Corporate Policies
Privacy Policy Statement
Coerente Capital Management is committed to protecting the privacy and confidentiality of our clients’ information. CCM needs to collect private information from our clients in order to fulfill our investment management duties and complying with any legislation.
Having complete information allows us to ensure we meet our clients’ investment goals and objectives, as well as making certain our investment choices are suitable to each client’s unique situation. The statement below details how Coerente Capital Management performs this duty, as well as how we protect your personal information and privacy.
What information we collect
Information that we collect in our role as investment manager are items like (but not limited to): your name, address, date of birth, citizenship, residency, marital status, financial situation, risk tolerance, income needs, political exposure, social insurance number, articles of incorporation, insider status, current asset holdings, outstanding debts, and contact information.
We ask this information through our KYC, Risk Assessment forms, and through meetings and phone conversations.
Unless you otherwise advise, by providing us with your personal information you have consented to our collection, use and disclosure of the information.
Why we collect it
CCM does not ask for any information that does not exclusively pertain to fulfilling our investment management duties and our regulatory requirements.
The collected information enables us to make informed investment decisions to help us perform our investment management duty to you, and to ensure suitability of the investment choices we make on your behalf.
Additionally the information is used to complete any data needs for account opening/maintenance at the custodian, carrying out any specific type of transaction such as a corporate action on a holding or class action claim, or adhering to any legislative requirements.
How we protect it
CCM takes your privacy and personal information seriously. CCM implements several layers of protection to ensure your information remains private and secure.
At CCM our first layer of protection is through our people. All of our employees are responsible for maintaining the confidentiality of all the personal information that they may have access to. As a condition of their employment at CCM, each employee signs a confidentiality agreement each year to ensure they are as up to date as possible to their personal responsibilities to our clients and their information.
On a regular basis each employee reviews our Policy and Procedures and are kept up to date with compliance policy changes as they occur.
We store your personal information in both physical and electronic formats.
Physical files are locked during non-business hours as well as access to the office is limited. Access to physical files are restricted to employees who need access to fulfill CCM’s duties as investment manager to you.
Electronic files are also limited to users who need to have access for specific purposes. We have in-place various hardware and software solutions to protect and monitor our data from outside intrusion, and any data stored offsite is in a secure location. We have all of our data backed up multiple times per day. Any physical hardware is stored in a locked location outside of business hours.
Keeping your information up-to-date
CCM’s ability to provide investment management services suited to your unique needs and goals is limited by the accuracy of the data that we have collected from you.
Any life changing events, changes in financial goals, or any other changes in collected information should be relayed to your investment manager so that we can keep your portfolios consistent with your investment goals and needs.
Additionally, you have the right to correct any data you feel is incorrect that we may have and we encourage you to provide us with the most accurate information whenever available or as is occurs.
Retention and disposal of your personal information
We store your personal data for as long as it is useful to perform our duties as investment managers, or as is required by law.
Any physical records are destroyed through a private shredding service that is done on-site.
All electronic media is destroyed through a private disposal service that provides verification services of its destruction.
Any other computer equipment is destroyed so that no information can ever be obtain from it prior to its disposal.
Your personal information – Rights and Requests
Right to withdrawal consent:
Your personal information belongs only to you. During your interactions with CCM you provide us with information so that we can fulfill our portfolio manager relationship with you. At any given time you may withdraw this consent, but it will potentially limit or even restrict our ability to perform our duties under the relationship that you entered into with CCM.
Right to refuse sharing personal information with 3rd parties:
CCM does not share your personal information with any 3rd parties, with the exception of your custodian (that you have a direct relationship with), brokers, power of attorney, and any governmental body upon their requestion.
You are able to withdrawal your consent as well for sharing information with our 3rd parties as well, but it may affect our ability to service you as portfolio managers.
Right to access your information:
You have the right to access the information that we have regarding you. To access this information, you can contact your portfolio manager and make a request, and we will provide you the information in a timely manner.
CCM has designated the Chief Compliance officer (Marc Trottier) as Privacy Officer. The Privacy Officer is responsible for employee training in our privacy policies and for monitoring the fulfillment of our privacy commitments.
Should you have any general questions or concerns we would ask for you to contact him directly at 514-360-7940.
A client wishing to review his or her personal information in our possession should send a written request addressed to Coerente Capital Management Privacy Officer at the address below:
Coerente Capital Management Privacy Officer
630 boul. René-Lévesque West
Suite 2860
Montréal, Québec
H3B 1S6