Privacy Policy

AS TWINO Investments, legal address: Pērses iela 2A, Riga, LV-1011, Reg. No. 44103143823, performs responsible data processing, providing for and promoting customer privacy. Any personal data submitted, collected and received will be processed only for the stated purpose and only to the extent necessary to achieve the goal. Please, read more about the main privacy principles here.

In order to provide information and services, we collect information in various ways - directly from you in an automated way and receiving from third parties. More details here.

We need to use the information we collect, including from third parties, in order to provide our services and fulfil our business goals. Likewise, we may use pseudonymed, anonymized, or otherwise unidentifiable information for other purposes, incl. transfer to third parties. More details here.

We may need to disclose your personal data to our group of companies and our cooperation partners in order to meet the objectives associated with the service delivery. Prior to such data transfer, we evaluate the volume, purpose of the data to be transferred, and we require data recipients to comply with and provide the necessary data protection technical and organizational measures. More details here.

You should be aware that no method of electronic data transmission or storage is ever completely secure, but we do a series of administrative, technical, personnel and physical activities to protect our information. More details here.

You are entitled to information, data access, data correction and data "forgetting", as well as to object to the processing of data and perform their transfer. To realize this right, see the information here.

Duration of data storage is set up by the completion of their collection and processing objectives, more details here.

We use cookies to provide a better user experience, collect additional usage data and improve our services. More about cookies here.

Our Website may contain links to other third party Internet sites. We neither control, nor take any responsibility for the content, privacy policies and practices of third-party web sites or services. More details here.

From time to time, we may update our Privacy Policy, so we encourage you to periodically review this Website. We will notify you of any changes by posting actual changes on this Website. These changes are valid immediately after they are posted on the Website.

If you would like to contact us regarding the privacy of data, or if you would like to comment on this Privacy Policy, please email to: [email protected].

AS TWINO Investments, legal address: Pērses iela 2A, Riga, LV-1011, Reg. No. 44103143823, hereinafter referred to as "we", understands the importance of our clients' privacy and takes responsibility for the processing of personal data.

This Privacy Policy describes our attitude to and responsibility for the information we collect about you or received from you, when you visit our website www.twino.eu (hereinafter referred to as the Website). This privacy policy applies to all of our services that have a link to this privacy policy.

We do not knowingly collect, use, or disclose personal information about identifiable persons under the age of 18 unless specifically required by law.

We may transfer and store your data to countries located in the European Union and/or the European Economic Area, but do not transfer your data to countries outside the European Union and the European Economic Area.

For the purposes of this privacy policy, "private information" is information identifying a particular person, such as a name, surname or email address (hereinafter referred to as "Personal data"). Likewise, if other information, such as the purchase of services, is related to the private information, it is also considered to be private information of a person.

When you only visit the Website and do not transfer information to the input forms, identified or identifiable personal data are not collected, but cookies are collected in accordance with the section of the "Cookies" of the present privacy policy.

Any personal data submitted, collected and received will be processed only for the stated purpose and only to the extent necessary to achieve the goal. Information will be provided on specific data to be transmitted and, if necessary, consent will be required under the General Data Protection Regulation and other data processing regulatory documents.

This privacy policy may be subject to change. Our Website has an up-to-date wording of the policy, as well as out-of-date wordings of the privacy policy are available here.

To ensure the provision of information and services, we collect information in the following ways:

1. Directly from you:

   1. providing an opportunity to fill out an application form on our Website;

   2. by means of online communication, by phone, e-mail or other technical tools and communication channels.

2. In an automated way:

   1. technical information that may contain your IP address, device data, software data, and similar data;

   2. social network information and content that may contain identification and social account data;

   3. cookies (more information in the section "Cookies").

3. Receiving from third parties:

   1. publicly available resources (social networks, public registers);

   2. our cooperation partners and affiliated companies.

For you to receive the services listed on the Website and for other business objectives of our company, you may need to provide information to us or our cooperation partners to the extent necessary for a specific purpose.

We may use information about you to:

1. maintain your user account;

2. verify your identity;

3. process the applications received from you;

4. provide services;

5. conduct business analysis, statistical measurements, market research and evaluate our activities, quality of our services and products provided;

6. ensure and improve the quality of services;

7. develop and offer you new services;

8. maintain and verify our Website and make the necessary improvements therein;

9. contact you regarding the services provided, as well as new services that might be of interest to you and inform about changes in services and contractual relations;

10. offer you other services and products provided by us, companies within our group and/or third parties;

11. to promote (on websites and mobile services, by mail, email, phone or SMS) our products and services or those of other companies within our group, or third parties, including by adapting them to your personal preferences;

12. ensure the receipt of appropriate commercial and non-commercial notifications;

13. identify and prevent any criminal activity, including money laundering, terrorist financing and other criminal financial activities;

14. perform the duties arising from the requirements of regulatory enactments;

15. use in any other legal manner.

Prior to transferring data, we require data recipients to comply with and provide the necessary technical and organizational measures for data protection, data storage and processing security.

We may disclose your personal data to the companies within our group and our cooperation partners for the following purposes:

1. to carry out your identification and solvency assessment, transferring your Personal Data to relevant state and commercial institutions;

2. to offer and develop new services;

3. for cooperation partners - service providers, such as website maintainers, marketing service providers, etc.;

4. to identify, investigate and prevent any money laundering or terrorist financing activities, as well as any fraudulent activities;

5. to exchange with other service providers with your personal data that we have obtained or you have provided us with, while using the services offered on our Website;

6. for the needs of statistics and any other research;

7. in the course of legal research, as well as in case of sale of an enterprise;

8. in the cases provided for in regulatory enactments.

From the third parties for our purposes, we can request and obtain information about you:

1. searching for information about you, about your financial standing, credit standing, past and present liabilities and indebtedness, employment, as well as other necessary information in other publicly available sources;

2. information from financial and payment institutions, including banks;

3. information from companies within our group;

4. information from our cooperation partners regarding the provision of payments, technical support or services;

5. information in any other case, where you have given us the consent or there exists any other legal basis.

In order to ensure that our content, services and messages are consistent with you and similar to your target audience, we may collect information from you and about you to evaluate your potential areas of interest.

If information received from you or about you does not identify you as a natural person and/or is used in a pseudonymed, anonymized or otherwise unidentifiable manner, we may use it for any purposes other than those previously mentioned, including transfer to third parties.

We perform a series of necessary administrative, technical, personnel and physical activities to protect any available to us information against loss, theft and unauthorized use, disclosure or modification, and other unlawful uses.

You must be aware that no electronic data transmission or storage method is ever completely secure and therefore we cannot substantiate or guarantee that such information will never be available, used or released in a manner that does not comply with this Privacy Policy, however we have taken all necessary steps for such risk minimization.

We will keep your information for the period required to meet the objectives set forth in this Privacy Policy, unless the law provides or permits a longer storage period.

You have the right to be informed of all the purposes, scope and intended processing of the data prior to any data transfer, and agree or disagree with the processing of data that cannot be performed without your express consent. Such information will be provided on the Website at the moment before you transfer data.

You have the right to request and receive information about your personal data that we process, what information we process, the purpose for which we process it and to whom we transfer your personal data.

We will try to fulfil your request as soon as practicable. Please note, you are entitled to free access to this information, but not more often than twice in a calendar year. In the event you request the aforementioned information about your personal data more often, in that case we will provide it for you in return for a fee that will cover our costs of providing to you with this information.

You have the right at any time to request us to correct and update inaccurate data at our disposal.

You have the right to oppose the continuation of the data processing, and to revoke the prior consent of the data processing.

You can realize all the above rights by sending a request and contacting our data processing specialist by e-mail [email protected].

You have the right to request the "forgetting" of your data, however, we reserve the right to assess in which cases to completely delete your data and in which to perform their anonymization or pseudonymization, i.e. make them unidentifiable. Likewise, we have the right to refuse the request, if the continuation of the data processing is necessary for the fulfilment of the legitimate aims in accordance with contractual relations and requirements of the regulatory enactments. Applications for "forgetting" data can be submitted by e-mail [email protected].

You have the right to export the personal data you have submitted for the purpose of transferring them to another service provider. Exports can be retrieved in an automated way in the section "Profile" of your online account.

You are entitled to refuse the receipt of our commercial and non-commercial notifications by choosing "Discontinue receipt of further information" in any communication received. If, after the refuse to receive any commercial and non-commercial notifications you continue to receive our communications erroneously, please let us know by e-mailing to the above address, so that we can resolve the situation.

We offer to purchase shares by using automatic share purchase service "Auto Invest", who selects shares according to your chosen criteria.

Auto Invest service is performed according to the following algorithm:

1. You can set-up criteria for automatic share purchase on Website section Auto Invest by choosing Your desirable parameters for automatic share purchase operations.

2. By accepting Auto Invest parameters and accepting agreement Auto Invest functionality will be enabled and will:

   1. search if there is available investment object according to your parameters;

   2. if relevant investment object found, system will automatically prepare and agree contract to purchase share.

3. You can disable Auto Invest functionality any time.

You can oppose the decision taken by the automated processing by sending a request and contacting our data processing specialist by e-mail [email protected].

We store personal data in accordance with the procedure set out by the regulatory enactments of the European Union and Latvia, respecting the data storage terms set out by the legal, financial, data protection and other enactments, as well as to ensure the legitimate interests in the case of any disagreement.

The data storage period lasts until the completion of the purposes for which they have been collected and processed, except for the personal data that you have provided us with on the basis of consent. Such personal data will delete no later than within 1 (one) month from the date of withdrawal of your consent and receipt of the request.

A cookie is a small text file stored on your device. The purpose of the cookie is to identify the device by which you access our Website.

We and our partners use cookies to:

1. protect our customers and prevent fraudulent activities;

2. find out how our Website users access our Website and explore how they use it to improve the quality of services provided to you;

3. monitor and manage the traffic of the Internet site;

4. improve the quality of the Website;

5. offer you our commercial and non-commercial notifications.

We use two types of cookies:

1. session (short) cookies that are deleted, when you close or leave the Website;

2. permanent cookies that remain after the browser is closed and, which can be used again when returning to the Website.

Our website cookies can be used by third-party analytics and online commercial communications maintenance platforms (Google, Facebook, etc.), so that commercial communications based on your visit history can be presented to you. You may refuse to use such cookies by visiting the settings of the home page of these systems.

If you want to restrict or block cookies on our Website or on any other website, you can do so by changing your Internet browser settings. For example, you may be able to block all cookies, accept only first-party cookies, or delete all cookies by leaving the browser.

Please note that some of our services may not work, if you block or delete cookies.

Our Website may contain links to other third party Internet sites. Each site has its own Privacy Policy. If you visit such third-party internet sites, these sites will be subject to their privacy policies. We neither control, nor take any responsibility for the content, privacy policies and practices of third-party web sites or services.