Privacy Statement

The purpose of this Privacy Statement is to inform you, as a user of Avenue International (Cook Islands) Limited (“Avenue CI”)'s services and website, about how we collect, use, disclose, and protect your personal data. It serves to establish transparency and compliance with data protection regulations, allowing you to make informed decisions about how your data is handled when interacting with us.

Avenue International (Cook Islands) Limited may update this statement without prior notice. Changes will be promptly communicated on our website, ensuring you are informed about the data we collect, its usage, and disclosure. Any relevant changes will be effective immediately upon posting. If required by law, we will notify you and seek your consent to material changes.

1. Personal Data Collected and How We Collect It

We shall gather and retain your personal data under the following situations:

  1. when you furnish such information directly to us, for example, when making inquiries or communicating with us;
  2. through your interactions with our websites, apps, or social media platforms;
  3. in cases where you have supplied the data through alternate channels; and
  4. from affiliated entities, business partners, and other independent third parties sources in accordance with legal obligations.

The personal data we may collect (which includes sensitive personal data as defined under relevant applicable laws and regulations) are as follows:

  1. identity information such as name, address and personal contact details (including email address and telephone numbers);
  2. technical information such as IP address, browser type and version, time zone settings, browser plugin types, operating systems and platforms, device information (including where mobile device the IMEI number, wireless networks and general network information);
  3. legally collected personal or non-personal information related to you; and
  4. information about you from any social media features or platforms you used on this website, an application we provide, or through a social media provider, including the data you have chosen to share in your social media profile or account, subject to your privacy settings with the relevant social media provider.

We will indicate which of the information we collected is essential for a particular purpose, such as registering an account, accessing the website, and receiving service. While you have the option to withhold the requested information, please be aware that doing so may affect our ability to conduct business with you or adequately address your inquiries.

2. How We Use Your Personal Data

The data about you that Avenue International (Cook Islands) Limited possesses may be utilised for the following intentions:

  1. plan operations, encompassing application processing and evaluation, identity and credit checks, suitability assessments, investigations, account/debt collection, communication, data analysis and research, internal and external audits, maintaining quality services, sales and marketing, and customer loyalty building.
  2. fulfilling disclosure requirements of applicable laws, regulations, or guidelines issued by legal entities, authorities, industry bodies or associations of financial services providers.
  3. direct marketing, involving the promotion, marketing, or provision of Avenue CI-related plans or services, as well as any financial-related plans or services offered and/or marketed by third-party financial institutions, through electronic or other means.

We will seek your consent if we intend to use your personal data for purposes other than those stated in this statement. Your information will be retained as needed for data collection purposes or to comply with applicable laws and regulations. We implement reasonable security measures to prevent unauthorised access, processing, erasure, loss, or use and will dispose of the data when it is no longer needed.

3. Providing Your Information to Third Parties

Avenue CI will maintain the confidentiality of your personal data, but we may disclose it to the following third parties for plan processing purposes:

  1. Avenue CI's affiliates;
  2. financial institutions or financial service providers involved in processing payments or handling payment instructions;
  3. professional advisors, data processors, IT service providers, mailing houses, or third-party service providers engaged to provide independent advice or specialised services to Avenue CI and/or its affiliates;
  4. persons to whom Avenue CI and/or its affiliates are obligated to disclose information under applicable laws, regulations, or guidelines, including regulators, government authorities, courts, adjudicators, and industry bodies;
  5. financial intermediaries authorised by Avenue CI and/or its affiliates to promote or provide after-sales services related to Avenue CI's plans and services; and
  6. actual or potential purchasers of Avenue CI's business or its affiliates, along with their advisors in the transaction.

Your personal data may be transmitted beyond the Cook Islands for the stated purposes, encompassing data processing and storage.

In the course of business transactions, such as purchasing or selling businesses or parts thereof, your personal data might be transferred or disclosed. If we acquire a business, your data will be processed in line with this statement as far as possible and permissible.

4. International Transfers of Your Personal Data

We may share your personal data with the entities mentioned earlier, even if they are in different jurisdictions from yours. Your data may be processed in various locations where Avenue CI entities or third-party contractors operate. In some cases, we may ask for your consent to transfer your data outside your jurisdiction. We assure you that we will maintain a level of protection for your personal data that is at least comparable to the jurisdiction or territory in which you provided it.

5. Direct Marketing Privacy Notice

With your consent, which serves as our legal basis for such processing, we intend to use your name and contact details for promotional and marketing purposes. This includes sending marketing communications and conducting direct marketing to you through electronic and non-electronic means, including by post. The plans, services, and subjects covered are as follows:

  1. trust plans;
  2. wealth and financial management;
  3. investment;
  4. financial; and
  5. rewards/loyalty/privileges programs, services and subjects.

In pursuit of providing you with better services, we may share your name and contact details with other affiliates within Avenue CI, their respective agents, our business partners, and marketing partners. This will enable them to offer you information about relevant plans, services, and subjects. Your written consent is necessary for us to proceed with this transfer. Furthermore, in compliance with applicable laws, we may share your personal data with providers offering the mentioned plans, services, and subjects for gain.

At any point, you have the option to change your decision and withdraw your consent for receiving direct marketing communications.

6. Your Rights Regarding Your Personal Data

Your rights concerning your personal data include:

  1. request a copy of your personal data (a reasonable fee may apply);
  2. ask us to correct any inaccuracies or complete any incomplete personal data; and
  3. lodge a complaint with a data protection authority or another independent regulator if you have concerns about how we are using your personal data.

EU jurisdiction residents have additional rights under the General Data Protection Regulation (GDPR), including:

  1. request the deletion of your personal data if it is no longer needed for the purposes mentioned in section 2 of this privacy station, or if there is no other legal basis for the possession;
  2. object to the use of your personal data for direct marketing or other processing based on legitimate interests, including related profiling;
  3. ask us to provide a copy of your personal data in a structured and commonly used format in certain circumstances;
  4. limit the use of your personal data or withdraw any consents (including automated decision-making) you have given for the processing of your personal data.

7. Cookies Notice

When you access our website or use internet-enabled devices, a small file containing letters and numbers, known as a cookie, is stored on your browser or computer's hard drive. In addition, we automatically collect and retain specific information, including your IP addresses (and domain names), browser software, language settings, geo-locations, operating systems, referring websites, viewed pages, content, and visit durations during your visit. This data serves various purposes, such as ensuring seamless and proper website functionality, facilitating secure logins, allowing us to personalise content to provide the best user experience, and analysing traffic for future website enhancements.

Our website uses the following types of cookies:

  1. Strictly necessary cookies: These are essential for the proper functioning of our website, such as authenticating and verifying users for accessing our websites, including the password-secured area.
  2. Functionality cookies: These cookies recognise you upon returning to our website, enabling us to personalise content, address you by name, and remember your preferences, such as language or region selection.
  3. Analytical/performance cookies: These cookies help us track and analyse the number of visitors on our website and how they navigate it. This valuable information aids us in enhancing the user experience and ensuring that visitors find what they seek effortlessly.

By continuing to use our website, you consent to the use of cookies as described above. You may modify your privacy settings to block or manage cookies whenever needed. For instructions, kindly refer to the help menu of your respective browser or mobile device.

8. Privacy Statement of External Websites

Please note that certain parts of this website may contain links to other websites that may not adhere to this privacy statement. We advise you to review the privacy statements on those websites to understand their policies concerning the collection, usage, transfer, and disclosure of personal data.

9. Contact Us

For any inquiries in relation to this statement or Avenue CI's data privacy practices, or should you wish to exercise your rights regarding your personal data, including withdrawing from our direct marketing communications, please get in touch with:

The Data Protection Officer
Avenue International (Cook Islands) Limited
1/F., Are Taunga, Taputapuatea Road, Rarotonga, Cook Islands