Privacy Policy

This policy applies to Stockbroking Services provided by TD Direct Investing (Europe) Limited and associated Banking Services provided by TD Bank N.V.

We, Computershare Investor Services Plc, TD Direct Investing (Europe) Limited and TD Bank N.V are committed to providing you with the highest quality service. This includes maintaining your privacy and protecting your personal data. In addition to the Customer Terms of Service the following policy explains what we and our associated companies in the TD Group do with the personal data we collect about you. We will tell you which companies are in the TD Group upon request. Our contact details are at the end of this privacy policy. To get the best from our services, please keep your personal data (including your email address) accurate and up to date by visiting Preferences online or sending an email via the Contact Us facility on the website.

Please take the time to read this privacy policy carefully. In opening an account with Computershare Sharedealing you consent to our use of your personal data in accordance with the Customer Terms of Service and the Privacy Policy. We hope that by implementing and operating this policy, we will make your online experience a more secure and enjoyable one.

Contents

1. Why have a privacy policy?
2. What personal data do we collect about you and how?
3. How do we use your personal data?
4. Safeguarding your personal data
5. What are cookies and how do we use them?
6. Sale of the business
7. Contacting us
8. Third-party web beacons

Why have a privacy policy?

There are a number of laws which set out important standards regarding information that identifies a living individual. This is known as "personal data." All organisations processing personal data must do so fairly and lawfully. They must also be registered or "notified" with the Information Commissioner whose role it is to ensure that organisations comply with their data processing obligations. If you wish, you can view a copy of our data protection notification by visiting the Information Commissioner's website. In addition, certain rules apply to sending direct marketing information by certain methods such as telephone and email. We treat these obligations seriously and take all steps necessary to comply when we store and process your personal data.

What personal data do we collect about you and how?

It is essential to us to collect, store and process your personal data so that we can offer and perform our services. Some of the information we request is voluntary, and you do not have to provide it. Typical information we might ask for includes your name, your address, other contact details and bank account information. We may also store other personal data, including information from third parties, such as credit referencing agencies.

In addition our servers automatically receive and record information on all visitors to our websites. Please see cookies (below) for more information.

We will only hold your personal data (aside from the automatic information detailed above) once you have been issued with a registered username and password, and your registration with our services has been completed.

We collect your personal data in a number of different ways, including the following:

• if you provide it when communicating with us (For example when registering for our services);
• if you order any of our products or services;
• if you enter a competition or promotion;
• if you make payments or modify your account details; and
• when you visit our websites (for example by cookies and other browser-generated information).

How do we use your personal data?

We retain and use your personal data for the following main purposes:

• running your accounts, providing our services, contacting you and servicing our relationship with you; administration and accounting, billing and auditing and other legal purposes;
• security, payment verification, preventing and detecting money laundering, fraud and other crime, insurance, credit assessment and administration, tracing debtors and recovering debt. For these purposes, we may also pass on your personal data to third parties;
• generating statistics on our users, such as the popularity of certain of our services, about the "traffic" visiting our websites. When we do this, your data becomes anonymous and you are not personally identified; and
• disclosing and passing-on to other companies within our group, some of which are located outside of the EEA.

Keeping you informed

Except where you have not agreed to be contacted for example by using the declaration section on the application form or you have written to us asking this we may also use your personal data to keep you informed about relevant products and services. We may use your personal data including your contact details, your application details (but not banking details) and details of the services we provide you with and how you use them, to decide what products and services may be of interest to you. We may contact you by telephone (including automated calls), post, email and other electronic messages such as short text, video and picture messaging, and fax, with information, news, events and seminars on our investment, banking and financial services and those of TD Group and other selected partners. Please click here for details of our products and services. We may also pass this information to companies in the TD Group and selected partners for them to contact you about their products and services in the same ways. You can ask us at any time to stop sending you this information by writing to us at the address at the end of this policy. Please remember that even if you have requested this, we may still contact you about the running of your existing account and for the services requested from us.

Naturally we reserve the right to access and disclose your personal data if we are required to do so by law (or if we reasonably believe we are required to do so by law), or if it is necessary for the proper operation of our systems, our protection or that of our users and customers, or for the enforcement of our Customer Terms of Service.

Safeguarding your personal data?

We take all reasonable care in the collection, storage, processing and disclosure of your personal data and have implemented internal security procedures so as to minimise the risk that unauthorised parties will be able to access the information. It is because of these security procedures that we may ask for proof of your identity before we disclose any personal information about you. Only certain of our employees and contractors have access to your personal information and although we cannot guarantee that your information will never be lost, misused or altered by any of our employees, we have implemented procedures to minimise the risk of these unlikely events.

Nonetheless, the internet is an open medium and we cannot guarantee that any information you send to us by email or via our website will not be intercepted or tampered with. To help protect your personal data and minimise the risk of it being intercepted by unauthorised third parties our secure servers employ industry standard Secure Socket Layer (SSL) encryption when you submit information to us through our website. Some older browsers do not allow the use of current SSL technology and we therefore recommend that you upgrade your browser to Netscape version 7.0 or higher, or Microsoft Internet Explorer 6.0 or higher.

You can also help to protect your personal data, by following the guidelines below:

• choose a password that you will be able to remember but that would be hard for someone to guess. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;
• make sure that no-one can see the details you are entering when you log-in;
• if other people have access to your computer, remember to close your browser each time you log-off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have saved or "cached"; and never disclose your account details to anyone.

What are cookies and how do we use them?

A cookie is a small "packet" of information that your browser automatically stores on your hard drive when you visit Internet sites. A browser is the facility on your computer which enables you to visit websites, move from page to page on a website, print pages and use webmail. Our websites create a cookie when you visit us. We are then able to access and use that cookie to tell us, for example, what browser you use. This ensures that our services work well on your computer and helps us to understand how our websites are used. Cookies tell us which pages of the website were seen, or which functions, services or products were seen, how often certain pages were visited and which were the most popular areas of the website, helping us to improve the design of our website and what it can offer. We may also use it to flag when we have already asked you to participate in any online market research and to prevent you from being asked to complete the same questionnaire each time you visit this website.

If you wish, you can usually adjust your browser so that your computer does not accept cookies. However, our site may not behave as intended if cookies are disabled. Alternatively you can adjust it to tell you when a website tries to put a cookie on your computer. How you adjust your browser to stop it accepting cookies or to notify you of them will depend on the type of programme your computer uses. Visit your browser software vendor's website for details on how to manage cookies using your particular web browser.

Please remember, cookies do not contain confidential information such as your home address, telephone number or credit card details. We do not exchange cookies with any third party websites or external data suppliers.

On our website, you are able to save your login name so that it is automatically completed in the login box on subsequent visits. This facility is optional and will not store any of your personal information other than your login details.

Your browser also generates other information, including your language and your Internet Protocol address ("I.P. Address"). An I.P. address is a set of numbers which is assigned to your computer during a browsing session whenever you log on to the Internet via your internet service provider or your network (if you surf from, for example, a computer at work). Your I.P address is automatically logged by our servers and used to collect traffic data about visitors to our web sites. We do not use your I.P address to identify you personally.

Sale of the business

In the event that the business is sold fully or in part, integrated with another business, or it disposes of its rights and obligations under any agreement with you, your records may be disclosed under appropriate confidentiality terms to our advisers and any prospective purchasers' adviser, and will be passed onto the new owners.

Contacting Us

Please bear in mind that this privacy policy only applies to websites and services operated by us and not those operated by third parties, including those to which our websites may link. We suggest that you make yourself familiar with any privacy policy operated by third party websites before providing personal information about yourself.

You are entitled to a copy of the personal information we hold about you on payment of a small administration fee. If you would like to see this information, please write to the address below.

If you have any queries about this privacy policy, any of the Customer Terms of Service or the web site in general, do not hesitate to contact us:

Customer Service Manager
Computershare Sharedealing
Exchange Court
Duncombe Street
Leeds
LS1 1AX
Tel: 0845 607 6001
Email: customer_services@computershare-sharedealing.co.uk

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Third-Party Web Beacons

Third-Party Web Beacons: We use third-party web beacons from Yahoo! to help analyse where visitors go and what they do while visiting our website(s). Yahoo! may also use anonymous information about your visits to this and other website(s) in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo!, click here.

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