TD Cowen U.S. Privacy Notice

U.S. Customer Privacy Notice

Cowen Inc. and its U.S. affiliates (collectively referred to as “TD Cowen Companies”, “we”, “us”, “our” or similar pronouns) provide this U.S. Customer Privacy Notice (this “Notice”) pursuant to the Gramm-Leach-Bliley Act and the regulations promulgated thereunder, including Regulation S-P adopted by the United States Securities and Exchange Commission (collectively, “GLBA”).

This Notice describes the TD Cowen Companies’ privacy policies and practices with respect to “nonpublic personal information” (as defined by GLBA) such as personally identifiable financial information that is not otherwise publicly available (collectively, “personal information”) of natural persons who are current or former customers of TD Cowen Companies’ financial products or services within the meaning of GLBA (“you”).

Cowen Inc. was recently acquired by The Toronto-Dominion Bank. Cowen Inc. and its subsidiaries prior to the acquisition are now indirect subsidiaries of The Toronto-Dominion Bank, continue to operate legacy Cowen businesses and references herein to “TD Cowen” are references to the Cowen legacy businesses. This privacy notice and the other privacy notices and policies referenced herein only apply to Cowen Inc. legacy businesses as stated therein and do not otherwise cover operations of the Toronto- Dominion Bank and its other subsidiaries.

I. Your Privacy Is Important to Us

Your privacy is important to us. We recognize that you entrust your personal information to us, and we understand the importance of maintaining the confidentiality and security of your personal information. This Notice explains how we collect, share, and protect your personal information, and how you can limit our sharing of certain information under certain circumstances.

This Notice replaces all previous TD Cowen U.S. customer privacy notices and may be amended from time to time. Please read this Notice carefully.

II. What Personal Information Do We Collect?

We collect, use and process various types of personal information about you and your accounts and transactions. The types of personal information we collect and share depend on the relationship you have with us, such as which financial product or service we provide to you. The personal information we collect includes:

Information from you, such as information on your TD Cowen application(s), TD Cowen forms or questionnaires you may complete or agreements you enter into with us. For example, this may include:
- Personal details, such as name, age, occupation, and marital status;
- Contact details, such as address and phone number;
- Identification documents, such as your passport, national identity card, or driver’s license;
- A personal identifier, such as your Social Security Number or other tax payer identification number; and
- Financial information, such as source of wealth, financial resources, investment experience, risk tolerance, etc.;
Information about your transactions with TD Cowen and our affiliates, such as account balances, account activity and transaction history;
Information about your transactions with nonaffiliated third parties, such as clearing firms and trading systems; and
Information from consumer reporting agencies, such as your credit bureau reports and other information relating to your creditworthiness.

If you decline to provide us with the personal information we request, we may not be able to make investment products and services available to you.

We may disclose any or all of the personal information that we collect about you (including about former investors or customers) to affiliates and nonaffiliated third parties, including to:

Our affiliates for their everyday business and marketing purposes (which may include sharing information about your creditworthiness);
Financial service providers, such as our affiliates, clearing firms, order routing systems, and order management systems;
Non-financial companies, such as service providers who assist us in processing transactions, marketing, record retention, customer contact management, and other services; and
Other nonaffiliated third parties for our everyday business purposes, such as to process transactions, maintain account(s), respond to court orders and legal investigations, or report to credit bureaus; or as permitted by law.

You have the right under the GLBA to opt out of the following types of our sharing:

Sharing information about your creditworthiness with our affiliates for their everyday business purposes; or
Sharing personal information with our affiliates for their marketing purposes.

To exercise your opt-out right, please contact us using one of the following means, specifying the nature of your request in reasonable detail, as well as your name, address, telephone number and account numbers to which the opt-out applies:

Write to us at the following address:
- TD Cowen Inc.
  Legal and Compliance Department
  599 Lexington Ave
  New York, NY 10022

Email us at privacy@cowen.com

Depending on where you reside, state laws may give you additional rights to limit sharing. See below for more information on your rights under state law.

IV. Protecting Your Personal Information

The TD Cowen Companies have policies and practices to maintain physical, technical and administrative safeguards designed to help protect the confidentiality and security of personal information against anticipated threats and protect against unauthorized access or use of personal information that could result in substantial harm or inconvenience to any customer. Our policies and practices include training, vendor management, and restricting access to personal information about you to those employees, agents or other parties who need to know that information to provide products and services to you or to us, or otherwise in connection with your investments and activities with or through us.

If you are based in the European Economic Area (“EEA”) or a jurisdiction with substantially similar privacy laws, please see TD Cowen’s Non-U.S. Customer Privacy Notice for information about our privacy practices with respect to your information and your rights under applicable laws.

V. Rights Under State Law

Special Notice To Residents Of California

The following section supplements this Notice with respect to TD Cowen Companies’ individual clients who have a California address as their current home address of record with us and supersedes anything to the contrary in this Notice with respect to those clients only.

If your account has a California home address, we will not share your personal information except as permitted by applicable California law.

If you are a California resident, California law may provide you with additional rights regarding your personal information. To learn more about your California privacy rights, visit the TD Cowen Privacy Notice for California Residents.

Special Notice To Residents Of Vermont

The following section supplements this Notice with respect to TD Cowen Companies’ individual clients who have a Vermont address as their current home address of record with us and supersedes anything to the contrary in this Notice with respect to those clients only.

The State of Vermont requires financial institutions to obtain your consent prior to sharing personal information that they collect about you with non-affiliated third parties, or eligibility information (such as creditworthiness) with affiliated companies, other than in certain limited circumstances. We will not disclose information about your creditworthiness to our affiliates, other than permitted by Vermont law, unless you authorize us to make these disclosures.

Contact Us

If you have any questions about our privacy practices, or to exercise your rights outlined above, please contact us at privacy@cowen.com.

This Notice was last updated on March 1, 2023.