Code of Privacy Principles

"The confidentiality and security of your personal information is important to us. As such, protecting your privacy is one of our highest priorities."

Commitment to Privacy

At Equitable¹ (variously referred to as "the Bank", "we", "us" or "our"), we are firmly committed to protecting your personal information. This Code of Privacy Principles (the "Code") demonstrates that commitment by informing you of the practices we have in place relating to the management of your personal information and should be read in conjunction with our Privacy Agreement. The Code applies to any individual who has applied for, or offered to provide a guarantee for, any product or service offered by us in Canada.

To fulfill our commitment to you, we observe the following 10 principles when dealing with your personal information.

What is 'personal information'?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Your name, address, email address, mobile telephone number, occupation, date of birth and other information used to authenticate your identity such as knowledge-based information (i.e. username, password and account information), biometric information (i.e. signature, fingerprint and voiceprint), device information (i.e. device model, browser type and activity, IP address, security cookies and approximate physical location of device); 
• Identification documents, such as a valid non-expired driver's license, passport or birth certificate;
• Your annual income, assets and liabilities and credit history;
• Information about your transactions, including payment history and account activity; and
• Other information that we may need in order to provide you with a product or service or that may be required by law.

We ask you for your personal information for the following purposes:

• To verify your identity and protect against fraud;
• To understand your financial service requirements;
• To determine the suitability of products and services for you;
• To set up and manage products and services you have requested;
• To comply with legal, regulatory and contractual requirements; and
• To assist in the collection of debts that you may incur with us from time to time.

Principle #1: We are Accountable to You

Equitable is responsible for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. We have a Chief Privacy Officer, who oversees the implementation of our privacy program. To contact the Chief Privacy Officer please refer to the 'Contact Information' section below.

Principle #2: We Will Identify the Purpose for Collecting Your Personal Information

Equitable will identify and document the purposes for which we collect your personal information, before or at the time of collection.

Principle #3: We Will Obtain Your Consent to Manage Your Personal Information

Equitable will make a reasonable effort to make sure you understand how your personal information will be used, and will obtain your consent before or at the time we collect or use the personal information. Your consent can be express, implied, or given through an authorized representative. Subject to legal, regulatory and contractual requirements, you may withdraw your consent to our collection, use or disclosure of your personal information. However, depending on the circumstances, the withdrawal of your consent may prevent us from providing you or continuing to provide you with some services or information that may be of value to you. In addition, you should be aware that we may collect, use or share your personal information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law. For example, we may collect, use or share your personal information to investigate a breach of an agreement or law, in response to a demand, search warrant or court order we believe to be valid, to realize on security pledged, or to investigate and deter fraud.

Principle #4: We Will Limit the Collection of Your Personal Information

Equitable limits the amount and type of personal information we collect to what is necessary for the purposes we have identified to you. We will only collect personal information using practices that are fair and lawful, and as described in this Code and our Privacy Agreement.

Principle #5: We Will Limit the Use, Disclosure and Retention of Your Personal Information

Equitable will use or disclose personal information only for the purposes it was collected, unless you give consent to use or disclose it for another reason, or it is permitted or required by law. Under certain exceptional circumstances, Equitable has a legal duty or right to share your personal information without your consent to protect Equitable's and/or the public interest.

Equitable will only keep your personal information as long as necessary for the purposes identified at the time of collection.

Principle #6: We Will Keep Your Personal Information Accurate

Equitable will make a reasonable effort to keep your personal information up to date, accurate and relevant for its intended use. However, we also rely on you to tell us when your information changes. You may, in writing, request access to your personal information to verify the accuracy and completeness and request that it be amended as appropriate. To access your personal information, please contact the Chief Privacy Officer as directed in the 'Contact Information' section below.

Principle #7: We Will Safeguard Your Personal Information

Equitable uses security safeguards to protect personal information that are appropriate to the sensitivity of the information and include: physical and electronic security measures, organizational processes and contractual obligations with third parties. In addition, privacy is a part of our job description, and all employees are trained on the importance of protecting your personal information.

Principle #8: We Will Make Information about Our Privacy Program Available to You

Equitable is open about the way we manage your personal information. You may request access to more information about our privacy practices, and we will make it available to you in a manner that is easy to understand.

Principle #9: We Will Give You Access to Your Personal Information

You may make a request in writing for access to your personal information. After verifying your identity, we will, within a reasonable timeframe, tell you what personal information we have, what it is being used for, and to whom it has been disclosed. In certain situations, however, we may not be able to give you access to all your personal information. In these situations, we will, except where prohibited by law, explain the reasons for this lack of access and advise you of any recourse you may have. There may be a charge for retrieving some information about you, and if so, we will notify you before processing your request so you have an opportunity to withdraw it. If you wish, you may also challenge the reasonableness of the charge.

Principle #10: We Will Respond to Your Questions, Concerns and Complaints about Privacy

Equitable will respond to your questions, concerns and complaints about the protection of your personal information in a timely manner, typically within thirty (30) days. If we need to extend the time, or if we refuse your request, we will tell you why and notify you of the new deadline.

For additional information on how we may collect, use and disclose your personal information please refer to the Privacy Agreement available on our website or in any of our offices.

Questions or Concerns

If you have a question or concern about personal information, please contact us by phoning us at:

Complaints Hotline: 416-515-2293

Leave a message with your name and a telephone number where you can be contacted during business hours. We will contact you for more details and to begin the resolution process.

Contact Information

You may also contact us at:

Chief Privacy Officer
Equitable Bank Tower
30 St. Clair Avenue West, Suite 700
Toronto, Ontario M4V 3A1

If your concern remains unresolved by the Chief Privacy Officer, you may contact the Privacy Commissioner of Canada at:

Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Quebec K1A 1H3