Effective Date: June 2, 2025

At Coco Brush (“we,” “our,” or “us”), we are dedicated to protecting your personal information in compliance with applicable laws, including those in the Cook Islands, New Zealand’s Privacy Act 2020, and, where relevant, the General Data Protection Regulation (GDPR) of the European Union and US privacy acts.

This Privacy Policy outlines how we collect, use, store, and safeguard your personal data when you interact with us online or in person.

1. Information We Collect

We may collect the following personal information:

• Full name
• Contact details (email address, phone number)
• Booking and event participation information
• Payment details (processed securely via third-party platforms)
• Optional demographic or feedback information
• Photos from events (for promotional use, with your explicit consent)

We do not knowingly collect personal data from children under the age of 13 without verified parental or guardian consent.

2. Legal Basis for Processing Personal Data (Under GDPR)

If you are located in the European Union or if the GDPR applies to your data, we rely on the following legal bases to process your personal data:

• Contractual Necessity: To fulfill a booking or provide a service you have requested.
• Consent: For marketing communications or the use of photographs.
• Legitimate Interests: To improve our services, communicate important updates, or for internal administrative purposes.
• Legal Obligations: To comply with applicable laws and regulations.

3. How We Use Your Information

We use your information to:

• Process bookings and payments.
• Communicate with you regarding events, services, or any changes.
• Provide customer support.
• Send marketing communications, where you have provided consent.
• Improve our offerings and enhance service quality.

We will always inform you of the specific purpose for data collection at the point of collection if it differs from those listed above.

4. Data Storage & International Transfers

Your data may be processed and stored in the Cook Islands, New Zealand, or other countries where our third-party service providers (e.g., web hosting, payment processors) operate.

By using our services, you acknowledge that your data may be transferred to jurisdictions that may not offer the same level of privacy protection as your home country. We ensure that all international transfers comply with applicable privacy regulations, including the use of Standard Contractual Clauses (SCCs) for transfers under the GDPR, where required.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. You may request the deletion of your information at any time, subject to any legal or contractual retention obligations.

6. Your Rights

Under Cook Islands and New Zealand Law:

You have the right to:

• Access your personal information.
• Request correction of any inaccuracies in your data.
• Request deletion of your information (subject to our retention policies).
• Object to certain types of data use.
• Lodge a complaint with the relevant supervisory authority.

Under the GDPR (if applicable):

You have additional rights, including:

• The right to data portability.
• The right to restrict processing.
• The right to lodge a complaint with a supervisory authority within the EU.

To exercise any of these rights, please email us at cocobrushco@gmail.com.

7. Data Protection & Security

We implement appropriate administrative, technical, and physical security measures designed to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

8. Cookies & Website Analytics

Our website may utilize cookies and analytics tools (e.g., Google Analytics) to enhance your browsing experience. These tools may collect anonymous data about your website usage. You can manage your cookie preferences through your browser settings.

9. Photos and Media

During events and classes, photos may be taken for promotional purposes. By attending, you grant Coco Brush permission to use your likeness in these photos. If you prefer not to be photographed or have your image used, please notify a staff member at the event or email us at cocobrushco@gmail.com.

10. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before providing any personal data.

 11. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in legal obligations, our practices, or our services. The most current version will always be posted at https://www.cocobrush.co.


12. Contact Us

If you have any questions regarding this Privacy Policy, your personal data, or your rights, please contact:

Coco Brush

🌐 Website: https://www.cocobrush.co

📧 Email: cocobrushco@gmail.com

📞 Phone: +682 57714

📍 Based in: Cook Islans