TwoBuddies ™
Privacy policy
LEGAL ADVICE
This Website is property of MINVESTGRUP, EAF, S.L. (hereinafter, MINVESTGRUP) with NIF B10950046, address at c/ Croacia 13, 08192 San Quirze Del Valles, Barcelona (Spain)
Likewise, we put at your disposal a Data Protection Officer who will not only be in charge of supervising all data processing carried out in our entity, but will also be able to assist you with any issue related to the processing of personal data. The contact details of our data protection officer are: LAURA MUÑOZ GARCÍA C&S SL...
This website is governed by the regulations exclusively applicable in Spain, and both nationals and foreigners who use this website are subject to it.
Access to our Website by the USER is free and its use is governed by the conditions of use in force at the time of access, which we ask you to read carefully. If the user does not agree with these conditions of use, they must refrain from using this portal and operating through it, and may contact us so that we can resolve any questions related to them.
The provision of personal data through our portal requires a minimum age of 14 years, or, where applicable, having sufficient legal capacity to contract.
At any time we may modify the presentation and configuration of our Website, expand or reduce services, and even delete it from the Network, as well as the services and content provided, all unilaterally and without prior notice.
A. INTELLECTUAL PROPERTY
All contents, texts, images, and source codes are the property of MINVESTGRUP or third parties from whom their exploitation rights have been acquired, and are protected by Intellectual and Industrial Property rights.
The USER only has the right to private, non-profit use of them, and needs express authorization to modify, reproduce, exploit, distribute them or exercise any right belonging to their owner.
The establishment of links to our portal does not confer any rights over it. Likewise, the simple fact of establishing a link to our website does not give the right to be granted the category of collaborator or partner.
MINVESTGRUP is exonerated from liability for any claim regarding the intellectual property rights of the articles and images published by third parties on its portal.
Imitation, whether total or partial, of our portal or the establishment of links to our website without the prior authorization of MINVESTGRUP is absolutely prohibited.
B.
Access to our website is free and does not require subscription or prior registration.
Sending personal data implies express acceptance by the USER of our privacy policy.
The USER must access our Website in accordance with good faith, the rules of public order and these General Conditions of use. Access to our website is carried out under the own and exclusive responsibility of the USER, who will be liable in all cases for any damages that may be caused to third parties or to ourselves.
The USER is expressly prohibited from using and obtaining the services and content offered on this website, by procedures other than those stipulated in these conditions of use.
The USER is prohibited from any type of action on our portal that causes an excessive overload of the operation of our computer systems, as well as the introduction of viruses, or installation of robots, or software that alters the normal functioning of our website, or ultimately may cause damage to our computer systems.
Taking into account the difficulty of controlling the information, content and services contained in third-party web pages available from our website, we inform you that MINVESTGRUP is not responsible for them, without prejudice to the fact that it will try, to the extent of as much as possible, ensure its legality.
MINVESTGRUP reserves the right to terminate any USER that the organization believes has violated the conditions that govern the use of our website. Likewise, it reserves the right to take appropriate legal action against those who violate these general conditions of use.
C.
Confidentiality and security are primary values of MINVESTGRUP and, consequently, we assume the commitment to guarantee the privacy of the USER at all times and not to collect unnecessary information.
The provision of personal data through our portal requires a minimum age of 14 years and express acceptance of our Privacy Policy.
D.
By making this Website available to the USER, we want to offer a quality service, using maximum diligence in its provision, as well as in the technological means used. However, MINVESTGRUP does not guarantee that the availability of the service will be continuous and uninterrupted, due to circumstances caused by problems in the Internet network, breakdowns in computer devices or other unforeseeable circumstances, so that the USER agrees to support these within reasonable limits. circumstances.
This Website, except as regulated, where appropriate, by some specific conditions of use, is purely informative and a corporate presentation of our products and services, so MINVESTGRUP is not responsible for expectations of any kind that may be generated by the USER. .
Everything related to our Website is governed exclusively by Spanish laws. In the event that any type of discrepancy or difference occurs between the parties in relation to the interpretation and content of this website, all parties submit to the Courts and Tribunals that legally correspond.
E.VALIDITY OF THE GENERAL CONDITIONS OF ACCESS TO THE WEBSITE
These General Conditions of Use have been modified in January 2024. We may modify them at any time: please check the date of issue each time you connect to our Website so that you will be sure that no There has been any modification that affects you.
For any question regarding the Conditions of Use of our Website, you can contact us at the information indicated above.
CUSTOMER SERVICE
In accordance with the regulations on transparency and customer protection of financial services, Minvestgrup makes available to its customers a Customer Service Department whose task will be to address and resolve customer complaints and claims.
Minvestgrup puts at your disposal all the means to respond to all your needs. Our staff is best suited to receive and resolve any possible suggestions, complaints or claims that may arise. To make your complaints or claims you must contact:
• By email, through the address sac@minvestgrup.com
• By phone at the following phone number 919 293 621
The Customer Service has a period of two months, from receipt, to respond to a complaint or claim. Therefore, if the complexity of the matter raised requires this maximum period, after it has elapsed, we will send you a definitive response or progress report.
If within the indicated period, and once you have exhausted the different instances that Minvestgrup makes available to you, you have not received a response or it is not satisfactory, you may contact as the next instance:
• Complaints Service of the National Securities Market Commission (CNMV) Commissioner for Investor Defense
C/ Edison 4, 28006 Madrid
• Claims Service of the Bank of Spain
C/ Alcalá 48, 28014 Madrid
www.bde.es
• Claims Service of the General Directorate of Insurance and Pension Funds
Paseo de la Castellana 44, 28046
www.dgsfp.mineco.es
For more information about the operation of the Customer Defense Service, you can consult our Customer Defense Regulations.
ACTIVITY PROGRAMME
The Activities Program contains a description of the activities carried out by MinvestGrup.
INTERNAL REGULATION OF CONDUCT
The Internal Regulations of Conduct include the rules of conduct applicable to the activity carried out by MinvestGrup.
ETHICAL CODE
The purpose of the MinvestGrup Code of Ethics is to preserve and set an example of ethical behavior in accordance with its values as a company that provides financial advisory services.
RESPONSIBLE CHANNEL MANAGEMENT POLICY
The objective of this policy is to establish the guarantees for the protection of informants, the general principles that regulate the operation of the Internal Information System and its Procedure.
RESPONSIBLE CHANNEL
WHAT IS THE RESPONSIBLE CHANNEL?
Minvestgrup makes the Responsible Channel available as communication mechanisms so that any non-compliance can be reported in order to promote respect for the law and the rules of conduct included in its Code of Ethics. Minvestgrup guarantees the confidentiality of the communications received, which may also be made anonymously.
We recommend prior consultation of the Responsible Channel Management Policy where you will find all the information about the channel.
This channel is not for complaints and/or claims about the service received from Minvestgrup. For this, the following email is enabled: sac@minvestgrup.com
WHO CAN REPORT?
- Employees, managers and the Sole Administrator.
- Shareholders
- Scholarship holders,
- Temporary employment agency workers,
- Collaborators,
- Suppliers and people who work for or under their supervision,
- Clients or potential clients,
- Former employees,
- Candidates for a job,
- Third parties with whom any type of relationship or link may exist, and Any third party who has detected illegal conduct.
WHO CAN BE REPORTED TO?
A complaint may be made against all employees, directors, the Sole Administrator, or external collaborators of Minvestgrup subject to its authority who have committed any irregularity or conduct of those provided for in the objective scope detailed in the Responsible Channel Management Policy.
WHAT IS THE PROCESS TO CREATE A COMPLAINT?
To send a report, access the platform and start by clicking on the "Channel access" button located on the left side of the Minvestgrup Responsible Channel introduction page. https://canres.page.link/kG1E
1. Once you access the page, you will first be asked to read, understand and accept the following documents: Channel Use Manual, Communications Management Procedure and Privacy Policy.
2. Once you accept, you will automatically access the “Previous data” screen where the following data will be requested:
- Type of communication that you want to make (infringement, irregularity, suggestion, doubt, complaint)
- Indicate whether or not it is urgent
- Type of relationship that the informant maintains with the organization (employee, manager, agent, client, supplier, partner)
- Areas that are considered violated (optional)
- A password must also be entered, which must be repeated to continue.
3. Next, you must choose the form of communication: through written form or personal interview. Once you have selected the form of communication, you can choose between:
Anonymous communication. The person who performs it will not have to indicate any personal information. As notices cannot be sent to you (communication status changes, requests...), you will have to access your communication in the channel to check if they exist.
Semi-anonymous communication. The person who performs it will have to indicate their personal data, but these will not be communicated to the entity. You may receive notices in the email you provide and your data will not be revealed to the entity unless you have acted in bad faith.
Non-anonymous communication. The person making the communication will indicate their personal data to the entity and will receive notices in the email provided.
Once this has been chosen, the form must be completed by filling out the following fields:
- Indicate when it has occurred or if it continues to occur
- Description of the facts
- Who knows the facts
- Which people or departments are involved
- Password reminder for tracking
Remember that you must save your password and reference number to be able to track your communication.
*ATTENTION: Through the use of the responsible channel, the protection of the person who files the complaint is guaranteed. Therefore, we ask that, if you want your communication to be anonymous, do not provide us in the description of the facts or in the documentation provided any personal data through which you can be identified.
Likewise, we recommend not using a device that has been provided to you by the company itself to submit your report.
HOW DO I FOLLOW UP A COMPLAINT?
To know the status of the complaint, you must access the platform and in the upper margin of your screen you will find “Communication Monitoring”. You must fill in the Complaint Reference and Password field and then click on the “Send” button.
Once you enter the code that was generated at the time of the presentation, you will access your specific case, being able to view its status, provide new documentation or chat with the responsible channel manager.
Those who wish to have the complete Policy may request it at the following email address compliance@grupolmg.es