorized purpose. We train our employees on the procedures they must take to keep your information safe.
We have policies and procedures to:
• prevent unauthorized access to your information
• respond to privacy questions, complaints, or breaches
• limit the use of your information to the purposes communicated to you
• honour the choices you made about your information
• retain your information for the period we need it to serve you and manage our business and legal obligations
• securely destroy your information or convert it to an anonymous form after the time we don’t need it
• help make sure that any service providers or agents who handle your information on our behalf, in Canada or elsewhere, protect that information
We review our procedures and security measures on a regular basis. We do this to help make sure that they remain effective and appropriate.
We may modify information to help protect your identity, such as by removing direct identifiers, aggregating or anonymizing it, before using or disclosing it for certain purposes.
Some of the ways we use your information are to support our efforts to protect your security. For example, we may ask you to provide certain information to authenticate you. This helps to prevent unauthorized access to your accounts. And it helps to support our efforts that we are collecting the correct information from third parties.
You can obtain more information about our policies, procedures and security standards. Please contact us using the information under the heading "Questions" below.
Transfers of Your Information to Other Regions
TD is a global organization. TD has affiliates and service providers across Canada and in other countries. We and they may use, store or access your information in any region in Canada and other countries. These countries may include the USA, UK, European states, India, and others where TD has a business presence. We take steps to protect your information wherever it is handled, subject to requirements to disclose it
in response to legal demands or requests from governments, regulators, courts and law enforcement authorities in other jurisdictions that we deem to be valid.
Retaining and Destroying your Personal Information
We retain your information only as long as we need it for the purposes for which it was collected, used or disclosed. We have procedures to help us determine the length of time we will retain your information. The length of time varies. It depends on the product or service, the sensitivity of the information, and the purposes for which we use it. We may retain your information after the end of your relationship with us. For example, when we need your information:
• for legal or regulatory purposes
• to respond to issues that may arise at a later date
• to support fraud prevention organizations and other risk assessments
• for security purposes
We have procedures to guide what we do when we no longer need your information for these purposes. We may securely destroy, delete, or erase it. Or we may convert your information to an anonymous form.
You can contact us if you have questions about how long we retain your information. Contact us using the information under the heading "Questions" below.
YOUR RIGHTS TO ACCESS AND CORRECT INFORMATION
Accessing your personal information
Upon request, we will give you access to the information we retain about you. If you ask us, we will help you make your request. Contact us by phone 1-833-917-0381 (option 1) (option 3) or by email at TD.PrivateGivingFoundation@td.com.
Most of your 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 need information not found in your donation records, contact us or send a written request. We will ask you for your information to confirm your identity.
We will let you know 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 will not be able to provide information about you from our records that contain references to other persons, is subject to legal privilege, contains confidential information proprietary to PGF or TD Bank Group, relates to an internal investigation, risk assessment or violation of law, or that cannot be disclosed for other legal reasons.
Correcting your personal information
We make reasonable efforts to keep your information accurate and up to date.
This helps us give you better service. It also reduces the chance that we may use wrong information. We have procedures and practices to help us maintain the accuracy of your information.
You can help by keeping us informed of any changes. For example, tell us if you move or change telephone numbers. If you find any errors in our information about you, let us know right away. We will make the corrections. We will also give the corrections to anyone we gave your information to and who relies on it. If we don't agree with your requested change, we will note your request in your file.
Questions?
If you have any questions on this Privacy Policy, you may call us at 1-800-851-0299.
If this does not answer your question, you may contact TD's Chief Privacy Officer at:
Email: TD.Privacy@td.com
Mail: Toronto-Dominion Centre P.O. Box 193 Toronto, ON M5K 1H6 Attn: TD's Chief Privacy Officer
RESOLVING A COMPLAINT
Do you have a complaint?
We take your concerns seriously. We work hard to help resolve any privacy complaint. If you have a general complaint, please contact us in one of the following ways:
Mail: Private Giving Foundation TD South Tower 79 Wellington Street West, 4th Floor Toronto, ON M5K 1A2
Telephone: 1-833-917-0381 (option 1) (option 3)
Email: TD.PrivateGivingFoundation@td.com
If you have a privacy complaint, please follow our complaint resolution process. This is set out in this link: https://www.td.com/to-our-customers/resolving-your-problems/comments.jsp
If your complaint is not resolved by us, and it relates to a potential violation of privacy law, you may contact:
The Office of the Privacy Commissioner of Canada
Website: www.priv.gc.ca
Mail: 30 Victoria Street Gatineau, QC K1A 1H3
Telephone: 1-800-282-1376
Fax: 1-819-994-5424
MORE INFORMATION
Privacy Policy Updates
We may change this Privacy Policy from time to time. The current Policy will be available on our website https://www.td.com/ca/en/investing/private-giving.
If you have any questions on this Policy, please contact us at 1-800-851-0299.
If this does not resolve your question or request, you may contact TD’s Chief Privacy Officer at:
Email: TD.Privacy@td.com
Mail: Toronto-Dominion Centre P.O. Box 193 Toronto, ON M5K 1H6 Attn: TD's Chief Privacy Officer
Last modified: October 2024
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