CIBC Privacy Policies

To help you understand our privacy policy, here are some important terms you should know.

• “Personal information” or “information” means information about an identifiable individual, such as contact information, account numbers, demographic information like age and marital status, financial information, biometric information, photographs and signatures. This can also include information collected through your activities on CIBC Digital Channels, such as device model, browser type and IP address.
• “CIBC”, “we”, “our” or “us” means collectively Canadian Imperial Bank of Commerce and its Canadian affiliates that offer deposits, loans, mutual funds, securities trading, portfolio management, investment counseling, mortgages, credit cards, trust services, insurance and other products or financial products and services, including Simplii Financial.
• “CIBC Digital Channels” means our websites, mobile apps, social media accounts, virtual assistant, chatbot and other digital channels.
• “CIBC Foreign Affiliates” means CIBC’s businesses, affiliates, subsidiaries and branches of CIBC located outside of Canada, such as CIBC Bank USA.
• “Program partners” means companies we have carefully selected to provide benefits, products or services under, or to participate in, a CIBC partner program.
• “CIBC partner program” means a program under which CIBC clients are entitled to receive specified benefits, products or services that are provided by, or in participation with, our program partners, such as, affinity reward or loyalty programs, travel or credit insurance, purchase or credit protection programs and retailer offers or coupons.
• “Permitted or required by law” or “legal and regulatory obligations” means actions that we are permitted or required to take under applicable laws or regulations, or applicable rules, codes, guidelines, expectations or requests of any applicable regulator or self-regulatory organization, or under any codes, programs or principles publicly adopted by CIBC.

This policy, the privacy terms of your agreements with us and our privacy notices provide an overall description of CIBC’s privacy practices. This policy applies to the collection, use and sharing of any personal information collected by CIBC while conducting our business in Canada. Please note this policy does not apply to information that is not considered personal information. For example, information about a business or company is generally not considered personal information. Within this policy, we explain how we collect, use, share and protect personal information collected by CIBC, including through CIBC Digital Channels. We also provide information about the rights and choices you have regarding your personal information. 

This policy will continue to apply for as long as CIBC holds your information, including after the termination of any of your product or service agreements with us. By providing us with information, you are consenting to the collection, use and sharing of your information as set out in this privacy policy.

We may update this privacy policy and our other privacy-related documents. Any changes we make to this privacy policy will be effective when we post the revised policy on our websites. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy. The date at the top of this policy indicates when it was last revised.

The type of personal information we collect depends on various factors, such as the type of products or services you request or use, any applicable legal and regulatory obligations and the channel through which you communicate with us. This information includes:

• Contact information that allows us to communicate with you, such as your address, telephone number, email or other electronic address, social media account username and fax number.
• Credit and other financial information from credit bureaus, as described in Section 6, “What are the specific ways we may collect, use and share your information?”
• Identity information that allows us to establish and verify your identity, including government-issued identification and utility bills, name, date of birth and occupation.
• Biometric information refers to the measurement of physical and behavioural characteristics, such as facial features and voice patterns, that enable machines to verify identities. This may be a digitized profile of your voice, known as voiceprint, that allows us to verify your identity when you call us.
• Tax Identification Number, such as a Social Insurance Number or SIN, to comply with legal or regulatory requirements, such as the Income Tax Act (Canada), which requires us to collect your SIN when opening a product that earns income. We may also ask for your SIN to help us verify your identity and ensure we obtain accurate information from credit bureaus. Providing your SIN for this purpose is optional. Refer also to Section 9, “What are your privacy choices?”.
• Financial information that allows us to determine eligibility for, and appropriateness of, products or services, such as employment and financial history, income, net worth, credit reports, investment knowledge and objectives and details of security provided for loans.
• Transactional information about how you use different products or services, such as purchase and payment history.
• Health and lifestyle information including family health history, personal activities, behaviours and lifestyle choices that helps us assess your eligibility for life and health insurance products, calculate appropriate premium rates, administer the insurance and adjudicate claims. Health and lifestyle information may include travel plans, hazardous sports and leisure activities. Due to the sensitive nature of this type of information, health and lifestyle information collected for this purpose will not be shared for marketing or loan assessment purposes.
• Another individuals’ information we request, or that you provide about individuals other than yourself. This could be information about beneficiaries or insured spouses, common-law partners or dependents under an insurance product or a registered plan. It could also be information about an authorized user of your account or contact information of someone you believe may be interested in a CIBC product or service. If you provide us with information about another individual, we will assume you have the authority to provide this information and have obtained their consent to its collection, use and sharing for the purposes set out in this privacy policy.
• Information collected through your interactions with CIBC Digital Channels. For example, we may collect:
  • Profile information, such as your digital IDs, passwords and service preference, for example, your preferred language.
  • Web browser information, such as the type of web browser you use, for example, Microsoft Edge, Chrome, Safari and Firefox, or the address of the site you came from if you clicked on a CIBC ad.
  • Device information, such as device details, for example, device ID, model, operating system or device notification status, privacy settings and other device configurations or settings, location information, or your IP address, which is a number that is automatically assigned to your computer or device when you browse the Internet, and from which the general geographical location of the device can be derived.
  • Location information, such as broad location information derived from your IP address and geolocation information from your browser or mobile device, if you have enabled it to share this data.
  • Other web technology derived information via tools, such as cookies and web beacons. This may include information such as a unique identifier and your response rate to understand how you are using our CIBC Digital Channels. For example, with this response rate we can measure, on an aggregated basis, how many individuals are interacting with a digital advertisement.
• Other information we collect that helps us to understand our relationship with you by learning more about you, including how you like to do business with us, and what types of products, services or offers you may like or be interested in. This can include information you provided to us by various means such as language and communication preferences, demographics and interests.

We may collect information from you directly, from third parties or automatically through your interactions with various CIBC channels, including CIBC Digital Channels and Telephone Banking.

Directly from you. We may collect personal information directly from you, including in the following circumstances:

• When you communicate with us
• When you apply for a product or service with us
• When you subscribe to our communications such as newsletters
• When you fill out CIBC forms, such as on CIBC Digital Channels or in the Banking Centres
• When you complete a research survey on CIBC’s behalf
• When you post content directed at CIBC’s social media profile on any social media platform, such as photographs or comments

We also collect your personal information from your use of our products and services.

From third parties or public sources. We may collect personal information from third parties or public sources. We do so with your consent or as permitted or required by law. For instance, we may collect personal information from the following categories of third parties or public sources:

• Credit bureaus. Refer also to Section 6, “What are the specific ways we may collect, use and share your information?”
• Government institutions or regulatory authorities
• Insurance information bureaus in order to assess insurance risk
• Program partners, who may provide us with information in relation to a program in which you participate 
• Public sources such as telephone directories, newspapers, Internet sites, commercially available marketing lists, or government agencies and registries like land or property registries or driver’s license offices, or public records as defined by applicable laws 
• Other financial institutions, such as for fraud management purposes
• Other organizations through business transactions or strategic partnerships
• Third party identity verification and authentication service providers
• References you have provided

Through automated means. We may also collect information by monitoring or recording your interactions with CIBC through telephone calls and video conferencing, including those of Foreign Affiliates and CIBC Digital Channels, to:

• Enhance and maintain our quality of service, including to determine your eligibility for offers and promotions
• Protect you and CIBC from security threats and criminal activities
• Confirm our discussions with you
• Conduct quality assurance and coaching, such as a manager and an agent listening to a call together to identify improvement opportunities
• Prevent or detect fraud by analyzing interactions with our online services to help authenticate you

We also use video recording and other surveillance as necessary, in and around our CIBC Banking Centres, bank machines, offices and other locations, to:

• Maintain the safety of our clients, employees and others 
• Protect against illegal activity, such as theft, vandalism and fraud
• Enhance and maintain client service quality

At CIBC, we take the protection of your personal information seriously. We make reasonable efforts to prevent unauthorized use, sharing, loss and theft of information. We regularly audit our security measures and assess that they remain effective and appropriate. Our employees who have access to your information are aware of the importance of keeping it confidential.

Information may be shared with or accessed by our service providers so that they can perform services on our behalf. We are careful when selecting our service providers and require them to have privacy and security standards that meet CIBC’s requirements. We use contracts and other measures with our service providers to maintain the security of your information and to prevent it from being used for any other purpose other than that for which it was intended.

Protecting the security of your personal information and the financial transactions you conduct online is of utmost importance. We use multiple layers of protection when you access any of our digital products or services, such as digital banking, including:

• Web browser encryption: all browsers supported by CIBC digital services offer industry standard encryption. This provides a high level of protection for transmitting confidential data over the Internet.
• Monitoring: we monitor activity on CIBC digital services to enhance security and to protect your personal information.

CIBC sites may contain links to non-CIBC sites. CIBC is not responsible for the information and privacy practices of these third-party sites. We recommend that you read any such third-party site’s privacy policy to learn about its information and privacy practices before you provide any personal information.

The length of time we keep your information will vary depending on the product or service and the type of information we have. We keep your information for as long as we reasonably need it for customer service, legal or reasonable business purposes. For these reasons, we keep your information beyond the end of your relationship with us. When your information is no longer required, we securely destroy it or make it anonymous. Depending on the nature of the information, your information may be stored in the CIBC Banking Centre or office where you regularly do business, in computer systems or in the record storage facilities of CIBC or our service providers.

Information may be stored and processed in any country where we have affiliates or service providers. By using our products or services, you consent to the transfer of information to countries outside of Canada, including the United States, which may provide different data protection rules. CIBC, service providers and other third parties, including CIBC Foreign Affiliates, with whom we share information under this policy, may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.

Subject to legal, business or contract requirements, you can withdraw your consent to our collection, use and sharing of information at any time by giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products and services. For example, if you choose not to provide us with your SIN, we will not be able to provide you with any product where the collection of a SIN is required under tax law, such as a registered product like an RRSP.

In certain circumstances, your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use and sharing is permitted or required by law, is required to ensure we have correct and up-to-date information about you, such as your current address, or is necessary to manage our business, including the sharing of information when we assign our rights to others for business transactions.

In particular, during our relationship with you, we provide you with the following privacy choices:

Social Insurance Number (SIN)

Including your SIN in a credit bureau request is the best way to make sure the information we obtain from credit bureaus accurately refers to you. This use of your SIN is optional and, if you choose not to give your permission, this by itself will not prevent you from qualifying for products and services. We only use your SIN as part of credit bureau requests when qualifying you for products and services or reporting information to the credit bureaus and do not use your SIN on an ongoing basis, as described in Section 6, “What are the specific ways we may collect, use and share your information?”

Marketing

Subject to applicable law, CIBC may offer you products and services of CIBC or of CIBC Foreign Affiliates, including special promotions, which may be of interest to you. Your consent to receive marketing communications is optional and you can decide to withdraw it at any time. However, this will not limit the information provided to you through discussions with a CIBC representative or through general CIBC marketing or servicing communications, such as posters in CIBC Banking Centres and electronic messages on banking machines or our website, or information we send you that is related to your existing products or services or is permitted or required by law. We may also, from time to time, communicate with you to ask whether you wish to update your marketing preferences to help ensure that our records are up-to-date and reflect your current preferences.

If you wish to update your marketing preferences: 

Contact the CIBC Banking Centre or office where your account is held or talk to your CIBC representative or if you are a CIBC banking client, call us at 1-800-465-2422 Opens your phone app.. For other CIBC clients, such as CIBC Private Investment Counsel and CIBC Wood Gundy, refer to one of the contacts in the section for “Addressing any privacy concerns” below. We will then update your file as quickly as possible. It may take some time for our records to reflect your choice. Also note that your choice may not be captured for a promotion already in progress. You may also opt out of email communications by selecting the “unsubscribe” link included in each of our commercial electronic communications.

Interest-based advertising 

Interest-based advertising uses information collected from your browsing behaviour to help predict your preferences and provide you with CIBC-related advertisements that will be more relevant to you on our mobile apps, our website and third-party websites. 

If you wish to update your interest-based advertising preferences:

If you opt out of interest-based advertising, you may still get CIBC online advertising, but it won’t be tailored to your preferences. The following are ways in which you can manage your preferences for interest-based advertising:

• AdChoices
  • We are a member of the Digital Advertising Alliance of Canada’s (DAAC) AdChoices program. AdChoices is a self-regulated program for companies participating in online interest-based advertising. The program aims to give Canadians more information and choices about the advertising they get. To learn more about this program, visit the AdChoices in Canada page Opens in a new window.
  • To opt out of interest-based advertising from some or all AdChoices program participants, use the AdChoices’ opt-out tool for browser data on their tools page Opens in a new window.. This page will scan all of the advertising cookies held on your browser, and a check box will appear under the opt-out column beside companies that are using cookies while you browse sites. To manage your preferences and opt out, check the boxes and select submit. AdChoices’ Mobile AppChoices tool for app data also lets you opt out of cross-app data collection for the purposes of interest-based advertisements. You can refer to the same webpage for more details.
• Adobe
  • We also work with the Adobe Marketing Cloud to provide interest-based advertisements. To opt out from receiving these types of advertisements and from Adobe Analytics, set your preferences directly through Adobe Opens in a new window.. You can opt out of interest-based advertising, under the “Adobe interest-based ads” section, and you can opt out from ad tracking through the “Adobe websites” section.
• Google Advertising
  • We also work with Google Advertising to provide interest-based advertisements. To opt out of interest-based Google advertisements, set your preferences using Google’s Ad Settings Opens in a new window.. You can also opt out of Google Analytics with Google’s opt-out browser add-on Opens in a new window..
• Operating System
  • Depending on your operating system, you may be able to opt out of interest-based advertising by going into your settings, selecting the app in question, and turning off “Allow Tracking”.
  • If your operating system does not have this option, you can opt out of interest-based advertising by visiting the individual sites or app of choice, such as TikTok or Facebook, for information on their privacy practices and opt-out settings. For example, CIBC uses Facebook and TikTok pixels on CIBC websites for interest-based advertising and website optimization.

Device information

If you wish to manage the data you share with us on your device

The ability to access certain personal information is managed through your device settings. For example, you may allow your device to share your camera, contacts and photos. However, some services may not operate effectively without this access. Your device support will have instructions for how to manage these permissions.

If you wish to manage notifications and alerts on your device

If you have installed our mobile app and wish to stop receiving push notifications, set your preferences within the mobile app. You may also manage push notifications at the device level.

Login information

If you wish to manage your login IDs and passwords

Many browsers and devices allow you to store passwords and login ID so you are not required to re-enter this information each time you access a site. To prevent unauthorized access to your information, we strongly recommend you do not use this functionality when accessing CIBC digital properties.

Cookies

If you wish to manage cookies

You can block or disable third-party cookies in your browser settings so that your browser accepts only first party cookies, which are those cookies belonging to the site you are currently browsing including cookies from CIBC when you are on CIBC’s site.

Location information

If you wish to manage your location information

The ability to share your location information is managed through your device settings. CIBC will not collect or use certain types of location information from your mobile device if the location services, for example, GPS, geolocation or proximity technologies, are disabled.

Call recording

Telephone calls with CIBC representatives may be recorded and monitored for coaching, training, quality and security. Refer also to Section 4, “How do we collect information?”

If you do not wish to have your telephone calls recorded

You have the option to conduct your business with us through a CIBC Banking Centre, office or location, through the use of our bank machines, through our Internet banking services or by writing to us.

We make every reasonable effort to keep the information in our records as accurate, complete, and up-to-date as necessary for the purposes which it is used. However, we also rely on you to tell us when your information changes. Keeping your information accurate and up-to-date allows us to continue to offer you the highest-quality service.

If you want to update or correct any personal information we hold about you:

Contact the CIBC Banking Centre or office where your account is held or talk to your CIBC representative. If you are a CIBC banking client, call us at 1-800-465-2422 Opens your phone app.. You can also sign on to CIBC Online Banking^®.

You have the right to access personal information we hold about you. Much of your information is available to you through your paper or electronic account statements, by visiting the CIBC Banking Centre or office where you regularly do business, by accessing your account online or through Telephone Banking. 

If you want access to additional personal information we may hold about you:

Contact the CIBC Banking Centre or office where your account is held or talk to your CIBC representative. 

We will require you to put your request in writing. We can provide you a form and you can provide us with enough specific details to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for, or providing you with, access to your information. We will let you know in advance whether there will be a fee to provide access to your information. We may also ask you for additional information to confirm the scope of your request, such as the relevant time period or a specific description of the information you are seeking to access.

Once we receive your written request, verify your identity and understand the scope of your request, we will provide a written response to your access request within the time frame set by applicable privacy law.

If you have a sensory disability, you may request your information in an alternative format. If we already have this format, we will provide it. Otherwise, we will convert the information into the requested format if it is reasonable and in accordance with applicable privacy law to enable access. There may be limits on your right to access your information. For example, if the information is subject to legal privilege, contains confidential commercial information, relates to an investigation of a breach of an agreement or law, or contains information of other individuals that cannot be separated.

If we have obtained information about you from others, you can ask us for the source of that information. On request and where legally permitted, we will provide you with the types of third parties to whom we have, or may have, given your information. However, this will not include service providers we have used to do work for us. It will also not include reports to the Canada Revenue Agency or information that has been provided for legal and regulatory obligations.

If you request access to a credit report we obtained about you from a credit bureau, we will give you a copy if we still have it on file. We also will provide you with the name and address of the credit bureau we used, as they will have the most current information and can provide you with instructions on how to read the report. You have the right to access and correct the credit bureau report directly with the credit bureau. For contact information for credit bureaus with whom CIBC may exchange information, refer to Section 6, “What are the specific ways we may collect, use and share your information?”

If you have any questions, concerns or complaints about this policy or our privacy practices, let us know right away. In most cases, a question, concern or complaint is resolved simply by talking to us about it. If you choose to send us an email, don’t include sensitive information such as card or account numbers. 

You may also request a printed copy of our privacy policy or more details about our privacy policy and practices, including with respect to service providers outside of Canada. Refer to our CIBC Privacy Principles or Privacy FAQ.

Step 1: Talk to us

The following steps apply to CIBC Banking Centre clients:

You should be able to get swift results by talking to a CIBC representative where you do business.

• Talk to a CIBC representative 
• Visit your nearest CIBC Banking Centre 
• Call  1-800-465-2422Opens your phone app.

• 1-800-567-3343 Opens your phone app.
• Email us at CIBCInvestorServicesInc@cibc.com Opens your email app.

• Contact your Investment Advisor.

• Contact your Investment Advisor or call Client Relations at 1-800-563-3193 Opens your phone app.

• Telephone: 1-888-723-8881 Opens your phone app.
• TTY Service: 1-888-632-9022 Opens your phone app.
• Email: talktous@simplii.com Opens your email app.
• Write to:

Step 2: Contact the CIBC Client Care Centre

If your question, concern or complaint isn’t resolved to your satisfaction, you can contact the CIBC Client Care Centre, which handles privacy related matters and escalates to the Chief Privacy Officer when required:

Telephone: 1-800-465-2255 Opens your phone app.
Email: Opens your email app.client.care@cibc.com Opens your phone app.

Write to:
CIBC Client Care
Attention: Chief Privacy Officer
PO Box 15, Station A
Toronto, Ontario
M5W 1A2

Be sure to include your name and contact information where you prefer to be reached, the nature of your complaint, question or concern, details relevant to the matter and the names of any individuals whom you have already discussed the issue with.

Step 3: Contact the CIBC Client Complaint Appeals Office

If your question, concern or complaint has still not been resolved to your satisfaction by Client Care, feel free to contact the CIBC Client Complaint Appeals Office:

Telephone: 1-800-947-5207 Opens your phone app.
Email: Opens your email app.ClientComplaintAppeals@cibc.com Opens your email app.

Write to:
CIBC Client Complaint Appeals Office
P.O. Box 342
Commerce Court
Toronto, Ontario
M5L 1G2

If the above steps do not resolve your concern, you may consider escalating the matter further.

Office of the Privacy Commissioner of Canada (OPC):

You may contact the OPC to help resolve a privacy concern you have:

Telephone: 1-800-282-1376Opens your phone app.
Website: priv.gc.caOpens in a new window.
Write to: 30 Victoria Street
Gatineau, Quebec
K1A 1H3

Depending on the nature of your concern, you may also contact Independent Consumer Support Agencies.