The following Privacy Statement is provided to you in connection with your provision of personal data or information (“Data”) to ALPHA from time to time.




  1. From time to time, it is necessary for you to supply ALPHA with Data in connection with various matters such as account opening or continuations, provision of services to you or compliance with any laws or guidelines issued by regulatory or other authorities.

  2. The kinds of Data that may be collected includes, but is not limited to, name and address, occupation, contact details, date of birth, nationality, identity card or passport numbers, details of financial status.

  3. Failure to supply such Data may result in ALPHA being unable to open an account or continue to provide services to you or unable to comply with any laws or regulations or guidelines and codes issued by regulatory or other authorities.

  4. It is also the case that Data is collected from you in the ordinary course of the continuation of your relationship with ALPHA, for example, when you open an account, write cheques, transfer funds, effect transactions, attend seminar/events, participate in online activities or generally communicate verbally or in writing with ALPHA.


Purpose and Use:

5. The purposes for which Data may be used will vary depending on the nature of your relationship with ALPHA. ALPHA intends to use your Data for any or all of the following purposes:​

a)      the processing of an application for an account with ALPHA including confirming and verifying your identity;

b)      the daily operation of your account and the services to be provided to you;

c)      any purpose related to the administration of the products and services offered by ALPHA;

d)      researching, designing and launching financial, investment services or related products for clients;

e)      meeting the disclosure and compliance requirements under any laws or regulations, codes, guidelines or internal ALPHA compliance policies applicable to ALPHA in the Cook Islands or elsewhere;

f)      promoting and direct marketing of the following services and products subject to your right to object to such use:

i)      financial planning, wealth management, insurance and related services and products;

ii)      financial and educational seminars and forums;

iii)      other services and products offered by any member of ALPHA Group;

g)      any other purpose directly related to the above.

6. You have the right to object to the use of your Data for direct marketing purposes as set out in paragraph 5(f) above. ALPHA will cease to use your Data for direct marketing purposes without charge if you so request.


Retention and Access:


7. The Data collected may be maintained for such period of time required under applicable law and as otherwise needed to fulfill the purposes set out above.

8.Data held by ALPHA relating to you will be kept confidential and ALPHA will take all reasonable measures to ensure that Data is kept secure against unauthorized access, loss, disclosure and destruction. ALPHA may provide such information to the following parties, whether inside or outside of the Cook Islands, for the purposes set out in the “Purpose and Use” section above:


a)       the ultimate holding company of ALPHA, its subsidiaries, representative offices, associated companies and/or affiliates;

b)       the service providers of ALPHA including the trustee, investment manager, registrar, transfer agent, the custodian, administrative service agent, and the auditor of ALPHA;

c)      any agent, contractor or third party service provider who provides administrative, research, design, launch, digital or telecommunication, clearing and settlement or other services to ALPHA in connection with the operation of its business;

d)      the employees, officers, directors of ALPHA;

e)      any party (including but not limited to, any governmental or regulatory authority or court of competent jurisdiction) entitled thereto by law or regulation or in response to a regulatory request; and

f)       external service providers of ALPHA (including but not limited to printing houses, mailing houses, digital or telecommunication companies, data processing companies, storage companies, and information technology companies) that ALPHA engages for the purposes set out in paragraph 5(f) in the “Purpose and Use” section above.


9. You have the right to:

(a)      check whether ALPHA holds Data about you, and access to such Data;

(b)      require ALPHA to correct any Data relating to you which is inaccurate;

(c)       ascertain ALPHA’s policies and practices in relation to data and to be informed of the kinds of Data held by ALPHA; and

(d)      object to the use of your Data for direct marketing purposes and ALPHA shall not use your Data for direct marketing purposes after you communicate your objection to ALPHA.


ALPHA has the right to charge a reasonable fee for the process of any data access request.


For access to your Data held by ALPHA, correction of such Data, objection to use of your Data for direct marketing purposes or for information regarding policies and practices and kinds of Data held, please contact us by clicking on the Contact Us link.

© 2018 by Alpha Trust (Cook Islands) Limited. All rights reserved.