This policy covers the collection, use, storage and disclosure of personal information about customers, future customers, suppliers, directors and employees. It is established in accordance with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Act respecting the protection of personal information in the private sector (Quebec).
“Personal information” is defined as any information that relates to a natural person and allows that person to be identified. In the course of its activities and in order to properly serve its customers, COTE 100 collects information from its customers and future customers, including name and contact information, date of birth, marital status, information on spouse and dependents, driver’s license number, passport number, social insurance number, annual income, value of total assets and other sensitive financial information. The sources of the information collected are manifold and may include, in particular, information gathered in:
COTE 100 file opening forms;
custodian account opening forms;
management agreements, investment policies and other forms;
telephone conversations, e-mail exchanges and face-to-face meetings.
Also, in the normal course of business, COTE 100 may, from time to time, collect certain personal information on its employees or on candidates for employment, in particular to verify certain information required for the position to be filled or, subsequently, for company management purposes.
COTE 100 has designated the Chief Compliance Officer as its Privacy Officer.
Any customer or employee of COTE 100 shall be informed of and consent to any collection, use or disclosure of his or her personal information (except where inappropriate) after being informed of the purpose of the collection. Consent is given verbally at the time of collection for specific file analysis purposes. Subsequently, consent is given in writing when COTE 100 file opening documents are signed. The person concerned may withdraw this consent.
Once collected, information must remain protected at all times. In this regard, information is kept in a safe place, protected from unauthorized access and retained only as long as necessary. COTE 100 is responsible for the personal information it entrusts to third parties for processing (within the limits of the consent obtained). COTE 100 must therefore provide a comparable level of protection to information processed by a third party. Access to files is restricted to employees who need to know this information in the performance of their duties. Personal information is stored in accordance with COTE 100’s policy on data archiving and retention, and in compliance with applicable regulations.
Personal information collected from customers will be used solely for the purpose of opening an account (mainly to identify and get to know the customer, to determine the customer’s investor profile and, in particular, the customer’s status as an insider of certain issuers, and to assess the suitability of investments). The information requested is also necessary to comply with applicable regulations (in particular, securities regulations and regulations to combat money laundering and the financing of terrorist activities). Finally, personal information may also be required to enable the possible transfer of assets from another financial institution.
Some personal information may also be collected on COTE 100 employees and will be used in the context of the employment contract between COTE 100 and its employees. COTE 100 communicates confidential information only to external parties necessary for the performance of its activities (for example, regulatory authorities and service providers such as trustees, portfolio management systems, market intermediaries, etc.).
COTE 100 takes reasonable steps to ensure the accuracy of personal information and subsequent updates.
Customers may access their personal information at any time to review its content and accuracy. In order to exercise this right, the customer is asked to provide a request in writing, to allow for a complete search by COTE 100. COTE 100 will respond to written requests within 30 days and may provide copies of relevant documents where appropriate (COTE 100 will retain the originals in its possession).
In the event that COTE 100 suffers a data breach, the Firm will be subject to a number of obligations, namely:
determine whether the breach presents a “real risk of serious harm” to any individual whose personal information was the subject of the breach (“data subjects”) by conducting a risk assessment that takes into account the sensitivity of the information and the likelihood of misuse;
as soon as possible, notify individuals of any breach that it believes poses a real risk of serious harm to them, and report the breach to the Privacy Commissioner of Canada (the Commissioner);
notify any other organization that may be able to mitigate the risk of harm to the individuals;
keep a record of any data breach of which the organization is aware and provide it to the Commissioner upon request.
Any complaint relating specifically to the protection of personal information must be made in writing and sent to:
COTE 100 Inc.
Att: Catherine Lussier
Chief Compliance Officer and Privacy Officer
1543, rue Montarville
Saint-Bruno, QC J3V 3T8
COTE 100 shall make readily available to individuals its policies and practices relating to the management of personal information. As such, a copy of this policy is added to the company’s website.
Updated: April 2025
