Wealthswise || Privacy Policy

This Privacy Policy was last updated on September 1, 2022.

Your privacy is protected

Thank you for choosing Wealthswise to provide your financial services. We value the trust you place in us. At Wealthswise, we are committed to giving you the best possible service whenever and however you bank with us, while protecting your privacy.
To ensure we meet our commitment to you, Wealthswise has appointed our Chief Privacy Officer as being responsible for overseeing our privacy practices and our efforts to comply with applicable privacy law and to manage and mitigate privacy risk.

As we build an enduring relationship with you to help make your ambitions reality, our privacy policy explains what you can expect from us. 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.

1 Important Terms

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 Wealthswise Digital Channels, such as device model, browser type and IP address.
“Wealthswise”, “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.
“Wealthswise Digital Channels” means our websites, mobile apps, social media accounts, virtual assistant, chatbot and other digital channels.
“Wealthswise Foreign Affiliates” means Wealthswise’s businesses, affiliates, subsidiaries and branches of Wealthswise located outside of Canada, such as Wealthswise Bank USA.
“Program partners” means companies we have carefully selected to provide benefits, products or services under, or to participate in, a Wealthswise partner program.
“Wealthswise partner program” means a program under which Wealthswise 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 Wealthswise.

4. What information We Collect?

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 Wealthswise 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 Wealthswise 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 Wealthswise 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 Wealthswise 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.

5. Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared. You can manage Adobe’s LSOs through their Website Storage Settings panel.
To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
To update data you provide directly, log into your account and update your account at any time.

6. Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not use the Services. If we learn that we’ve collected personal data from a child under those ages.