Information Disclaimer

Information on this site is for informational purposes only, and is not intended to provide financial, investment, legal, account, tax, or other advice and should not be relied upon in that regard. You should consult with an investment professional or advisor.

The Website if made available “as-is” and “as available” basis. CCM does not guarantee the site will be uninterrupted.

None of CCM’s officers, directors, or employees makes any express or implied warranties about the website, and shall not be responsible to any person for any direct, indirect, special, incidental, or consequential damages, or any other damages arising out of the use or reliance on the website.

Client Portal Access

The client portal provides portfolio information and reporting to clients. Access to the client portal is only available upon request, and will require a login and password. You can request a login and password from your investment manager.

The client is solely responsible for your login and password. As with any login and password, you must take the necessary precautions to protect it. Please contact us as soon as possible if you discover that your login and your password have been stolen or fraudulently used. You are responsible for any fraud or liability arising from the use of your login and your password.

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.

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.

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.

Requesting your personal information

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: