CIBC Privacy Policy

Revised August, 2017

Your Privacy Is Protected

Your privacy is important to us: We value the trust you have placed in us by choosing CIBC as your financial services provider. At CIBC, protecting the privacy and confidentiality of your personal information is very important to us and an integral part of our commitment to service excellence. To help us meet this commitment to you, CIBC has appointed a Chief Privacy Officer to oversee CIBC’s privacy practices and this privacy policy.

Your privacy is important to you: We encourage you to read this privacy policy so that you can understand how we collect, use, share and protect your personal information and how you can manage your information in a way that best suits you. 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, or details such as age, marital status, and financial information. This information can be in any form including paper, electronic, video or voice recording.
  • “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 services. 
  • “CIBC Foreign Affiliates” means CIBC’s businesses, affiliates and subsidiaries outside of Canada.  
  • “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 any laws or regulations, or any 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.

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About this privacy policy

CIBC Privacy Principles, together with our Online Privacy Statement and any privacy provisions in the terms of your agreements with us, forms 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 its business in Canada and will continue to apply for so long as CIBC may hold your information (including after the termination of any of your product or services agreements with us). By providing us with information, you are consenting to the collection, use or sharing of your information as set out in our privacy policy.

For more information about our privacy practices, review the CIBC Privacy PrinciplesOnline Privacy Statement or our Privacy Frequently Asked Questions (FAQ) or read the "How to Contact Us" section below.

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


What we collect and how we collect it

The type of personal information we collect will depend 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 or contact you (e.g. address, telephone number, email or other electronic address, social media account name and fax number).

Identity information that allows us to identify you, authenticate you (e.g. voice recognition) or to meet tax, anti-money laundering and other “know your client” legal and regulatory obligations (e.g. name, Social Insurance Number (SIN), date of birth, occupation and government-issued identification).

Financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services (e.g. 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 (e.g. purchase and payment history).

Relationship information that helps us to understand more about you including how you like to do business and what types of products, services or offers you may like (e.g. language and communication preferences, location, demographics and interests).

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. Such information may include travel plans and 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 (e.g. information about beneficiaries or insured spouses 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 their consent to its collection, use or sharing for the purposes set out in this privacy policy.

We collect information from a variety of sources but much of the information comes from you (e.g. applications for or use of our products or services, communications with us and user-generated content on our social media websites such as photographs or comments you post).

We also collect information from other sources such as credit and insurance information bureaus, references you have provided, program partners, government or financial institutions or from public sources such as telephone directories, newspapers, Internet sites, commercially available marketing lists or government agencies and registries or public records.

We may monitor or record communications between you and our representatives (e.g. telephone calls, video conferencing) in order to enhance and maintain client service quality, to protect you and CIBC, to confirm our discussions with you or for training purposes. We use surveillance, including video recording, in and around our banking centres, ATMs and other locations; for the safety of our clients, employees and others, to protect against illegal activity, such as theft, vandalism and fraud, or to enhance and maintain client service quality.


How we use and share information

When we make reference to sharing information within CIBC it means sharing among CIBC and its Canadian affiliates.

We use and share personal information to:
 

Provide you with products or services

  • Establish your identity and determine your eligibility for products and services 
  • Help to ensure that the advice, products and services offered to or purchased by you are appropriate for you
  • Set up, manage, administer and maintain your products and services


Communicate with you

  • Send communications by various methods, such as mail, email, text message, telephone, automatic dialing-announcing device (at the numbers you have provided to us), fax, other telecommunication channels or social media; including marketing or communications about benefits, features or other details about products or services


Provide you with value

  • Review and analyze your applications, transactions and other information to understand who you are, your financial needs and activities, and what products, services and promotions may be of interest to you; including targeting promotions based on information that we have collected
  • Promote and market products and services offered by CIBC and CIBC Foreign Affiliates, by our program partners or other third parties we have carefully selected
  • Better manage and improve your overall relationship with CIBC including monitoring, reviewing or improving client service and business processes to make it easier to do business with us
  • Encourage you to continue doing business with us


Manage our business

  • Perform our everyday business and operations including record keeping or internal reporting (e.g. if you have provided your SIN it can be used as an internal identification number to accurately identify you from clients having the same or similar names)
  • Understand and better manage CIBC’s business and to develop products and services, including conducting market research or analyzing data we hold about you
  • Administer referral arrangements
  • Use third-parties to perform services on our behalf
  • Insure, reinsure or otherwise protect, CIBC’s interests in its own product and services portfolio (e.g. obtain insurance for CIBC’s mortgage loan portfolio or obtain reinsurance to manage CIBC’s insurance risk) 
  • Periodically update your information with credit bureaus, as long as you have the product or service with us and for a reasonable period of time thereafter
  • Manage CIBC’s credit, business and other risks as may be required to operate as an effective, efficient and financially prudent financial institution
  • Meet tax or legal and regulatory obligations
  • Protect you and us from error and criminal activity including the prevention, detection and investigation of fraud, money laundering, cyber threats and other such risks and threats (e.g. 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)

Some of the specific ways we use and share your information within CIBC or with CIBC Foreign Affiliates and other third parties include:


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 (e.g. 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.


Protect us or where permitted by
law We share information to protect our rights or interests. For example, where we are involved in judicial, administrative or regulatory proceedings, or other similar processes including enforcing our rights (e.g. to collect on a debt). We may also share information, in order to comply with any 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 also collect, use or share information without consent where permitted by law.


Program partners
– We share information with our program partners 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, we may not be able to provide you with the product or service (e.g. where the program is an automatic benefit of the product like a product or service with a rewards program).


Joint accounts, representatives and
beneficiaries – Where you hold a product or service jointly with another person (e.g. joint accounts) or where someone is authorized to use or access your product or service (e.g. authorized user on a credit card), or where liability is shared with others (e.g. someone has provided 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 (e.g. 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 (this includes, where representatives are jointly appointed, sharing information as instructed by either representative). 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.


Insurance
– Where we administer or sell the 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 necessary people or organizations (e.g. health care practitioners, medically related facilities, 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.


Business transactions
– If we enter into a business transaction involving personal information, or when considering such transactions, such as selling or securitizing assets, we may share information with the other parties to the transaction (e.g. 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 privacy policy will apply to our collection, use and sharing of the purchased information (which 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 you.


CIBC Foreign Affiliates
– We may share information with CIBC Foreign Affiliates, to manage your total relationship with us including opening and servicing your account(s) and maintaining information about you, to manage and assess risks and operations including to collect a debt owed by you, to perform analytics, and to comply with legal or regulatory obligations.  

Information shared with CIBC Foreign Affiliates will be subject to the privacy policies of those affiliates and the laws of those countries.


Protecting your personal information

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 procedures 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. Depending on the nature of the information, it may be stored in the banking centre or office where you regularly do business, in various computer systems or in the record storage facilities of CIBC or service providers.

Where we use service providers who might have access to information, we select them carefully 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.

CIBC, service providers and other third parties (including CIBC Foreign Affiliates) with whom we share information under this privacy 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.

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.

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 for different data protection rules.


Your privacy choices

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 SIN is required under tax law (e.g. a registered product like an RRSP — Registered Retirement Savings Plan).

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

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.
 

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. Consent to receive marketing 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 channels (e.g. posters in banking centres and electronic messages on ATMs 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.
 

Call recording: 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 ATMs, 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 (e.g. 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 order to maintain the integrity of the credit reporting system, we may periodically update your information with credit bureaus as long as you have a credit product or service with us and for a reasonable period of time afterwards. Your consent to the exchange of information can’t be withdrawn during this time.
 

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 for 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.

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 account statements or bankbook updates, by visiting the banking centre or office where you regularly do business, by accessing your account online or through Telephone Banking. If you require other information, refer to the “How to contact us” section below.
 

Addressing any privacy concerns

If you have any complaints, questions or concerns about this privacy policy or our privacy practices, please let us know right away. If you choose to send us an email, don’t include sensitive information (e.g. card or account numbers).

The following process applies to CIBC banking clients. For other CIBC clients (e.g. clients of CIBC Private Investment Counsel and CIBC Wood Gundy), refer to the complaint process provided to you when you opened your account, contact the banking centre or office where your account is administered or speak to your CIBC representative.
 

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. You can speak with us in a banking centre or by calling Telephone Banking at 1-800-465-2422.
 

Step 2: Call 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: 1-800-465-2255
Fax: 1-877-861-7801
Email: client.care@cibc.com
Write to: CIBC Client Care
PO Box 15, Station A 
Toronto, ON
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: 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: 1-800-308-6859 or 416-861-3313 in Toronto
Fax: 1-800-308-6861 or 416-980-3754 in Toronto
Email: ombudsman@cibc.com
Write to: CIBC Ombudsman
P.O. Box 342
Commerce Court
Toronto, ON
M5L 1G2
 

Step 4 – Escalate

If you are not satisfied with the decision of the CIBC Ombudsman, you can ask how your matter can be further escalated.

If the above steps fail to resolve your concern you may also contact the applicable privacy commissioner.


How to contact us


If you

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

You should

Contact the 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.
 

If you

Do not wish to receive marketing communications from CIBC:

You should

Contact the 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. We will then update your file as quickly as possible. It may take some time for our records to reflect your choice as many records can only be changed during regular file updates and your choice may not be captured for a promotion already in progress.

 

If you

Do not wish us to use your SIN as an aid to identify you in credit bureau requests:

You should

Contact the banking centre or office where your account is held or talk to your CIBC representative.

 

If you

Want access to the personal information we hold about you:

You should

Contact the 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 that you provide us with enough specific details, in order 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. If you have a sensory disability you may request your information to be made available in an alternative format. There may be limits on your right to access your information.

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 wish to 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 they 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.
 

If you

Want written or more details about our privacy policy and practices (including with respect to service providers outside of Canada):

You should

Refer to our CIBC Privacy Principles, Online Privacy Statement, or Privacy FAQ or see the “Addressing Any Privacy Concerns” section above.

For additional information on client privacy
talk to a CIBC representative
visit your nearest banking centre
call 1-800-465-2422


Additional Contact Information