Coigne Capital Inc. – Privacy Policy
Effective Date: 4 June 2024
Last Reviewed: 6 July 2025

Site Covered: coignecapital.ca and all related sub-domains (collectively, the “Site”)

1. Purpose & Scope

This Privacy Policy explains how Coigne Capital Inc. (“Coigne Capital,” “we,” “us,” “our”) collects, uses, discloses, protects, and retains personal information obtained through the Site and any other digital channel that links to this Policy. It applies to all visitors, prospects, and clients who interact with us in Québec and elsewhere in Canada.

This Policy is drafted in accordance with:

• Québec’s Act Respecting the Protection of Personal Information in the Private Sector (as modernised by Law 25);
• Personal Information Protection and Electronic Documents Act (PIPEDA); and
• Relevant rules and guidance issued by the Autorité des marchés financiers (AMF) for firms registered under the Insurers Act and the Securities Act.

2. Our Commitment

• No Sale or Commercial Disclosure. We do not sell, rent, trade, or otherwise disclose personal information for marketing or commercial purposes.
• Limited Sharing. We share information only when necessary to:
  1. meet regulatory or legal obligations;
  2. deliver the services you request through duly-licensed partners (e.g., Global Maxfin Investments Inc. for mutual-fund and exempt-market products); or
  3. complete a business transaction in which equivalent privacy safeguards are imposed.

3. What We Collect

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 client file.
• Regulatory Compliance – Satisfying obligations under AMF rules, anti-money-laundering (FINTRAC), and tax reporting regimes.
• Site Operation & Analytics – Operating, auditing, and improving website performance and security.
• 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 unauthorised activity.

5. Cookies & Tracking Technologies

We use functional and analytics cookies to remember preferences and understand aggregate traffic patterns. Non-essential cookies (e.g., analytics, advertising) are deployed only after you provide explicit opt-in consent in compliance with Law 25. You can withdraw consent at any time via our Cookie Settings panel; essential Site features may be affected.

6. Financial Calculator Tools – Important Notice

The calculators hosted on our Site are illustrative only. Results depend on user-supplied inputs and 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 assumes no liability for decisions taken based on calculator outputs. Always consult a licensed advisor before acting.

7. Disclosure to Third Parties

8. International Transfers

Where a service provider processes data outside Québec or Canada, your information may be subject to the laws of that jurisdiction. We perform privacy-impact assessments and require contractual clauses guaranteeing protection equivalent to Québec’s Law 25 and PIPEDA.

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 seven (7) years). Thereafter, data is securely destroyed or irreversibly anonymised.

10. Security Measures & Email Disclaimer

Email & Electronic Communication.
Coigne Capital takes every commercially reasonable measure to secure electronic communications and uses reputable, encrypted email and portal technologies. Nevertheless, no method of transmission over the Internet or electronic storage is 100 % secure. Accordingly:

• Coigne Capital Inc., its principal Sergio Paier, and Global Maxfin Investments Inc. are not liable for any loss or damage arising from an unintended interception, alteration, or disclosure of email or electronic data, unless caused by our gross negligence or wilful misconduct.
• By communicating with us electronically, you acknowledge and accept these inherent risks.

11. Rights of Individuals

We may decline the erasure where records must be retained to meet legal or regulatory obligations.

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 so we can delete it promptly.

13. Contact & Questions

Privacy Officer
Sergio Paier
Coigne Capital Inc.
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 the Site. Continued use of the Site after an update signifies acceptance of the revised terms.

Acknowledgement

By accessing or using the Site, you confirm that you have read, understood, and agreed to the practices described in this Privacy Policy.

Disclaimer: Use of Financial Calculator Tools

The financial calculators on this Site are provided solely for informational and illustrative purposes. Calculations, projections, and estimates are based on user-provided inputs and assumptions, which may not reflect actual future performance, rates, or returns. They do not constitute financial, investment, or legal advice, nor do they guarantee any specific outcome.

Users acknowledge that these tools do not account for all factors that may affect an individual’s financial situation, including market fluctuations, legislative changes, or personal circumstances—and should therefore not be relied upon for investment decisions. Coigne Capital Inc. assumes no liability for errors, omissions, or actions taken based on calculator outputs.

In line with the guidelines of the Autorité des marchés financiers, Coigne Capital encourages all users to consult a licensed financial advisor—such as a representative of Coigne Capital or Global Maxfin Investments Inc.—before acting on any information produced by these tools.