Coigne Capital Inc. – Privacy Policy
Effective Date: 4 June 2024
Site Covered: coignecapital.ca
1. Purpose and Scope
This Privacy Policy explains how Coigne Capital Inc. (“Coigne Capital,” “we,” “us,” “our”) collects, uses, discloses, protects, and retains personal information obtained through our website and all digital channels that link to this Policy (collectively, the “Site”). It applies to visitors, prospects, and clients who interact with our Site or submit information to us in Québec and elsewhere in Canada.
The Policy is drafted in accordance with:
Québec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25)
Personal Information Protection and Electronic Documents Act (PIPEDA)
Autorité des marchés financiers (AMF) rules for firms registered under the Insurers Act and the Securities Act
2. Our Commitment
No Sale or Commercial Disclosure: Coigne Capital does not sell, rent, trade, or otherwise disclose client or prospect information to third parties for marketing or commercial purposes.
Limited Sharing: Information is shared only to (i) satisfy regulatory or legal obligations, (ii) deliver the services you request through duly-licensed partners, or (iii) complete a business transaction in which equivalent privacy safeguards are imposed.
3. What We Collect
| Category | Examples | Collection Method | Legal Basis* |
|---|---|---|---|
| Identification & Contact | Name, address, email, phone, date of birth | Web forms, secure portals, phone or video meetings | Consent / contractual necessity |
| Regulatory Know-Your-Client (KYC) | Financial goals, risk tolerance, employment, income, asset details | Secure uploads, advisor interviews | Legal obligation (AMF) |
| Website & Device Data | IP address, browser type, pages viewed, clicks | Cookies, analytics tags | Legitimate interest (site security & improvement) |
* We rely on express consent for any purpose that is not required by law or contract.
4. How We Use Your Information
Client On-Boarding & Advice – Verifying identity, assessing suitability, generating proposals, and maintaining your portfolio file.
Regulatory Compliance – Satisfying obligations under AMF regulations, anti-money-laundering (FINTRAC), and tax reporting.
Site Operation & Analytics – Operating, auditing, and improving website performance.
Communications – Responding to inquiries, sending statements, newsletters, or mandatory notices. You may withdraw marketing consent at any time.
Risk Management & Fraud Prevention – Protecting you and our firm against unauthorized activity.
5. Cookies & Tracking Technologies
We use functional and analytics cookies to remember preferences and understand aggregate traffic patterns. You can adjust browser settings to refuse or delete cookies; essential features may be affected.
6. Financial Calculator Tools – Important Notice
The calculators hosted on our Site are illustrative only. Results depend on user-supplied assumptions that may not reflect future market conditions, tax rules, or your personal situation. They do not constitute financial, investment, or legal advice, and Coigne Capital accepts no liability for decisions taken based on calculator outputs. Always consult a licensed advisor before acting.
7. Disclosure to Third Parties
We disclose personal information solely:
Regulators & Legal Authorities – When demanded by AMF, FINTRAC, Revenu Québec, or courts.
Service Providers – Cloud hosting, data back-up, or payment processors that sign confidentiality agreements and implement security controls comparable to ours.
Business Transfers – If Coigne Capital is involved in a merger or acquisition, provided the acquiring entity safeguards the information to at least the same standard.
8. International Transfers
Where service providers operate outside Québec or Canada, information may be processed in that jurisdiction. We perform privacy impact assessments and require contractual clauses guaranteeing protection equivalent to Québec’s Law 25.
9. Retention & Destruction
Personal information is retained for the longer of three (3) years after last activity or the period required by AMF, tax, and anti-money-laundering statutes (often 7 years). Data is then securely destroyed or anonymized.
10. Security Measures
Encryption in transit and at rest for client documents and portal sessions
Tier-IV Canadian data centres with 24/7 monitoring
Role-based access controls; staff and agents are bound by confidentiality undertakings
Incident Response Plan consistent with Law 25 breach-notification rules; affected individuals and the Commission d’accès à l’information du Québec (CAI) will be notified promptly of any material breach.
11. Rights of Individuals
Under PIPEDA and Law 25 you may exercise the following at any time:
| Right | What It Means | How to Exercise |
|---|---|---|
| Access | Obtain a copy of the personal information we hold about you. | Contact our Privacy Officer (see Section 13). |
| Rectification | Correct inaccurate or incomplete data. | Same as above. |
| Withdrawal of Consent | Stop non-essential processing (e.g., marketing). | Click “unsubscribe” links or email us. |
| Erasure* | Request deletion when data is no longer required. | Email Privacy Officer; statutory retention limits apply. |
| Data Portability | Receive your data in a structured, machine-readable format. | Written request to Privacy Officer. |
* We may decline erasure where records must be kept to meet legal or regulatory retention periods.
12. Minors
The Site is intended for persons 18 years or older. We do not knowingly collect data from children under 13. Parents who believe a minor has provided information should contact us for prompt deletion.
13. Contact & Questions
Privacy Officer
Sergio Paier
3773 boul. Côte-Vertu, Suite 460
Saint-Laurent, QC H4R 2M3
Toll-Free 1-888-333-0398
📧 [email protected]
14. Changes to This Policy
We may update this Policy to reflect legislative or operational changes. The “Effective Date” will be revised accordingly and a notice posted on our Site. Continued use after an update signifies acceptance of the revised terms.
By accessing or using the Site, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.
