CIBC Privacy Policies

• “Personal information” or “information” means information about an identifiable individual such as contact information, account numbers or details, such as age, marital status and financial information. This information can be in any form including paper, electronic, audio, video or biometric, such as voiceprints, photographs and signatures. This information can also include information collected through digital activities, 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 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. For example, 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 do 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 works together with our CIBC Privacy Principles, our Digital Privacy Statement and the privacy provisions in the terms of your agreements with us to form CIBC’s privacy policy. This policy applies to the collection, use or sharing of any personal information collected by CIBC in the course of conducting our business in Canada. It 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 or sharing of your information as set out in this privacy policy.

For more information about our privacy practices, review the CIBC Privacy Principles, Digital Privacy Statement or our Privacy Frequently Asked Questions (FAQ).

This privacy policy and our other privacy-related documents will be updated from time to time.

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

• Contact information that allows us to communicate with you, such as  name, address, telephone number, email or other electronic address, social media account name and fax number).
• Identity information that allows us to establish your identity, including government-issued identification and utility bills; authenticate your identity through biometric technologies such as voice recognition, identity verification or analysis of interactions with our online services; or to meet tax, anti-money laundering and other “know your client” legal and regulatory obligations, such as date of birth, occupation and government-issued identification.
• Social Insurance Number (SIN) to comply with legal or regulatory requirements, such as the Income Tax Act of Canada requires us to ask for your SIN when opening a product that earns income. We may also ask for your SIN as an aid to verify your identity and ensure we obtain accurate information from credit bureaus. However, providing your SIN for this purpose is optional (refer to “Your privacy choices” below).
• Financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services offered to you, such as employment and financial history with others, 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 or otherwise do business with us, such as, purchase and payment history.
• Health and lifestyle information about your health, family health history, activities, behaviour and 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 individual’s information we request, or that you provide, about an individual other than yourself. For example, this could be information about beneficiaries or insured spouses, common-law partners or dependents under an insurance product or a registered plan; an authorized user of your account; and 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 or sharing for the purposes set out in this privacy policy.
• 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. This can include language and communication preferences, location, demographics and interests.

We may collect information from you directly, indirectly or from other sources, such as:

• product or service applications and use 
• communications with us
• credit bureaus (refer to “Credit bureaus” below for further detail)
• insurance information bureaus
• references you have provided
• program partners
• other financial institutions
• government institutions or regulatory authorities
• user-generated content on our social media websites such as photographs or comments you post
• 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 licensing offices, or public records

We may also collect information by monitoring or recording your interactions with CIBC through telephone calls, video conferencing, online chats or other interactions with CIBC’s websites and mobile sites in order to:

• enhance and maintain client service quality, including to determine your eligibility for offers and promotions
• protect you and CIBC
• confirm our discussions with you
• conduct quality assurance and coaching. For example, a manager and agent may listen to a call together to identify improvement opportunities
• prevent or detect fraud by analyzing interactions with our online services to help authenticate you

We use surveillance, including video recording, in and around our CIBC Banking Centres, bank machines and other locations to

• maintain the safety of our clients, employees and others; 
• protect against illegal activity, such as theft, vandalism and fraud; and 
• 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 made 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 confidentiality and security of your information and to prevent it from being used for any other purpose other than that for which it was intended.

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 delete personally identifiable information. 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 various 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 contractual requirements, you can withdraw your consent to our collection, use or sharing of information at any time upon 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 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 credit bureau information accurately refers to you, however, 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. If you have provided your consent for us to use your SIN for this purpose, you may choose to withdraw your consent at any time.

If you wish to withdraw your consent to use a SIN as an aid to identify you in credit bureau requests:

You may choose to withdraw your consent at any time by contacting the CIBC Banking Centre or office where your account is held or talking to your CIBC representative.

Marketing

Subject to applicable law, from time to time 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 BankingCentres 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. 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. To manage your digital privacy choices, refer to our Digital Privacy Statement. You may also opt out of email communications by selecting the “unsubscribe” link included in each of our communications.

Call recording

Telephone calls with CIBC representatives may be recorded and monitored for coaching, training, quality and security (refer to “How we collect information” for further detail). 

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.

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

Keeping your information updated

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 or sign on to CIBC Online Banking®, and where available, edit your information under Customer Services. If you tell us that we have information about you that is obsolete or incorrect, we will update our records as necessary. When appropriate, we’ll correct any information which we may have given to a third party.

Accessing your information

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 give you a form) and 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 in accordance with the time frame prescribed 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 names of third parties to whom we have given 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.

Addressing any privacy concerns

If you have any questions, concerns or complaints about this policy or our privacy practices, let us know right away. 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, Digital Privacy Statement or Privacy FAQ.

The following steps apply to CIBC Banking Centre clients:

Step 1: Talk to us

In most cases, a question, concern or complaint is resolved simply by talking to us about it. 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.

CIBC Everyday Banking

1-888-872-2422 Opens your phone app.

Email us Opens your email app.

CIBC Credit Cards

1-800-465-4653 Opens your phone app.

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:

Telephone: 1-800-465-2255Opens your phone app.
Fax: 1-877-861-7801
Email: Opens your email app.client.care@cibc.comOpens your email app.

Write to:
CIBC Client Care
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 Ombudsman

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

Telephone: 1-800-308-6859Opens your phone app. or 416-861-3313Opens your phone app. in Toronto
Fax: 1-800-308-6861 or 416-980-3754 in Toronto
Email: Opens your email app.ombudsman@cibc.comOpens your email app.

Write to:
CIBC Ombudsman
P.O. Box 342
Commerce Court
Toronto, Ontario
M5L 1G2

For other CIBC clients, such as clients of CIBC Private Investment Counsel and CIBC Wood Gundy, refer to the escalation process provided to you when you opened your account, contact the CIBC office where your account is administered or speak to your CIBC representative.

CIBC Investor's Edge and Imperial Investor Service

1-800-567-3343 Opens your phone app.

Email us Opens your email app.

Private and Investment Counsel
Contact your Investment Advisor.

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

For Simplii clients, if you require information about your privacy rights and how to exercise them, please contact Simplii Financial:

Telephone: 1-888-723-8881Opens your phone app.

TTY Service: 1-888-632-9022

Email: talktous@simplii.comOpens your email app.

Write to:
Simplii Financial
PO Box 603, Stn. Agincourt
Scarborough, Ontario
M1S 5K9

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.