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

1. Introduction

This Privacy Policy outlines 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 our Site, you agree to the terms of this Privacy Policy.

2. Contact Information

Coigne Capital Inc.
Email: info@coignecapital.ca
Toll-Free: (888) 333-0398
Address: 3773 boul. Côte-Vertu, Suite 460, Saint-Laurent, QC H4R 2M3

3. Purpose of this Privacy Policy

The purpose of this Privacy Policy is to inform users of our Site of the following:

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

This Privacy Policy applies in addition to our Site’s terms and conditions and complies with Canadian federal privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as Quebec’s privacy laws, including the Act Respecting the Protection of Personal Information in the Private Sector (Loi sur la protection des renseignements personnels dans le secteur privé).

4. Personal Data We Collect

We are committed to collecting only the data necessary to achieve the purposes outlined in this Privacy Policy. The types of personal data we may collect include:

Automatically Collected Data:

• IP Address
• Links clicked
• Content viewed
• Browser type and version
• Operating system

Data Collected When You Perform Certain Functions on Our Site:

• First and last name
• Date of birth
• Gender
• Email address
• Phone number
• Address
• Autofill data (if applicable)

Collection Methods:

• Website forms (e.g., contact forms, subscription forms)
• Cookies and similar tracking technologies

We will not collect additional data without providing notice and obtaining consent, where required.

5. How We Use Personal Data

We collect and use your personal data only for the purposes specified in this Privacy Policy or as disclosed on relevant pages of our Site. The data collected will be used for the following purposes:

Automatically Collected Data:

• Lead generation
• Client engagement
• Website statistics and analytics
• Enhancing user experience on our Site

Data Collected During User Interactions:

• Communication and professional advice
• Dissemination of monthly newsletters
• Provision of insurance quotes
• Advisor consultations and financial planning
• Compliance with regulatory requirements

6. Sharing and Disclosure of Personal Data

Internal Use:

Personal data may be disclosed to Coigne Capital Inc. employees and representatives who need access to fulfill the purposes outlined in this Privacy Policy. All employees are bound by strict confidentiality agreements.

Third-Party Disclosure:

We will not sell or share your data with any third party, except under the following circumstances:

• Legal Obligations: If required by law, regulatory authorities, or in connection with legal proceedings.
• Protection of Rights: To prove or protect our legal rights.
• Business Transactions: If the company is involved in a sale, merger, or acquisition, we may disclose user data to prospective buyers or parties involved, ensuring it is protected and used appropriately.

Please note that if you follow hyperlinks from our Site to another site, we are not responsible for and have no control over the privacy practices of those sites.

7. Data Retention

We will retain your personal data for a period of three years from the date of collection, or as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will notify you if your data is retained beyond this period and explain the reasons for the extension.

8. Data Security

We implement robust security measures to protect your personal data, including:

• Encryption: We use the strongest available browser encryption to safeguard your data.
• Secure Storage: Data is stored on secure servers located in Canada, in compliance with Canadian privacy laws.
• Access Controls: Only authorized employees and agents have access to personal data, and they are bound by confidentiality agreements.

While we take all reasonable precautions to protect your data, it is important to note that no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your personal data, we cannot guarantee its absolute security.

9. Minors and Privacy

The minimum age for using our Site is 18 years. We do not knowingly collect or use personal data from children under the age of 13. If we become aware that we have inadvertently collected personal data from a child under 13, we will delete that data immediately. Parents or guardians may contact our Privacy Officer to request the deletion of data if they believe it has been collected from a minor.

10. User Rights

You have the following rights regarding your personal data:

• Right to Access: You may request access to your personal data at any time to understand how it is being used and to whom it has been disclosed.
• Right to Rectification: If your data is inaccurate or incomplete, you have the right to request correction.
• Right to Erasure: You may request that we delete your personal data, subject to certain legal exceptions.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: Where applicable, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.

To exercise any of these rights, please contact our Privacy Officer:

Sergio Paier, Privacy Officer
Email: info@coignecapital.ca
Toll-Free: (888) 833-3039
Address: 3773 boul. Côte-Vertu, Suite 460, Saint-Laurent, QC H4R 2M3

11. Opting-Out of Data Collection, Use, or Disclosure

In addition to your rights outlined above, you may opt-out of specific forms of data collection, use, or disclosure:

• Marketing Communications: You may opt out of receiving marketing emails, mail campaigns, and promotional information by clicking “unsubscribe” at the bottom of any marketing email or by contacting us at info@coignecapital.ca.

12. Cookie Policy

Cookies are small text files placed on your device to collect data about your browsing habits. We use the following types of cookies on our Site:

• Functional Cookies: These cookies remember the selections you make on our Site so that your preferences are saved for future visits.
• Analytical Cookies: These cookies collect data about how you use our Site, such as which pages you visit and how long you spend on each page. This helps us improve our Site’s functionality.
• Targeting Cookies: These cookies collect data about your preferences and behavior, allowing us to tailor content and advertisements to your interests.
• Third-Party Cookies: We may use third-party cookies to monitor user preferences and display relevant advertisements.

Managing Cookies: You can choose to be notified each time a cookie is transmitted or disable cookies entirely through your browser settings. However, disabling cookies may affect your user experience on our Site.

13. Intellectual Property

All content published and made available on this Site, including images, text, logos, documents, downloadable files, and other materials, is the property of Coigne Capital Inc. and its creators. Unauthorized use of this content is prohibited.

14. Acceptable Use

As a user of our Site, you agree to use our Site lawfully and refrain from the following activities:

• Harassment or abuse of other users.
• Violation of other users’ rights.
• Hacking or unauthorized access to accounts.
• Fraudulent activity or posting inappropriate content.

15. Use of the Site

The information provided on our Site is for informational purposes only and should not be construed as financial advice. All financial products offered by Coigne Capital Inc. comply with the laws and regulations of the Autorité des Marchés Financiers (AMF) and other relevant financial institutions.

16. Certification

Coigne Capital Inc. is a financial services company approved by the Autorité des Marchés Financiers (AMF) with registration number 608528. The Firm acts as an intermediary or broker for financial and insurance services, working through QFS Qualified Financial Services for insurance products and WhiteHaven Securities for investment products.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices or legal requirements. When changes are made, we will update the “Effective Date” at the top of this Privacy Policy and notify users via email or a prominent notice on our Site. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

18. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact our Privacy Officer:

Sergio Paier, Privacy Officer
Email: info@coignecapital.ca
Toll-Free: (888) 833-3039
Address: 3773 boul. Côte-Vertu, Suite 460, Saint-Laurent, QC H4R 2M3

19. Compliance with Applicable Laws

This Privacy Policy is designed to comply with Canadian and Quebec privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Act Respecting the Protection of Personal Information in the Private Sector. Coigne Capital Inc. is committed to ensuring that all data collection, use, and disclosure practices adhere to these legal requirements.