Vista - Avoid "System32": Where to place an INI file?

Friends,

Our application uses a few INI entries in our own ZZZ.INI file located in
"System32". (We use database records most all configuration, but some
entries must be handled before a DB connection is established.) The INI
file use is part legacy, and partly for ease of editing; we hesitate to have
customers make registry entries.

Anyway, Vista "UAC virtualization" ensures that writes to the INI file do
not actually alter the "System32" INI file, but this results in per-user
entries. We plan to add an "AsInvoker manifest" to our next build to
prohibit "virtualization". But, we want to change the location for the INI
file to someplace acceptable to Vista. Such a location must be referenced
by something in the environment, similar to %SYSTEMROOT%.

The best I've found so far is %ALLUSERSPROFILE% Is this an acceptable
location for our INI file? IS there a more standard place for such things?
Should I bite the bullet and use the registry? (Accompanied by a little
user app to read/write registry entries, so as to isolate our users from
regedit.) There are some other common read/write files that we plan to
place in this new location too, so I want to get things right.

Any words of advice will be greatly appreciated. Thanks in advance!

James