Effective Date: June 4, 2024
Site: Coignecapital.ca
Site Type: Wealth Management and Financial Services Website

Introduction

This Privacy Policy and Terms & Conditions (“Policy”) outline how Coigne Capital Inc. (“we,” “us,” or “our”) collects, uses, discloses, and safeguards the personal data of users (“you,” “your”) who visit and interact with our website, Coignecapital.ca (the “Site”). By accessing or using the Site, you agree to this Policy.

Coigne Capital Inc. is a financial services company registered with the Autorité des marchés financiers (AMF) under registration number 608528 for Life Insurance and Insurance of Persons Products. Investment products are offered through licensed advisors in compliance with AMF guidelines. All financial and insurance product information on the Site is for informational purposes only and should not be construed as financial advice.

Financial recommendations and product offerings are made solely by duly licensed advisors, ensuring compliance with AMF regulations, PIPEDA, and Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Loi sur la protection des renseignements personnels dans le secteur privé).

Purpose of this Privacy Policy

This Privacy Policy is designed to inform users of the following:

• Personal data we collect
• How we use the data
• Who has access to the data
• Your rights regarding your data
• Our Site’s cookie policy
• How we protect your data

The Policy also ensures our compliance with Canadian federal privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Act Respecting the Protection of Personal Information in the Private Sector.

Personal Data We Collect

We collect only the personal data necessary to achieve the purposes outlined in this Policy. The data we collect includes:

• Automatically Collected Data: IP Address, links clicked, content viewed, browser type and version, operating system.
• User-Provided Data: First and last name, date of birth, gender, email address, phone number, and mailing address.
• Collection Methods: Data is collected via website forms (e.g., contact forms, subscription forms), cookies, and other tracking technologies.

We ensure data collection is transparent and will obtain explicit consent where required by law.

How We Use Personal Data

We collect and use your data solely for the purposes specified in this Policy or as disclosed on relevant pages of the Site. Personal data is used for:

• Automatically Collected Data: Lead generation, user engagement, website analytics, and improving user experience.
• User-Provided Data: Communication, provision of professional advice, financial planning, newsletters, insurance quotes, advisor consultations, and compliance with regulatory requirements.

Our processing methods ensure data is handled lawfully, fairly, and transparently, only used for the specified purposes, and retained only for the minimum period necessary to meet those purposes.

Sharing and Disclosure of Personal Data

We do not sell your data. Personal data is shared only under specific conditions:

• Legal Obligations: We may disclose data to meet legal requirements, including AMF directives regulatory obligations, and in connection with legal proceedings or investigations.
• Protection of Rights: To protect legal rights, enforce agreements, and prevent fraud or policy breaches.
• Business Transactions: We ensure data protection measures are in place in business transactions such as mergers or acquisitions.

Third-party service providers (e.g., data storage payment processors) may access personal data to provide services, with strict contractual obligations to maintain confidentiality and security.

Data Retention

We retain personal data for three years from the collection date or as long as required to fulfill the specified purposes, subject to legal or regulatory requirements. Users will be informed if an extended retention period and its legal basis are necessary.

Data Security

We implement rigorous security measures, including:

• Encryption: To protect data during transmission and at rest.
• Secure Storage: Personal data is stored on secure servers that are compliant with Canadian privacy laws.
• Access Controls: Access to personal data is restricted to authorized personnel bound by confidentiality obligations.

Although we strive for maximum security, no method of transmission over the Internet is entirely secure. We will promptly notify affected individuals and relevant authorities in case of a security breach.

Minors and Privacy

Users must be at least 18 years old to access our Site. We do not knowingly collect personal data from children under 13. If such data collection is detected, it will be promptly deleted. Parents or guardians may contact our Privacy Officer for deletion requests concerning minors.

User Rights

Under Quebec and Canadian privacy laws, you have the following rights:

• Right to Access: You can request access to your data at any time.
• Right to Rectification: Request corrections to inaccurate or incomplete data.
• Right to Erasure: Request deletion of your data, subject to legal exceptions.
• Right to Restriction of Processing: You may request data processing restrictions under certain conditions.
• Right to Data Portability: When applicable, request a copy of your data in a machine-readable format.

To exercise any of these rights, please get in touch with our Privacy Officer.

Opting Out of Data Collection

• Marketing Communications: Opt out by clicking “unsubscribe” in marketing emails or contacting [email protected].
• Cookies and Tracking Technologies: Manage or turn off cookies through your browser settings, though some functionality may be affected.

Cookie Policy

Our Site uses cookies to enhance user experience. Types of cookies include:

• Functional Cookies: To store preferences for future visits.
• Analytical Cookies: To improve site functionality and performance.
• Targeting Cookies: To personalize content and advertisements.

Manage or turn off cookies via your browser settings as desired.

Intellectual Property

All content on the Site, including text, images, logos, and documents, belongs to Coigne Capital Inc. Unauthorized use is strictly prohibited.

Acceptable Use

By using our Site, you agree to refrain from:

• Prohibited Activities: Unlawful activities, harassment, rights violations, hacking, fraud, or posting inappropriate content.

Violation may lead to restricted access or legal action.

Use of the Site

The information on our Site is for informational purposes only and should not be construed as financial advice. Coigne Capital Inc. works with licensed advisors through QFS Qualified Financial Services for insurance products and WhiteHaven Securities for investment products under AMF compliance.

Certification

Coigne Capital Inc. is registered with the Autorité des marchés financiers (AMF) under registration number 608528 and complies with all relevant laws and regulations governing financial and insurance services in Quebec and Canada.

Changes to this Privacy Policy

We may update this Privacy Policy as needed. The “Effective Date” will indicate changes, and users will be notified via email or on-site notice. We encourage regular Policy reviews.

Contact Information

For inquiries or requests regarding this Privacy Policy, please contact:

Compliance with Applicable Laws

This Policy complies with PIPEDA and Quebec’s privacy laws, specifically tailored for financial industries under AMF guidelines, ensuring all data collection, usage, and retention practices are legally sound and transparent.