1) Introduction
Coigne Capital Partners ("Coigne Capital," "we," "us," or "our") is committed to protecting the privacy and confidentiality of personal information entrusted to us. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website, engage with our services, or communicate with us.
This policy applies to all visitors, prospective clients, existing clients, and other individuals whose personal information we may process. By using our website or engaging our services, you consent to the practices described in this policy.
2) Information We Collect
- Contact Information: name, email, phone, mailing address, and organization.
- Professional Information: job title, business affiliation, industry, and background.
- Financial Information: where required for onboarding, KYC/KYB compliance, or suitability, including source of funds, source of wealth, and investment experience (secure channels only).
- Technical Information: IP address, browser, device, operating system, referring URLs, and browsing behavior.
- Communication Records: correspondence, inquiries, consultation notes, and records of interactions.
- Cookie and Tracking Data: information collected through cookies and similar technologies.
3) How We Use Your Information
- Respond to inquiries and facilitate initial consultations.
- Provide advisory, structuring, and coordination services.
- Conduct KYC/KYB, identity verification, and regulatory compliance processes.
- Communicate about services, updates, and relevant developments.
- Improve our website, services, and user experience.
- Comply with legal and regulatory obligations, including AML and sanctions screening.
- Enforce our terms and protect our legal rights.
4) Legal Basis for Processing (GDPR)
- Consent — where you have provided explicit consent.
- Contractual Necessity — where processing is necessary to perform or prepare an engagement.
- Legal Obligation — where required by applicable law.
- Legitimate Interests — where necessary for our legitimate interests, balanced against your rights.
5) Cookies and Tracking Technologies
Our website uses essential cookies (core functionality), analytics cookies (anonymized usage data), and preference cookies (e.g., language). We do not use advertising or third-party marketing cookies. You may manage cookie preferences through your browser. We respect Do Not Track signals where technically feasible.
6) Data Sharing and Disclosure
- Regulated partners involved in service delivery.
- Professional advisors within our vetted network, as required to fulfill engagements.
- Service providers supporting our website and operations, under appropriate data processing agreements.
- Regulatory authorities where required by law, regulation, or court order.
- Synexum Labs — a Coigne Capital company — for operational execution and reporting.
7) PIPEDA Compliance (Canada)
We adhere to the ten PIPEDA principles: accountability, identifying purposes, consent, limiting collection, limiting use and retention, accuracy, safeguards, openness, individual access, and challenging compliance.
8) GDPR Rights (EEA / UK)
- Right of access, rectification, erasure, restriction, portability, objection, and withdrawal of consent.
9) International Data Transfers
As an internationally active advisory platform, personal information may be transferred to jurisdictions outside your country of residence. We rely on standard contractual clauses, adequacy assessments, and contractual data protection obligations with partners and service providers.
10) Data Security
We use encryption in transit and at rest, access controls, secure communication channels for sensitive documents, and controlled data room processes. No transmission or storage method is fully secure; we cannot guarantee absolute security.
11) Data Retention
We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. When no longer required, it is securely destroyed or anonymized.
12) Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect personal information from children.
13) Third-Party Links
Our website may contain links to third-party sites. We are not responsible for their privacy practices; please review their policies.
14) Changes to This Privacy Policy
We may update this policy periodically. The "Last updated" date indicates the most recent revision. Material changes will be communicated through our website or by direct notification.
15) Contact Us
For privacy inquiries: Coigne Capital Partners — info@coignecapital.ca. For PIPEDA matters you may contact the Office of the Privacy Commissioner of Canada; for GDPR matters, your local supervisory authority.
