Some of the specific ways we collect, use and share your information within CIBC or with CIBC Foreign Affiliates and other third parties include:
To protect you
Where you might be a victim of fraud, financial abuse or other illegal activity, or where we have reasonable grounds to believe your interests can best be served by taking action, we may share information with the appropriate legal or governmental authorities, your next of kin or any other appropriate person. For example, notification of our concerns regarding potential financial abuse may be provided to a public guardian or trustee’s office. In these circumstances, we will only share information we believe is reasonably necessary to protect your interests.
We employ technologies to help prevent you from becoming a victim of fraud. For example, we offer an optional voiceprint-based authentication system for even greater security. These voiceprints cannot be used to reconstruct your voice. We may also use personal information to authenticate you or your device. For example, with your consent, we may use facial comparison technology to confirm your identity when you apply for new products online.
We use session cookies to protect your security on CIBC Digital Channels. These cookies ensure that your session is secure while you are signed on. Refer also to Section 6, “What are the specific ways we may collect, use and share your information?”
To protect us or where permitted by law
We collect, use and share information to protect our rights or interests, including the prevention, detection and investigation of fraud, money laundering, cyber threats and other risks and threats. For example:
- We may need to use and share your personal information where we are involved in judicial, administrative or regulatory proceedings or investigations, or other similar processes
- We may use and share your personal information in order to protect our interests, including to collect on a debt
- We may share your personal information to comply with legal and regulatory obligations, including any subpoena, warrant, judicial or administrative orders, or valid demands or requests from governments, regulators, courts and law enforcement authorities in Canada or other jurisdictions or countries
- We may share information with other organizations to investigate a breach of an agreement or law, or to detect, suppress or prevent fraud
- We will review and analyze your applications, transactions and other information to help us identify various types of threats and risks such as credit, fraud and money laundering. For these purposes, your information may be pooled with data belonging to other individuals and subject to data analytics
We may also collect, use and share information without consent where permitted by law.
We share information with our program partners — for example, Aeroplan, Journie Rewards, Costco — to help determine your eligibility for a CIBC partner program. If you participate in a CIBC partner program, CIBC and the program partner will share information in order to administer, develop, manage and promote the CIBC partner program, including accrual of points or rewards, reporting on and analyzing the program’s performance, developing new benefits, products and services and conducting market research. If you withdraw your consent to this sharing, you may not be able to participate in the CIBC partner program where the sharing is necessary to receive the benefits and features of the program. CIBC and our program partners may provide you with a particular privacy notice governing the collection, use and sharing of your personal information in relation to a program.
Joint accounts, representatives and beneficiaries
Where you hold a product or service jointly with another person, like joint accounts, or where someone is authorized to use or access your product or service such as a credit card, or where liability is shared with others such as someone providing a guarantee or indemnity for your obligations, we may share your information with them (or their representative, which includes their estate representative) in connection with the product or service. Where someone is acting as a representative or we reasonably believe is acting with proper authorization, such as a legal guardian, person having power of attorney, estate representative, lawyer, accountant and, for minor children, parent or guardian, we may share information with and take instructions from them including sharing information as instructed by either representative where representatives are jointly appointed. Following death, we may also share your information with your beneficiaries or estate representatives where reasonably necessary to help in the administration of your registered plans or insurance products or your estate’s financial affairs. If you are the surviving joint account holder, we may also share information about your account created or collected before a deceased joint account holder’s death with the representative of the deceased joint account holder.
Where we administer or sell insurance, we collect information on behalf of and share information with the insurance underwriter as their service provider to help sell and administer the insurance, pay claims and resolve complaints. Where we are the insurance underwriter, we share information with people or organizations, such as health care practitioners, medically related facilities, and insurance information bureaus, necessary to provide you with insurance products and services. Where we have entered into an agreement with a reinsurer to manage our risk, we share information with the reinsurer. We require the reinsurer to keep this information confidential and limit its use to the purpose of reinsurance.
If we enter into a business transaction involving personal information or are considering one, such as selling or securitizing assets, we may share information with the other parties to the transaction. For example, we may do so as part of due diligence or on completion of the transaction. We require that the other parties keep this information confidential and limit its use to the purposes of the transaction. Where we enter into a business transaction involving the purchase of information by us, this policy will apply to our collection, use and sharing of the purchased information. This may include information we continue to hold beyond the end of your relationship with us. If we sell assets, the purchaser may be permitted or required by law to retain certain information for a period of time. We may also share your information with the beneficial owner of a product or service we provide to you.
Within CIBC and with CIBC Foreign Affiliates
We may use and share information within CIBC and with CIBC Foreign Affiliates, to manage your total relationship with us and with CIBC Foreign Affiliates, including opening and servicing your accounts and maintaining information about you, to make doing business with us and with CIBC Foreign Affiliates easier, such as pre-populating applications, to manage and assess risks and operations including to collect a debt owed by you, to prevent and detect fraud or other unauthorized activity, to offer or promote products and services, to perform analytics, to facilitate internal operational, administrative and support services within our organization and to comply with legal or regulatory obligations. As such, your personal information may be transferred outside of Canada and information shared with CIBC Foreign Affiliates will be subject to the privacy policies of those affiliates and to the laws of those countries.
Where you hold a credit product such as credit card, loan, line of credit or mortgage with CIBC, or a deposit account with overdraft protection or hold or withdrawal limits, we will exchange information about you with credit bureaus at the time of application and on an ongoing basis, for as long as you hold the product and for a reasonable time afterwards, similar to other financial institutions. The credit and other information we collect from credit bureaus may include information about your current and past credit accounts, such as type, amount, payment history, collections actions, legal proceedings or other information that the credit bureau has collected from your other lenders. We may collect, use and share this information to assess your application for credit, verify your creditworthiness, assess and manage our credit risks and improve products and services, establish credit and hold limits, qualify you for other products and services and detect and prevent fraud. We may also periodically share credit, financial and other information about you with credit bureaus, to help maintain the accuracy and integrity of the credit reporting system. The credit bureau will incorporate the personal information they receive from us into its consumer reporting database and use the information for the purposes of maintaining the credit reporting database and as otherwise permitted or required by applicable laws, which may include sharing this information with third parties. If you consent to us providing your SIN to credit bureaus, it may be used by the credit bureaus to update their consumer reporting database and to assist them in matching and verification purposes. Such use by the credit bureau may include the verification, at its discretion, of personal information it maintains about you. If you apply for a product or service online or over the phone, we may also validate your information with a credit bureau to verify your identity and protect against fraud.
We may exchange information about you, as described in this policy, with the following credit bureaus:
TransUnion Opens in a new window.
3115 Harvester Road
Equifax Opens in a new window.
5700 Yonge St., Suite 1600
De-identification and analytics
We may de-identify or anonymize your information by removing identifiable information, such as your name, address, and account numbers. This information may be aggregated with other information and used for internal business purposes such as analytics and reporting, developing and improving our products and services, understanding and predicting client needs and preferences, preventing and detecting fraud, identifying trends like purchasing patterns and fraud trends or enhancing our marketing. Refer also to Section 5, “How do we use and share information?”
Cookies and similar technologies
We use persistent cookies to measure site and mobile app usage, including browsing behaviour, to improve functionality, and evaluate effectiveness of our sites, communications and promotional offers. For example, we may measure and track CIBC web and mobile pages viewed or how you came to our sites which includes the CIBC online marketing ad you selected, the address of the site that you came from when you selected the CIBC ad, the sites you are accessing that have CIBC ads, or keywords you searched to find our site.
Persistent cookies are also used to save your CIBC digital banking personal preferences. You must allow persistent cookies if you want your browser to remember your preferences such as card number, language or default home page each time you sign on.
We use location information derived from your IP address from your browser or mobile device and geolocation information, for example, GPS location from your browser or mobile device, if you have enabled it to share this data. We may also use location information to personalize your user experience, including through site or mobile app content, marketing, or offers for products and services.
Some services may involve access to information on your device. For example, accessing your contact list can make it easier to use Interac e-Transfer® banking services, or accessing your photos and camera can make it easier to complete a remote cheque deposit on your mobile device. Some services may allow your device and your wearable to communicate with a CIBC app, such as for Apple Watch®.