Section 01Who this notice applies to.
This notice applies to Cohen Capital Markets LLC (referred to here as "we," "the firm," or "CCM"), a boutique financial advisory firm headquartered at 99 Wall Street, New York, NY 10005. It governs how we handle information about prospective clients who submit confidential inquiries, current clients in active engagements, former clients with whom we maintain a relationship, counterparties and their advisors with whom we interact in the course of engagements, visitors to this website, and other individuals whose information reaches us in the ordinary course of the firm's work.
The notice does not apply to third-party websites we link to, to social-media platforms where we maintain a presence, or to broker-dealer partners that handle securities transactions referred from CCM engagements. Those third parties operate under their own privacy practices and policies.
Section 02Information we collect.
Information you provide.
When you submit a confidential inquiry through this site, request a meeting, engage the firm under an engagement letter, or correspond with us, you provide information that may include your name, role, organization, contact details, and a description of the matter you wish to discuss. In active engagements, you may share substantially more — financial information, business plans, board materials, and other confidential information necessary for the work.
Information generated through our work.
In the course of an engagement, the firm generates analytical work product, correspondence, and internal records that necessarily reflect information about the client, counterparties, and the transaction or matter. This work product is treated as confidential firm work product subject to engagement-letter terms.
Information from third parties.
We may receive information from third parties in connection with engagements — for example, from counsel coordinating on a transaction, from data providers used to validate market information, from references provided by prospective clients, or from public filings and recognized institutional research.
Technical information about your visit.
When you visit this website we may collect technical information automatically — IP address, browser type, pages viewed, referring URL, and timestamps. We use this information for site operation, security monitoring, and aggregate analytics. We do not use this technical information to build a behavioral profile or to target you on third-party platforms.
Section 03How we use information.
We use information for a defined set of purposes consistent with the firm's role as an advisory practice:
- To evaluate and respond to inquiries. When you submit a confidential inquiry, we use the information you provide to assess the matter and to determine whether the firm is positioned to help.
- To deliver engagements. In active engagements, we use information to perform the work the engagement letter contemplates and to communicate with the client and any counterparties or counsel.
- To meet regulatory and recordkeeping obligations. The firm maintains engagement records consistent with the standards expected of a financial advisory practice operating in New York.
- To run the firm. Information supports internal administration — billing under engagement letters, conflict checking on new mandates, training, and quality review.
- To protect the firm and its clients. We use information to detect and prevent fraud, to enforce engagement-letter terms, and to defend ourselves in any actual or threatened legal proceeding.
Section 04How we share information.
The firm does not sell information about clients, inquirers, or counterparties. We do not share information for unrelated marketing purposes. We share information only for purposes connected to the firm's work, including:
- With your authorization. In an active engagement, we share information with the parties you have authorized us to engage with — typically counsel, counterparties, lenders, accountants, and other professional advisors necessary to the transaction or matter.
- With professional advisors we engage. The firm may retain accountants, lawyers, technology providers, and other specialists in support of an engagement. Those advisors are subject to confidentiality obligations consistent with the engagement.
- With broker-dealer partners on referred matters. See Section 05.
- With regulators and authorities. We share information when required by law, by subpoena, or by other legal process, and when reasonably necessary to cooperate with regulatory inquiries.
- In connection with a transaction involving the firm. Information may be shared with potential acquirers, financing parties, or successors in interest in connection with a corporate transaction involving Cohen Capital Markets, subject to confidentiality protections.
Section 05The broker-dealer referral.
This section is material. Cohen Capital Markets LLC is not a registered broker-dealer and does not provide securities brokerage services, investment advisory services, tax advice, or legal advice. Where applicable, securities transactions are offered through a FINRA/SIPC-registered broker-dealer partner; Cohen Capital Markets and the partner are separate, unaffiliated entities.
When an engagement surfaces a need for securities execution, the matter is referred to the unaffiliated broker-dealer partner. In connection with such a referral, we may share information with the partner that is reasonably necessary for the partner to evaluate the matter, conduct its own KYC and onboarding, and (if it accepts the matter) execute the transaction. The partner operates under its own privacy and information-security practices once it has accepted a matter.
Section 06How we protect information.
The firm operates with the information-security discipline expected of a confidential advisory practice. The principal elements are technical — encryption in transit and at rest for engagement information; access controls aligned to the principle of least privilege; protected document repositories for engagement work product; multi-factor authentication on systems holding client information; vendor due diligence on technology providers we engage. The principal elements are also operational — confidentiality obligations binding on every member of the firm and on every advisor we retain; clean-desk and discretion expectations in the firm's working environment; conflict-clearance discipline at the outset of every engagement.
No system is invulnerable. The firm responds to information-security incidents in accordance with applicable law and the standards of the practice. We notify clients and inquirers of material incidents as required and as appropriate.
Section 07How long we keep records.
We retain information for as long as necessary to deliver the engagement, to meet regulatory and recordkeeping expectations, to resolve disputes, to enforce engagement-letter terms, and to maintain firm records consistent with the standards of the practice. Retention periods vary by the type of information and the purpose for which it was collected. As a general matter, engagement records are retained for a period of at least seven years following engagement close, and longer where regulation or the nature of the engagement requires.
Inquiry information that does not result in an engagement is retained for a shorter period sufficient for the firm to maintain conflict-clearance integrity and to respond to any future inquiry from the same person or organization.
Section 08Cookies and analytics.
This website uses a minimal set of first-party cookies and adjacent technologies necessary for the site to function and for the firm to monitor aggregate site usage. We do not use third-party advertising cookies. We do not participate in cross-site tracking or behavioral advertising. We do not maintain a marketing-automation profile of site visitors.
If we use a privacy-respecting analytics tool (a single, cookieless or first-party analytics layer), we use it to understand which pages of the site are most useful to readers and to identify technical issues. We do not use that information to target individuals.
Section 09Cross-border data.
The firm operates from New York and is engaged with clients, counterparties, and counsel across North America, Europe, Asia-Pacific, and the Middle East. As a result, information that reaches the firm may be processed in or transferred across multiple jurisdictions, including jurisdictions whose data-protection regimes differ from the originating jurisdiction. The firm maintains contractual and technical arrangements with its technology providers consistent with applicable cross-border transfer requirements.
If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with a generally applicable data-protection regime, additional rights may apply to you. Contact the firm at the address in Section 12 with any request and we will respond on the merits.
Section 10Your choices and rights.
Depending on the jurisdiction in which you are located, you may have rights to request access to, correction of, or deletion of information the firm holds about you; to object to or restrict certain processing; to withdraw consent where processing is based on consent; and to receive your information in a portable format. These rights are subject to exceptions, including for information the firm is required to retain to meet its regulatory and recordkeeping obligations, to maintain engagement records, or to defend itself in a legal proceeding.
To exercise a right, contact the firm at the address in Section 12. We will verify your identity before responding to any request and will respond within the timeframe required by applicable law.
Section 11Changes to this notice.
The firm may update this notice from time to time. When we do, we will revise the "Effective" and "Last reviewed" dates at the top of the page. Material changes will be communicated to active clients through engagement-level channels. Continued use of the site after the effective date of a revised notice indicates acceptance of the revised terms.
Section 12How to reach us.
Questions about this notice, requests regarding information the firm holds, or notices required to be served under applicable privacy law should be directed to the contact below.