Effective date: September 5, 2019
Online Privacy Practices
These Online Privacy Practices only relate to the information we collect online, including through the use of our mobile application. See below for our general privacy notice applicable to consumers as required by federal law. How we handle information about you when you visit our website will depend on what you do when visiting comerica.com and other websites owned by Comerica Bank.
Customer information
Solely Visiting Our Website
If you visit our website to solely read information and do not use any of our online services (offered to non-customers and/or customers), then we collect and store only the name of the domain from which you access the Internet, the date and time you access our website, Internet address of the website from which you linked directly to our website and your zip code. We may record the “IP address” assigned to you by your internet service provider as part of this process. We use the information we collect to measure the number of visitors to different sections of our
Using Our Services
We recommend that when you complete your online transactions to log off completely before visiting other sites and/or restart your personal computer. This may clear your cookies (see “Cookies” discussion below). We also recommend that you do not visit other sites during your online banking session with us.
When you visit our website and use our website or our mobile application to engage in account opening or electronic banking services (e.g. Comerica Web Banking®), then there may be times when you are asked to provide information about you that is personally identifiable (“Personal Information”). This may include the following:
Personal
- your first, middle and last name,
- your zip code, home or other physical address (including the street name and name of a city or town),
- your e-mail address,
- a telephone number,
- social security number,
- account number,
- date of birth,
- mother’s maiden name,
- password or any other identifier that permits physical or online contact with you,
- geolocation, and
- biometric information, including for example your voice print, fingerprint, or facial geometry scan.
Financial
- Average Account Balance,
- Household Income,
- Federal Income
Tax Bracket, Mont hly Debt, Monthly Rent, and Ava ilable Down Payment Amount.
- Account Preferences,
- Needs for Savings,
- Challenge/Security Questions,
- User IDs, and
- Passwords.
Cookies, Web
As mentioned above, we collect information from your online visits to our website and your use of our online banking services to help gather statistics about usage and effectiveness, personalize your experiences and tailor our interactions with you. We do so through the use of various technologies, including the use of cookies, web
Definitions
- Cookies. A “cookie” is generally a small piece of data sent from a website and stored in a user’s web browser while the user is browsing the internet. A “session cookie” is a cookie that exists in temporary memory only while the user is reading and navigating a particular website. A session cookie is typically deleted when the user closes his or her browser. A “persistent cookie” is a cookie that generally outlasts the user’s current online session and may be sent back to the server every time the user visits the same website. Persistent cookies are commonly referred to as “tracking cookies” since the user’s activity on a particular website may be tracked over time.
- Web Beacons. A “web beacon” is an object that is embedded in a web page or e-mail and is usually invisible to the user but allows checking that a user has viewed the page or e-mail. It is basically a technique to track who is reading a web page or e-mail. Web beacons, also called “web bugs” are often invisible to the user because they may be very small (only 1-by-1 pixel) and/or are made to blend in with the background color of the webpage, document, or e-mail message. Web bugs are identified with HTML IMG tags in the
webpage .
Use of Cookies
You may choose to set your browser to reject cookies. However, we do not recommend disabling cookies on our website because you may not be able to log in or use basic features on our website such as Comerica Web Banking®. For more information see the "Help" information for the browser you are using. If you do not wish to have cookies placed on your computer, you should set your internet browser to refuse cookies before accessing our site, with the understanding that certain features of the site may not function properly without the aid of cookies. If you refuse cookies, you assume all responsibility for any resulting loss of functionality. Please see the heading “Our Response to Web Browser Do Not Track and Other Similar Mechanisms” below for further information.
Use of Web Beacons
With the assistance of a cookie, web bugs may collect the IP address of your computer, the URL of the page the web bugs comes from and the time it was viewed, or other personal information. For example, web bugs may add information to a personal profile of what sites a person is visiting and to determine what banner ads to display based on the profile. Another use of web bugs is to provide an independent accounting of how many people have visited a particular website and to gather statistics about web browser usage at different places on the Internet. You may use the "view profiles" of the webpage you are viewing on our website to see whether the page is using a web bug.
Use of Biometric Technologies
We may collect biometric information from you in order to assist us with validating the security of your account and authenticating you as a customer, both during online use of our services and when calling our customer service offices. You will have the option to provide certain biometric data using our proprietary systems or through protocols provided by our third party vendors (for example, we may capture your facial geometry by having you take a selfie from your mobile device when you open an account).
Comerica Bank does not sell your biometric information to any third parties. We may provide your biometric information to our third party vendors solely to the extent necessary to enable us to provide you with our services and to use your biometric data in connection with the purpose for which it was gathered (customer authentication or verification). We will maintain agreements with any such vendor we use which comply with our obligations in these Online Privacy Practices.
We will store your biometric information on our systems or those operated by a vendor on our behalf, consistent with our security commitments. Biometric information used to authenticate your identity in the online account opening process will be retained for 7 days after authentication. Voiceprints will be retained for as long as you remain enrolled in the associated service. Following the termination of your account or your un-enrollment from the associated services your voiceprint biometric information will be permanently deleted. You will need to re-enroll (and provide your voiceprint to Comerica Bank again) in order to utilize any of the services which rely on your voiceprint.
By enrolling in the use of any of our offered biometric authentication or verification programs (for example relying on selfie identification or voice print recognition), you acknowledge and consent to the use of your biometric information as described in these Online Privacy Practices.
Use of Other Technologies
Comerica Bank may use other
Our website may include advertisements for third parties and their products, and those third-party advertisements and websites may include a cookie, web bugs, or
If you visit our website or engage in any online service that we offer, then we may collect and store the categories of Personal Information. We will not share the Personal Information you provide us at our website with a third party, except as described below under the heading “Categories of Third Parties with Whom Comerica Bank May Share Information.”
Our Response to Web Browser
You may set your web browser to disable the ability for one or more websites to track your usage. For example, as stated above under the heading “Use of Cookies,” you may choose to set your browser to reject cookies. We will respect any disabled cookies as a do not track mechanism that provides you a choice regarding the collection of Personal Information when you visit or conduct online activity on our websites regardless of whether your
Other Parties May Collect Personal Information
Other parties that may collect personal information about you when you use one or more of our websites once or over time are generally limited to service providers with whom Comerica Bank may share in order to administer, process or service the product or service you are using online.
Categories of Third Parties with Whom Comerica Bank May Share Information
Presently, Comerica Bank discloses Personal Information to third-party persons about our customers or former customers only as permitted by law in connection with the administration, processing or servicing of accounts.
We will not share your personally identifiable information with third parties and our marketing partners except as permitted by law to those third party persons or entities that perform services for us on your behalf. This may also include disclosure to protect against fraud, or as part of an audit or examination; and disclosure to protect and defend our rights and property or to act in an emergency or to protect someone’s safety.
As we develop our business, we may also buy and sell assets, and your Personal Information may be one of the transferred assets. In the event that we are acquired by another company, your personal identifiable information may be part of the assets transferred to the acquiring party.
Please be aware that other services, provided by other companies via links to their website from Comerica’s website, are not subject to these Online Privacy Practices. We encourage you to review third party service providers’ privacy policies before sharing your Personal Information.
Process to Request Changes to Personal Information
We wish to maintain complete and accurate information about you and your account (including information you have entered through any Comerica Bank website). We have established procedures to assist you should you ever believe that our records contain inaccurate or incomplete information about you. Please contact us to complete or correct your Personal Information. We will investigate your concerns and properly correct any inaccuracies.
Security Standards
We safeguard any information our customers share with us, according to strict standards of security and confidentiality. View detailed security information at your convenience (See Security link below).
Children’s Privacy Online
We do not knowingly solicit, collect, or use personal information from children under 13. For information concerning the Children's Online Privacy Protection Act (COPPA), visit the Federal Trade Commission's website at www.ftc.gov.
Changes to our Online Privacy Practices
We reserve the right to change our Online Privacy Practices. If we make updates to our Online Privacy Practices, we will update the Online Privacy Practices and revise the “Effective Date” at the top of these Online Privacy Practices. Any updates to our Online Privacy Practices become effective when we post the updates to our website. Your continued use of any portion of our website following the posting of the updated Online Privacy Practices will constitute your acceptance of the changes.
Acceptance of these Online Privacy Practices
Your use of one or more of our websites or our mobile applications, including disputes concerning privacy, is subject to these Online Privacy Practices and the Terms and Conditions of Use (see Terms and Conditions link below). By using our website, you are accepting the practices set out in these Online Privacy Practices and our Terms and Conditions of Use.
Comerica's Privacy Notice for Individuals
| FACTS | What Does Comerica Do With Your Personal Information? |
|---|---|
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include:
|
| How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Comerica chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does Comerica share? | Can you limit this sharing? |
|---|---|---|
For our everyday business purposes- such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
Yes | No |
For our marketing purposes- to offer our products and services to you |
Yes | No |
| For joint marketing with other financial companies | Yes | Yes (excludes private label credit card companies) |
For our affiliates’ everyday business purposes- information about your transactions and experiences |
Yes | No |
For our affiliates’ everyday business purposes- information about your creditworthiness |
Yes | Yes |
| For our affiliates to market to you | Yes | Yes |
| For nonaffiliates to market to you | No | We don't share |
| To limit our sharing |
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. |
|---|---|
| Questions? | Call 800.266.3742 |
| Who we are | |
|---|---|
| Who is providing this notice? | Comerica Bank, Comerica Bank & Trust, National Association, Comerica Securities, Inc., Comerica Insurance Services, Inc., Comerica Insurance Services of Texas Incorporated, Interstate Select Insurance Services, Inc., and World Asset Management, Inc. |
| What we do | |
|---|---|
| How does Comerica protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does Comerica collect my personal information? | We collect your personal information, for example, when you
|
| Why can’t I limit all sharing? | Federal law gives you the right to limit only
|
| What happens when I limit sharing for an account I hold jointly with someone else? | Comerica does not limit sharing by account but rather by |
| Definitions | |
|---|---|
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies.
|
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies.
|
| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
|

