TwoBuddies ^™  
Privacy policy

In compliance with Regulation (EU) 2016/679, General Data Protection and Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights, we provide you with all the necessary information about our Policy of Privacy, in relation to the personal data we collect, explaining:

• Who is responsible for the treatment.
• For what purposes we collect your data.
• How long we keep the data.
• To which recipients are communicated.
• What are your rights.

In case of introducing modifications in the future on it, we will notify you through the website or through other means so that you can know the new privacy conditions introduced.

1. RESPONSABLE 

MINVESTGRUP EAF 

Adress: C/ Croàcia 13, Saint Quirze del Vallàs, Barcelona 

Telephone: (+34) 639 761 482

Email address: www.minvestgrup.com

Data Protection Officer: lopd@minvestgrup.com

2. HOW DO WE COLLECT YOUR DATA?

We collect your personal information through different means, but you will always be informed at the time of collection through informative clauses about the person responsible for the treatment, the purpose and legal basis of the treatment, the recipients of the data and the conservation period of your data. information, as well as the way in which you can exercise your rights in terms of data protection.

Through our website we collect personal information related to your browsing through the use of cookies. To know clearly and precisely the cookies we use, what their purposes are and how you can configure or disable them, see our Cookies Policy.

3. PURPOSE AND LEGITIMATION OF PROCESSING

At MINVESTGRUP we collect and process your personal information in general to manage the relationship we maintain with you. The main purposes that we have identified are the following:

• Management and contracting of products and services offered by our company.
• Channel the requests for information, suggestions and claims that you can send us.
• Keep you informed about events, offers, products and services that may be of interest to you through different communication channels as long as you have given your consent.
• Management of the employment relationship, in the case of our employees.
• Management and selection of personnel in the case of our candidates.
• Management of the commercial relationship maintained with our suppliers.

 In particular regarding the processing of data sent through:

• Contact Form

Purpose: Provide a means for you to contact us and answer your requests for information, as well as send you communications about our products, services and activities, including by electronic means (Email, SMS, WhatsApp), if you check the box acceptance.
Legitimation: The consent of the user when requesting information through our contact form and by checking the box for acceptance of sending information
Conservation: Once your request is obtained through our form or answered by email, if you have generated a new treatment for us, and in case you have accepted to receive commercial shipments, until you request to cancel them.

• Sending emails

Purpose: Answer your requests for information, attend to your requests and answer your questions or doubts.
Legitimation: The consent of the user when requesting information through the email address.
Conservation: Once your request is answered by email, if you have not generated a new treatment.

4.RESPONSIBILITY OF THE USER

By providing us with your data, the user guarantees that they are over 14 years of age and that the data provided to MINVESTGRUP is true, exact, complete and up-to-date. For these purposes, the user confirms that he is responsible for the veracity of the data communicated and that he will keep said information properly updated so that it responds to his real situation, taking responsibility for false and inaccurate data that he could provide, as well as for damages and damages, direct or indirect, that may arise.

The personal data requested is necessary to manage your requests for information, any clarification or doubt and/or provide you with the services you may contract, so if you do not provide them to us, we will not be able to attend you correctly or provide you with the service you have requested.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

MINVESTGRUP has a data conservation and deletion protocol, according to which, we only keep your information for the period of time necessary to fulfill the purpose for which it was collected, comply with the legal obligations imposed on us and attend to the possible responsibilities that could derive from the fulfillment of the purpose for which the data was collected.

If at any time we have collected your data to address you as a potential user of our services or respond to a request for information made by you, said data will be kept until once your request is made through our form or answered by mail. e-mail, and if you have agreed to receive commercial shipments, until you request to cancel them.

In the cases of personnel management and selection, we keep the data for 1 year from the reception of the curriculum.

In any case, and as a general rule, we will keep your personal information as long as there is a contractual relationship that binds us or you do not exercise your right of deletion and/or limitation of treatment, in which case, the information will be blocked without using it beyond Its conservation, as long as it may be necessary for the exercise or defense of claims or some type of responsibility could be derived that had to be attended.

6. RECIPIENTS

Your data is confidential and will not be transferred to third parties, except for those transfers that we must carry out based on imposed legal obligations.

7. INTERNATIONAL DATA TRANSFERS

There are no international transfers of your data to countries outside the European Economic Area (EEA).

We have agreed with our suppliers that, for the provision of the contracted service, they make use of servers located in the EEA and if, in the future, we need to use servers located outside the territory of the EU or the EEA, the appropriate measures will be adopted. , which will be incorporated into this Privacy Policy.

Although it is not a transfer of data, to provide the requested service it may be that third-party companies, which act as our suppliers, access your information to carry out the service that we have contracted. These managers access your data following our instructions and without being able to use it for a different purpose and maintaining the strictest confidentiality.

8. RIGHTS IN RELATION TO YOUR PERSONAL DATA

The regulations on data protection allow you to exercise your rights of access, rectification, deletion and portability of data and opposition and limitation to its treatment, as well as not being subject to decisions based solely on the automated processing of your data, when appropriate.

These rights are characterized by the following:

• Its exercise is free, except in the case of manifestly unfounded or excessive requests (eg, repetitive nature), in which case MINVESTGRUP may charge a fee proportional to the administrative costs borne or refuse to act.
• You can exercise your rights directly or through your legal representative or volunteer.
• We must respond to your request within one month, although, taking into account the complexity and number of requests, the period may be extended by another two months.
• We have the obligation to inform you about the means to exercise these rights, which must be accessible and without being able to deny you the exercise of the right for the sole reason of opting for another means. If the request is submitted by electronic means, the information will be provided by electronic means when possible, unless you request otherwise.
• If MINVESTGRUP does not process the request, it will inform you, no later than one month, of the reasons for not acting and the possibility of claiming before a Control Authority.
  
  

In order to facilitate their exercise, we provide you with the links to the application form for each of the rights:

Form exercise of the right of access
Form for exercising the right of rectification
Form to exercise the right of opposition
Form to exercise the right of deletion (right "to be forgotten")
Form for exercising the right to limit processing
Form of exercises of the right to portability
Exercise form not to be subject to automated individual decisions

To exercise your rights, MINVESTGRUP makes the following means available to you:

1. Mediante solicitud escrita y firmada dirigida al RESPONABLE (Indicado al inicio de esta Política de Privacidad) con la referencia “Datos Personales” o similar e indicando el derecho que quiere ejercer y sobre qué tratamiento a la dirección postal o electrónica indicada en el apartado 1: domicilio C/ Croacia 13, Saint Quirze del Vallés, Barcelona o lopd@minvestgrup.com 
2. Enviando el formulario correspondiente, escaneado y firmado a la dirección de correo electrónico referida indicando en el asunto Ejercicio de Derechos LOPD 

In both cases, you must prove your identity by attaching a photocopy or, where appropriate, a scanned copy, of your ID or equivalent document in order to verify that we only respond to the interested party or their legal representative, in this case providing a document accrediting the representation.

Likewise, and especially if you consider that you have not obtained full satisfaction in the exercise of your rights, we inform you that you may file a claim with the national control authority by contacting the Spanish Agency for Data Protection, C / Jorge Juan, 6 – 28001 Madrid.

9. HOW DO WE PROTECT YOUR INFORMATION?

At MINVESTGRUP we are committed to protecting your personal information.
We use reasonably reliable and effective measures, controls and procedures of a physical, organizational and technological nature, aimed at preserving the integrity and security of your data and guaranteeing your privacy.
In addition, all personnel with access to personal data have been trained and are aware of their obligations in relation to their processing.

In the case of the contracts that we sign with our suppliers, we include clauses in which they are required to maintain the duty of secrecy regarding the personal data to which they have had access by virtue of the order carried out, as well as to implement security measures. technical and organizational techniques necessary to guarantee the confidentiality, integrity, availability and permanent resilience of the systems and services for the processing of personal data.

All these security measures are reviewed periodically to ensure their adequacy and effectiveness.

However, absolute security cannot be guaranteed and there is no security system that is impenetrable so, in the event that any information subject to treatment and under our control is compromised as a result of a security breach, we will take appropriate steps to investigate the incident, notify the Control Authority and, where appropriate, to those users who may have been affected so that they take the appropriate measures.

10. COOKIES

This website uses its own and third-party technical, personalization, analysis and advertising cookies that can capture connection and/or device data, as well as browsing habits for statistical and advertising purposes.

Therefore, when accessing our website, in compliance with article 22 of the Information Society Services Law, when dealing with the aforementioned cookies, we have requested your consent for their use and provided information about them.

You can obtain more information in Legal Notices.

11. UPDATE OF DATA

It is important that so that we can keep your personal data updated, you inform us whenever there has been any change in them, otherwise, we are not responsible for their veracity.

We are not responsible for the privacy policy regarding personal data that may be provided to third parties through the links available on our website.

This Privacy Policy can be modified to adapt it to the changes that occur on our website, as well as legislative or jurisprudential modifications on personal data that appear, for which reason it is required to be read, each time you provide us with your data through this website.