Payment services provider

About our card and account service provider

PECUNIA CARDS EDE, SLU, is an electronic money institution supervised by the Bank of Spain and registered under the number CSB 6707, whose commercial name is «PECUNPAY».

PECUNIA CARDS EDE, SLU is the issuer and administrator of the 2gether Money Management SL card and payment account. If you have any problems related to the operation of the card, you can contact the payment service provider via the following email address: servicioatencioncliente@pecuniacards.es

Payment service provider conditions

 

General Terms and Conditions of use of 2gether services

 

Introduction

The present document establishes the General Terms and Conditions that regulate the use and access to the services of the 2GETHER application whose ownership corresponds to the company 2gether Money Management, SL, hereinafter 2gether, support@2gether.global, CIF B87586400 whose headquarters are located at Calle Bravo Murillo 101, 28020, Madrid. The company is registered in the REGISTRO MERCANTIL DE MADRID according to the deed issued on: 02/06/2016 Sheet M-628706 Volume 34955 Folio 49, Inscription 1.

 

What do these Terms and Conditions regulate?

The present Terms and Conditions of Use regulate the access and use that the authorized User makes within the private area in which 2gether offers the service. If you do not accept the Terms and Conditions of Use of this service, you may not access or use it. Access to the 2gether application, its downloading and use are subject to these Terms and Conditions and in the event that the User has not read and accepted these Terms and Conditions, the User must refrain from accessing and using the Service. In the event that the user consents, they expressly accept these Terms and Conditions which shall govern their use.

The Terms and Conditions available at any time on the application and on the 2gether website (www.2gether.global) shall be considered valid and applicable. Any special conditions, notices, regulations, legal bases for promotions or operating instructions that are brought to the attention of users and that supplement the provisions of these Terms and Conditions shall also be applicable to use.

 

General information

Definitions. These General Terms and Conditions of Use (hereinafter referred to as the «General Terms and Conditions», «Terms and Conditions», «Terms» or «Conditions») govern the service or services of 2gether, (hereinafter referred to as «Service», «Services», «Pre-commercial Products», «Products» or «New version of commercial products» – the use of one of these definitions to refer to current and future products of 2gether); Terms and Conditions that 2gether offers directly to Users (hereinafter referred to as the «User» or «Users») previously chosen and designated by 2gether.

These Terms, as well as all other documents incorporated on the other services and products offered by 2gether, regulate the conditions governing the use of the Mobile Application, the Website and the purchase or acquisition of products and/or services on the same.

Before using the Service, the User must read, understand and accept the rights and obligations set out in these Conditions.

Use of the service(s) by the user requires:

  • Acceptance of all Terms and Conditions and Legal Notices published on the Website and the mobile application, hereinafter the «Application», or «App», where the Service is offered by 2gether. In accordance with the new Spanish and European regulations on Personal Data Protection, Users must actively and explicitly accept the 2gether Privacy Policy, therefore, in order to use the Service, the User will need to have previously accepted the 2gether Privacy Policy.
  • Acceptance of all the Conditions existing at the time the User accepts them by accepting them and registering for the Service.
  • Acceptance of all other conditions communicated to you, the User, each time you access and/or use the Service on the Website or in the Application, except all possible new conditions related to Data Protection and Privacy Policy.

By using 2gether or by making and / or requesting the purchase of a product and / or service through the App, the User consents to be bound by these Terms and Conditions and by all of the above, therefore, if they do not agree with all of the above, they shall not accept these Terms and Conditions, and access to the App or to the services offered by 2gether shall not be possible.

You are also informed that these Terms and Conditions may be modified. 2gether may notify the User by email or telephone, but the User is ultimately responsible for consulting them each time they access, browse and/or use the Application or the Website, as those in force at the time when the purchase of products and/or services is requested will be applicable.

 

 

1. The service

 

1.1 The service

Through the Service, 2gether provides the User with an environment in which they can:

  • Test different services and / or pre-commercial products and / or new versions of commercial Products, owned by 2gether and / or third parties;
  • Make suggestions and provide ideas (hereafter referred to as «Ideas»);
  • Receive recommendations on new services and/or products, which may be tested (hereinafter, the «Recommendations»).

 

1.2 Technical erequirements

The minimum technical requirements for use and, where applicable, installation will be published on the website and in the 2gether Application.

The 2gether Application is designed for Android and iOS mobiles, available through the Apple Store and Google Play shops respectively.

The downloads are free of charge for the user.

 

1.3 Advantages and promotions

For the registration of Users in the Service and/or, as the case may be, for the participation of Users in studies, surveys and/or questionnaires that are carried out and/or made available to them at any time on the Website and in the application, among other purposes, to learn about their experience after testing the Services, the Pre-commercial Product and/or the New versions of commercial Products of the Service; the User may receive certain advantages and/or participate in promotions that, at any time, may exist, in accordance with the instructions and other requirements that, in each case, they will be informed of.

 

1.4 Functionalities of the Service

 

1.4.1 The service offers:
  • Prepaid card and shared IBAN. 2gether will provide the user with a prepaid VISA card and a non-nominative IBAN number.
  • Crypto. 2gether will provide the user with a mobile application environment for trading cryptocurrencies.
  • Accounts. The User will be able to trade on the cryptocurrency market through the Accounts provided by 2gether in its mobile application. The User, without leaving the environment provided by 2gether, will be able to trade on this market, but the deposit of his funds will be on the platform of a third party: KRAKEN. In compliance with regulatory requirements and within 2gether’s policies, the User may send cryptocurrencies from his Accounts to other accounts or cryptowallets hosted outside the environments provided by 2gether. In addition, the User will also have their account in regulated currency (hereinafter, FIAT), namely EUROS, in another wallet, with which they will have the same functionalities described above for cryptocurrency accounts.
  • Transfers. The user will be able to make transfers in EUROS (FIAT) regulated currencies. Transfers in FIAT currency, currently EUROS, can be made in two ways: (1) by indicating the destination IBAN of the account to which you wish to transfer the money and (2) if it is a transfer to a 2gether User, by indicating in the list of contacts, within the 2gether environment in the Application, the user to whom you wish to send money.
  • ATM / Cash withdrawals at ATMs. The User may withdraw money in EUROS with his/her 2gether card from cash dispensers that accept VISA cards.
  • 2GT Tokens. When the User registers on the 2gether application, and after accepting all legal terms for its acquisition and use, the User may optionally acquire tokens issued by 2gether, called «2GT» to acquire the status of Founder.
  • Refunds. Refunds made by 2gether to the user, whatever the reason (failed purchase made by card, withheld transaction or error in the purchase of cryptocurrency), shall always be made in EUROS.

 

1.4.2 Cost of Service

The use of 2gether’s functionalities and services may, in certain cases, involve additional costs/service fees. Thus 2gether will charge the following fees:

 

SEPA Transfer: Free

Top Up Card: 1%

Custody: 0.25% yearly

Withdrawal: 15bps

Deposit: No charge

Staking: 10% of the APY

Direct Buy/Sell: 1.5%

Execution Desk Buy/Sell: 2%

 

1.4.3 Safe money

The regulated money, also known as FIAT, held by the User on 2gether, is deposited with Pecunia Cards, EDE, an e-money institution that is regulated by the European Commission directive 2009/110 and continuously supervised by the Central Bank of Spain. Unlike banks, e-money institutions cannot lend or invest customer deposits and must have them available at all times.

The cryptocurrencies held in the ACCOUNTS will be deposited in the Kraken environment. 

 

2. Conditions of access and use of the service

 

2.1. Registration and operational conditions

 

2.1.1 Access to the Service
  • Cost. However, the use of the Service, Products and/or Pre-commercial Products made available through the Service may be subject to the payment of a fee and/or compliance with certain conditions and/or requirements, in the manner determined in the relevant terms and conditions of the relevant Service, Product or Pre-commercial Product, which shall be previously informed to the User and accepted by them.
  • Legal age to access the Service. In order to access the 2gether Services, the User must be of legal age, i.e. must be over 18 years of age.
  • Pre-registration. Access to and/or use of the Service requires prior registration by Users.

The steps to be followed and completed by a future 2gether User to access its services are as follows:

  • Downloading the mobile app. To register for the 2gether services, the User must download the application (available on Google Play and Apple Store depending on the characteristics of the mobile device). Once the application has been downloaded, the User must open it to start the registration procedure.
  • Access key. First, you will be asked for an email address, and a password or access key to access 2gether via the mobile application. Subsequently, a phone number, to send a security code and continue with the registration process.
  • Identification for obtaining the prepaid VISA card. The User will access an environment in which they will be asked for a photograph, both sides, front and back, of their National Identity Document, Passport or NIE card.

In this User identification procedure, 2gether acts as a third party vis-à-vis the VISA card issuer, which is Pecunpay.

  • User identification procedure.

2gether, acts as a service provider to Pecunpay.

2gether thus provides, through the referenced procedure, what is necessary for the execution of the digital signature of the contract. The copy of the contract will be registered electronically by 2gether. Once the user proceeds to accept the conditions set out in the contract, this event will also be recorded electronically by 2gether.

On completion of the process, 2gether will send both parties the electronic certificate accrediting the contract.

The mechanisms provided by 2gether for the Signatory Client Recipient to complete the digital contracting process are as follows:

  • One-time password / URL link (OTP) sent by SMS or Email. Identification procedure by capturing a Selfie (Recipient’s Facial Photograph).
  • Identity validation procedure by capturing images of identity documents. (OCR / MRZ validation).
  • Payment settlement procedure, by bank card payment or SEPA mandates.
  • Streaming video identification for the capture of the documents and the explicit consent of the client.

 

  • Legal safeguards for the identification procedure:
    • The electronic signature of 2gether shall have full legal validity for Pecunpay, in accordance with Law 6(2020) and the Eidas Regulation.
    • Pecunpay has appointed 2gether as the Commercial Agent in charge of negotiating and/or concluding the purchase/sale transaction and/or provision of services with the Customer or User. 2gether being thus responsible for the processing of all charges established by Pecunpay and accepted in full by the Customer or User, who hereby authorises 2gether to debit each payment to the cards or bank accounts indicated therein.
    • 2gether, as the onboarding service provider within the procedure, is responsible for the issuing and custody of the electronic certificate for a period of 5 years, a document that accredits the procedure.
    • 2gether is a data processor in accordance with the provisions of Articles 28 et seq. of Law 3/2018 of 5 December 2018 on the Protection of Personal Data and the guarantee of personal digital rights and with the General Personal Data Protection Regulation of the European Parliament and of the Council 679/2016.
  • Terms of Use and Privacy Policy. Before continuing to enter data, the User must read and accept, expressly, freely and unequivocally, the 2gether Terms of Use and the Privacy Policy for the processing of personal data by 2gether.
  • Acquisition of 2GT. The User may, if they wish, acquire tokens issued by 2gether called 2GT, for a minimum amount of 200 2GT. The User will be free to acquire more 2GT, but this is the minimum amount to access some of 2gether’s premium products, services or benefits (e.g. Physical Card). Subsequently, after payment, subject to the refund policy specified in its corresponding section, the user will sign a contract for the acquisition of the tokens, namely a Simple Agreement on Token Futures – 2GT Token (hereinafter referred to as SAFT), of which its general, but not the only, specifications can be found in the Terms and Conditions of Use of the 2GT Token Service. In any case, the terms and conditions of 2GT token acquisition will be regulated in the SAFT. 
  • Prepaid VISA card delivery details. The User enters the shipping address of the prepaid VISA card. This product is not available for services that do not reach the minimum Founders membership (200 2GT). Delivery of the physical card may be subject to the fulfilment of other conditions. 
  • Diligent use of access keys. The User must use the access codes, in accordance with the instructions indicated by 2gether on the Website and the Application in each case (hereinafter, the «access codes»). These access codes may be modified, suspended or revoked, as a whole, due to consequences arising from the Service, and in any case the User shall be informed thereof.

In any case, the User agrees to make diligent use of the access codes and to keep them secret and not to transfer them, as well as to notify the loss or theft of the access codes as soon as possible, so that they can be deactivated. In any case, the User shall be liable for the consequences of any kind arising from the use of the Service by a third party using the User’s access codes for this purpose until, where applicable, the User has requested the deactivation of said access codes, unless the User has acted with intent or negligence.

  • Registration. Once registered on the relevant Service, through the 2gether mobile application, 2gether will confirm the User’s registration.
  • Termination. 2gether informs that any user may unsubscribe from the Service, through the specific procedure detailed in the Application. Should the user have any problem in processing the unsubscription in the environment provided by 2gether, they may contact 2gether to carry out such unsubscription, using the contact details set out in the heading of these General Terms and Conditions of Use. For any questions, the user may contact 2gether by e-mail at support@2gether.global.

Before initiating the unsubscription procedure, the user shall transfer from their accounts hosted in 2gether (whether FIAT money or cryptocurrency) the balances and amounts held by them to other accounts, whether bank accounts or cryptowallets, outside the 2gether environment.

Non-acceptance of these Terms and Conditions implies the impossibility to access the App. In the case of non-acceptance in which the user is already registered, and has positions in EUROS or CRYPTO, the user must provide an IBAN of his/her ownership, or one/some cryptowallets (also of his/her ownership), in order to have these funds transferred outside the 2gether environment, which will entail the charging of commissions indicated in the section dedicated to these.

2.1.2 Operational Conditions of Service

 

Given the operation of the Services offered, specified in point 1.4.1, the User, when contracting them, is aware that, as will be specified in the Terms and Conditions of Use of each Service provided by 2gether, they will be subject to certain conditions and limitations of operation of each of the Services.

 

2.1.3 Correct use of the Service: Obligations of the User
  • User commitment. The user agrees to:
    • Use the service in accordance with the law, with the General Conditions of Contract and with the Legal Notices published on the Website and the Application Conditions, where the Service is offered, with the present General Conditions of Use of the Service, and of each of the Services, generally accepted good customs, practices and morality and public order.
    • Use the service properly, in accordance with the purpose for which it has been made available to you.
    • To keep the account active through the use of the products and services offered by 2gether. In this regard, an account shall be considered inactive if no user activity is recorded for a period of three months. In this regard, 2gether will contact the user to manage the cancellation of the business relationship.
  • Prohibitions of use. For these purposes, by way of example, but without limitation, the User agrees not to use the Service, Products, Pre-commercial Products or New Versions thereof for:
    • Advertising and/or sale of other products or services;
    • Increasing traffic to other websites for commercial purposes, advertising sales or any other purposes;
    • Restate questions and answers posed by 2gether and/or other Users and/or third parties, to display or duplicate portions of the Service on your website or other third-party websites;
    • Establish links between the Service and your website or other third party websites or use the Service or the Websites where they are offered in «meta-searches».

By using the service, the User agrees to:

  • Not interfere or attempt to interfere with the proper functioning of the service.
  • Respect the intellectual and industrial property rights of the products and services of 2gether, as well as those of third parties to whom access is provided.
  • Not to use the services provided by 2gether in a manner that infringes any law, nor to damage or violate the intellectual or industrial property rights of 2gether or third parties.
  • Not to use the Service and the Products for spamming, or in contravention of Spanish, European and other applicable laws regarding commercial mass mailing or advertising by electronic means.
  • Prohibition of commercial use. 2gether provides the Service to Users for their exclusive personal use and may not be used for commercial purposes. If the User wishes to use any portion or part of the Service and/or the Products and/or Precommercial Products and/or New Versions of Commercial Products for commercial purposes, they must obtain the prior express consent of 2gether and of the owners of the Products and/or Precommercial Products and/or New Versions thereof. Any use of the Service and/or the Products and/or the Pre-Commercial Products and/or their New Versions (i) infringes the intellectual property rights of 2gether and/or its relevant licensors or (ii) is used for commercial purposes, 
  • Use of the 2gether Service. The user is authorized to use the 2gether service for the duration of the business relationship and in accordance with the Terms and Conditions set forth, which are accessible at all times. In case of modification of the Terms and Conditions, 2gether shall announce the changes for the review and approval of the users.
  • Intellectual and industrial property of 2gether. Both the content and the software of the Service, the Products and the Pre-Commercial Products and their New Versions are the property of 2gether and/or their owners, and are protected by Spanish and/or European and/or international intellectual property protection regulations. For this reason, the User agrees not to use the Service or the Products, or the Pre-Commercial Products, or their New Versions for illicit purposes or purposes that may damage the rights of third parties or that, in any way, may damage or deteriorate the Service, the computer equipment, the property, as well as the image of 2gether and/or its owners, other Users or third parties.

By way of example, but without limitation, the User agrees to:

  • Not use the Service, the Products and/or the Pre-Commercial Products and/or New Versions thereof to store, distribute or disseminate images, content or comments that (i) attempt or may attempt to infringe fundamental public rights and freedoms; (ii) incite violence or criminal acts; (iii) advocate terrorism; (iv) are defamatory or libellous; (v) are discriminatory on the basis of sex, race, age, creed or status; (vi) are pornographic, degrading, infringes on minors or is generally contrary to the law, morality or decency; (vii) are pornographic, degrading, infringes on minors or is generally contrary to the law, morality or decency; (v) are discriminatory on the grounds of sex, race, age, beliefs or condition; (vi) are pornographic, degrading, attack minors or, in general, are contrary to the Law, good customs or public order; (viii) infringe the intellectual or industrial property rights of third parties, without having previously obtained their authorisation; (ix) are contrary to personal and family privacy or to the person’s own image.
  • Not copy, reproduce, alter, modify, create derivative works or publicly display any of the Services, Products, Pre-Commercial Products and/or New Versions.
  • Not use robots, spiderbot or other automated devices or manual processes to monitor or copy any of the Services, Products, Pre-commercial Products and New Versions offered through the Service; or the Service itself.
  • Exclusion of liability. In no event shall 2gether be liable for personal injury, loss of profit or consequential or other damages, including merely informative and non-limiting damages for loss of profit or data, business interruption or any other type of damages or commercial losses, resulting from or related to the use or misuse of the Service, regardless of whether it was created and whether it responds to contractual liability, tort liability or unlawful acts. The User assumes all responsibility deriving from the use or misuse of the Service, expressly exonerating 2gether from all responsibility deriving from the use or misuse of the Service, before any person or authority. 
  • 2gether may, without prior notice and at any time, suspend and/or expel from the Service a user who repeatedly manifests inappropriate behaviour in the use of the Application or breaches these Terms and Conditions. Consequently, it reserves the right to disconnect or suspend access to the Application to those users whose behaviour or use of the Application goes outside the parameters of good use published or established by 2gether.
  • 2gether may also suspend the Service, temporarily or permanently, without prior notice when there are objectively justified reasons relating to the security of the User or suspicion of fraudulent use of the Service. The User shall be notified of this blocking or suspension, provided that it is not compromised for justified security reasons.
  • 2gether reminds users of the Services that, in accordance with its duty to cooperate with the public authorities, it will provide the data of its users and of the Content of the Application to public authorities who require it for the investigation of a misdemeanour or crime.

 

2.2 Liabilities and Guarantees

  • User liability. The User is aware and voluntarily accepts that the use of the Service, the Products and/or the Precommercial Products and/or their New Versions is carried out, in any case, under their sole and exclusive responsibility. The User is therefore solely responsible for all matters relating to the use of the Service, the Products, the Pre-commercial Products and their New Versions. In particular, the User is aware that the use of the Service, the Pre-commercial Products and/or their New Versions may require compliance with a number of technical requirements, as well as the installation of certain software.
  • Disclaimer of liability. 2gether cannot control how the User uses the Application. Therefore, it cannot guarantee that the User does so in accordance with the law, the current Terms and Conditions or any other regulations or conditions indicated. With respect to services offered by third parties, 2gether presents them as provided by the provider and assumes no responsibility with respect to such services. It is the user who declares to have knowledge of the service provided and shall use them at their own risk.
  • Responsibility of 2gether.
    • 2gether is exempt from any liability that may arise, for the User and/or its technical team, from the answers given by other Users on the Services, Products and Pre-commercial Products and/or their New Versions available for the Website or the Application.
    • 2gether is exempt from any liability that may arise from the User’s use of the Service and/or the User’s use of the Products, Pre-commercial Products and their New Versions, as well as any possible technical difficulties or damage that your equipment may suffer as a result of their use.
    • 2gether is exempt from any liability that may arise from the use of its property, as well as from possible technical difficulties or damage that the User’s equipment may suffer as a result of its use.
    • 2gether may claim from the User, through the established legal channels, compensation for damages for improper use of the Services, Pre-commercial Products and/or their New Versions, or for use in contravention hereof, for which the User shall be primarily liable.
    • 2gether does not guarantee the availability and continuity of the operation of the Service, nor does it guarantee its usefulness for the performance of a specific activity. 2gether shall warn Users, as far as possible, of possible interruptions to the Service.
    • 2gether does not guarantee the availability and continuity of the operation of the Products and/or the Precommercial Products and/or their New Versions of its property, nor does it guarantee the usefulness of the same for the performance of a particular activity.
    • 2gether shall warn Users, as far in advance as possible, of possible interruptions to the Service, the Products and/or Pre-commercial Products and/or their New Versions.

 

2.3 Advertising in the Service

The User is aware that the Service, the Products and/or Pre-commercial Products and/or their New Versions may, if applicable, include advertising, provided that the User accepts it freely and voluntarily.

 

2.4 Transmission, dissemination and delivery of messages and files to third parties

User Identity. To access 2gether services, and in particular, to access the VISA prepaid card, the User shall upload a personal image and a photo of their identification document. 2gether, in accordance with the following clause, guarantees that the personal data will be processed by 2gether in accordance with the legislation in force and applicable to the protection of personal data in Spain and in Europe, at any given time, when the User is using the Service or registered on the Service.

Point 2.1.1. of these Terms and Conditions specifies that 2gether acts as a trusted third party of the VISA card issuer, Pecunpay, and details the procedure to be followed and all its legal guarantees.

 

3. Personal data protection

 

  • Legislation. 2gether respects the confidentiality of the personal data provided by Users of the Service, as well as the treatment and processing of the User’s personal data, through compliance with current data protection regulations, specifically the regulations and stipulations contained in the General Data Protection Regulation 2016/679 («GDPR»).
  • Explicit consent. The Users, by completing the form, also accept and authorise 2gether to use the personal data provided in the corresponding web registration form and in the application for the provision of the Service, and have read and expressly accepted 2gether’s Privacy Policy, as well as the Terms of Service or, where applicable, the corresponding Product; and have given their unequivocal and express consent to the processing of their personal data in accordance with the purposes of the Service and the Product in question.
  • Purposes, legitimacy, recipients and rights. The purposes of the processing of personal data by 2gether, the legitimacy of 2gether to do so, the existence of third parties receiving the personal data, as well as the exercise of the user’s rights of opposition, rectification, access, deletion / cancellation, limitation of processing and portability, are included in the 2gether Privacy Policy that the User must accept to access the use of the service and the products regulated in these legal conditions of use.

Prior acceptance. The User may not access, register with or use the services provided by 2gether unless they have previously given their free, express and explicit consent to the 2gether Privacy Policy.

 

 

4. Industrial and Intellectual property

 

  • Industrial and Intellectual property rights of 2gether. 2gether warrants that it owns or has acquired the rights (i) in the Service – both the Service’s web pages and mobile applications and the other tools and functionalities incorporated in the Service; (ii) in the Products; (iii) in pre-commercial products; and (iv) in the New Versions of Pre-commercial Products; all except those programs that are owned by third parties or are in the public domain.

Furthermore, 2gether warrants that it owns or has the rights to use the trademarks appearing on the Service. Therefore, 2gether retains all the aforementioned rights. The use that the User may make of them is limited exclusively to the purpose for which they have been made available in accordance with the provisions of these Conditions. Thus, any use of the Service, the Products and the Pre-commercial Products (such as, but not limited to, reproduction, modification, alteration or distribution thereof) is strictly prohibited.

  • Prohibitions. No material (software or trademarks) may be copied (except a private security copy) modified, altered or distributed without the prior authorisation of 2gether and/or its corresponding owner.
  • User information. Since the Service offers the User many opportunities to participate, actively, by providing ideas, comments, suggestions, information, solutions to technical problems and any other type of information (collectively «Information»), 2gether has the right to preserve and use such Information, both in the Products and Pre-commercial Products and in their New Versions and in other products or Services (whether current or future), without providing any compensation to the User.

To the extent that this information may be covered by intellectual property protection laws, the User (i) guarantees that they will cooperate with 2gether, to the extent necessary to obtain such protection, if so desired and (ii) the User agrees to assign their rights to the aforementioned information to 2gether. In the same way, 2gether may share generic information (dissociated, non-personally identifiable data, and therefore data not considered to be of a personal nature) provided by any User, with business partners and other third parties.

 

5. Modification, suspension and/or withdrawal of service

 

2gether reserves the right, at any time and without prior notice, to:

 

  • Modify the presentation and configuration of the Service and / or the conditions required to access and / or use them, in order to adapt it to technical developments, being able to introduce variants thereof that segment the market or that incorporate new services and / or content both free and paid, as well as any technical improvement that allows to incorporate a greater number of services, in order to improve the Service; 2gether may, but is not obliged, to inform users about these new modifications in order to improve the User Experience and improve the use of the Services for the User. Generally, 2gether will give notice, as soon as possible and on a non-mandatory basis, via mobile application or via e-mail, of all changes to the Service. The only requirement will be, where appropriate, the publication of the modification.

 

  • Suspend and / or withdraw access to the Service to those users who do not comply with the provisions of these Terms. In the event of the suspension or withdrawal of the Service when users have positions in EUROS or CRYPTO, users must provide an IBAN of their ownership, or one or more cryptowallets (also of their custody), in order to have these funds transferred outside the 2gether environment, which will entail the collection of commissions as indicated in the section dedicated to these. 

 

  • In the case of users whose accounts have been blocked for irregular operations that do not comply with current regulations on the Prevention of Money Laundering and the Financing of Terrorism, the user must provide the information requested in the form of proceedings, in order to verify the legality of the operations carried out. In case of failure to do so, these accounts will be liquidated within one year (in EUROS) and will pass into the custody of 2gether until the requested information is provided.

 

6. Prevention of money laundering, terrorist financing and potential fraud

In compliance with Law 10/2010 on the Prevention of Money Laundering and Financing of Terrorism, of 28 April, and its regulatory developments, as well as the applicable directives, as a service provider for Pecunpay, 2gether shall apply the due diligence measures required by said Law in its art. 3 and 5, and may refrain from initiating the business relationship or executing any transaction if it cannot comply with the provisions of art. 7.3 of said law. For the sake of greater transparency it is established:

  • Prohibition. By accepting these Conditions, the User declares that they are not involved in any illegal activity of money laundering or financing of terrorism, or any other form or type of fraud. In the event that the User uses, directly or indirectly, the 2gether Services and Products for this type of illegal activity, it shall be understood that this is contrary to the correct and authorised use of the Service provided by 2gether, which may cancel the Service and the Products used by the User, and shall proceed in accordance with the provisions of the aforementioned regulations.
  • Prevention. The User agrees to answer the questions asked by 2gether and to provide the documentation required to comply with the application of due diligence measures for compliance with current legislation and regulations on the Prevention of Money Laundering and Financing of Terrorism at any time and within the framework of the internal policy established by 2gether.

This shall also apply in cases where any other type of fraudulent conduct constituting a criminal offence has occurred or is suspected, including as a preventive measure.

  • Monitoring. 2gether may temporarily block funds and/or interrupt exchange operations, for the duration necessary to carry out an effective monitoring of the operation in accordance with the requirements of the Law. The user must actively collaborate and provide the information required for the application of the appropriate due diligence measures.
  • Third parties. The third party that provides 2gether with the VISA prepaid card and IBAN, namely Pecunpay, complies with all current legislation and regulations on the Prevention of Money Laundering and Financing of Terrorism. 2gether, in turn, operates as a trusted third party for Pecunpay, being responsible for applying due diligence measures for each new User who acquires a VISA prepaid card and IBAN.
  • Politically Exposed Persons (PEPs). The User who registers and accesses the 2gether Services declares, by accepting these General Terms and Conditions of Use, and all the Terms and Conditions of each of the Services provided by 2gether, that they are not a Politically Exposed Person, in accordance with the legislation in force concerning the Prevention of Money Laundering and the Financing of Terrorism.
  • In the case of users whose accounts have been blocked for irregular operations that do not comply with current regulations on the Prevention of Money Laundering and the Financing of Terrorism, the user must provide the information requested in the form of proceedings, in order to verify the legality of the operations carried out. In case of failure to do so, these accounts will be liquidated within one year (in EUROS) and will pass into the custody of 2gether until the requested information is provided.

 

7. Duration of the service

 

The provision of the Service is, in principle, for an indefinite period of time. The products currently available do not have a specific and defined duration either, but will depend on the decisions taken by 2gether to maintain them or to openly launch new definitive products and services on the market.

However, 2gether reserves the right to suspend or terminate the provision of the Service at any time. Termination or suspension of the Service for reasons beyond the User’s control shall be communicated by 2gether to the User as soon as possible.

 

8. Territoriality

 

Use of the Service is expressly limited to the countries of the Euro zone and to Andorra, Monaco and San Marino only. 

2gether reserves the right to apply the necessary technologies to ensure that the use of the Service by the User takes place exclusively within the European territory.

2gether reserves the right to extend the provision of the Service to other areas of the planet. The territoriality of the Service shall always be stated in the Terms of Service.

 

 

9. Applicable law and jurisdiction

 

For the resolution of disputes that may arise from these General Terms and Conditions of Use of the Service, the User expressly agrees to submit to the jurisdiction of the Courts and Tribunals where 2gether has its registered office in Spain, expressly waiving any other that may be legally applicable.

Any dispute must be resolved in accordance with the provisions of this document, which shall be interpreted in accordance with Spanish law, the user expressly acknowledging that it is applicable to this document and the use of the service.

 

10. Complaints and claims

 

Users may send 2gether their complaints, claims or any other comments they may wish to make via the contact details provided at the beginning of these General Terms and Conditions of Use of the Service via email: support@2gether.global or via the contact details detailed in the heading of these General Terms and Conditions of Use.

In addition, 2gether has official complaint forms available to consumers and users, which they can request from 2gether at any time, using the contact details provided at the beginning of these General Terms and Conditions of Use of the Service.

Furthermore, if a dispute arises from the Use of the 2gether Services by the User, the User as a consumer may request an out-of-court settlement of disputes, in accordance with EU Regulation No. 524/2013 of the European Parliament and of the Council of 21 May 2013 on the settlement of consumer disputes online. You can access this method via the website: http://ec.europa.eu/consumers/odr/ .

 

Terms and Conditions | Contact for the use of VISA prepaid card, transfer and ATM services

 

These specific Terms and Conditions of Use regulate the use of the prepaid VISA Card service, transfers and cash withdrawals from ATMs, however, they are in any case a complement to the General Terms and Conditions of Use of the 2gether Service, which complement the present in their strictest sense and must be interpreted continuously and in all cases.

 

 

Transfers

The User may make transfers in regulated currencies (hereinafter referred to as FIAT), in particular EUROS. Transfers in FIAT currency, for the time being in EUROS, are made via a shared IBAN. The shared IBAN, and the VISA Prepaid Card, are subject to the restrictions detailed in the Provider’s Conditions of Use ( Pecunpay ).

  1. Transfer operations. Transfers can be made by the User in the wallet environment for the Euro account. From the mobile application, in the wallet environment of the Euro account, the User may deposit and send money transfers in FIAT currency, namely EUROS.

To send the transfers, the User will select Send, choose the desired amount, always within the limits established in these Terms and Conditions, and fill in the required details of the destination. Subsequently, a confirmation code will be sent via SMS to carry out the transfer.

In order to deposit into their Euro account wallet, the User shall indicate the desired amount within the limits set out in these Terms and Conditions, and shall fill in the required details and proceed by using a bank card.

The User will be able to send transfers, which can be made in two ways: (1) by indicating the destination IBAN of the account to which the money is to be transferred and (2) if it is a transfer to a 2gether User, by indicating in the list of contacts, within the 2gether environment in the Application, the user to whom they wish to send money.

  1. Use contact. 2gether reminds the User that these transfers are subject at all times to the Terms and Conditions of the issuer of the shared IBAN, Pecunpay. If any term or condition is doubtful or not regulated in these Terms and Conditions, the provisions of the Pecunpay Terms and Conditions of Use, which can be consulted here: https://www.pecunpay.es, shall prevail.
  2. Limitations. As set out in the General Terms and Conditions and in these specific Terms of Service, card transactions are subject to the limits established by 2gether and set out below.

In the event of termination. Before initiating the termination procedure, the user shall transfer from his/her accounts hosted in 2gether (whether FIAT money or cryptocurrency) the balances and amounts held by them to other accounts, whether bank accounts or cryptowallets, outside the 2gether environment. If any amount of FIAT money remains in the user’s account, 2gether, once the user requests cancellation of the Service, will contact the user in order to proceed appropriately and deposit the remaining money in the bank account indicated by the user. For any questions, the user may contact 2gether by e-mail: support@2gether.global.

 

Prepaid VISA card

  1. Registration and obtaining the card. Once the User has completed registration on the 2gether application, as set out in the General Terms and Conditions of Use, the User will have the possibility to request a card and will provide a postal address to receive the VISA Prepaid Card (hereinafter the «Card», «Prepaid Card») at the address indicated. It shall also be possible to request a virtual card, which shall be used via the 2gether application itself. It will also be possible to apply for a virtual card, which will be used through the 2gether application.The delivery time of the card will depend on the courier service contracted and 2gether cannot offer the User any specific period of time to receive the card.
  2. Activation and Use. Through the application, the 2gether User, and once the User receives the card by post at the address indicated or has the card in the application, will be able to activate or deactivate the Card, request a PIN code, or link the payments of their Card to any of the accounts that the User has.
  3. PIN and Access Keys. The User is responsible for saving and memorising their PIN and shall have the same diligence and obligations as those established for access codes in the General Terms and Conditions.
  4. Linking Accounts. The User is aware that if they link their Card to a cryptocurrency account and make a payment when there is no amount in any of these cryptocurrency accounts, the payment will be declined.
  5. Limitations. As set out in the General Terms and Conditions and in these specific Terms of Service, card transactions are subject to the limits established by 2gether and set out below.
  6. Conditions of Use. 2gether reminds the User that the Use of the Card shall at all times be subject to the Terms and Conditions of the issuer, Pecunpay. If any term or condition is doubtful or not regulated in these Terms and Conditions, the provisions of the Terms and Conditions of Use of Pecunpay, which can be consulted here: https://www.pecunpay.es, shall prevail.

 

Use of the card

  1. The card is a prepaid debit product that can be used to pay for goods and services at retailers displaying the card scheme symbol. To use the card, present it at the time of payment. You can use it to pay for part or all of your purchase.
  2. The card can also be used to make online purchases. 2gether is not responsible for the payment platforms set up by online shops or websites selling products and services.
  3. 2gether will not charge any fees for recharging its available card. However, at a later stage and with prior notice to the customer, 2gether may apply fees for recharging and using the card.
  4. When the User receives their card, they must use the 2gether mobile application to activate the card.
  5. If any purchase made by the User exceeds their available funds or the transaction limits set out in the General Terms and Conditions and these Terms, the transaction will be rejected.
  6. The User can use the card to make purchases in-store, over the Internet or by telephone. The card can be used to obtain cash through ATMs. It is also not a guarantee card or credit card. There is no interest on funds loaded onto the card. The User must not use the card for any illegal purpose.
  7. 2gether may stop, suspend or restrict your card or PIN for reasonable grounds related to:
    • The security of the card, card number or PIN, and
    • suspicious unauthorised or fraudulent use of the card or PIN. 2gether will inform the User if possible, before stopping, suspending or restricting their card or PIN and the reasons for doing so. If 2gether does not inform the User then, it will inform them immediately afterwards. The requirement to inform them does not apply when it compromises reasonable security measures or if it would be unlawful to do so.
  8. 2gether is not responsible for the quality, safety, legality or any other aspect of the goods or services purchased with the card. 2gether is not responsible for the fact that a merchant has not accepted the card.
  9. We will not issue the card under these terms and conditions to any person under 18 years of age.
  10. The Terms and Conditions of Use of the Card, in any case, are regulated by the issuer of the Card, Pecunpay, which you can consult here: https://www.pecunpay.es.

 

Cash withdrawals at automated teller machines (ATMs)

 

  • Operational. The User, with their prepaid VISA card provided by 2gether and issued by Pecunpay, will be able to access the ATMs of other banks that will be indicated to them for cash withdrawals.

This cash that will be available for withdrawal will be that which is in your Euro account, in the 2gether Euro Account environment. The user must follow the instructions at the ATM to make the withdrawal. This may involve entering the Card PIN.

2gether does not charge the User for cash withdrawals at ATMs. However, 2gether is not responsible for the fees that each bank may charge the User for cash withdrawals from its ATM.

2gether is not liable in the event that the ATMs selected by the customer do not work properly or do not have cash available.

  • Limitations. As set out in the General Terms and Conditions and in these specific Terms of Service, card transactions are subject to the limits established by 2gether and set out below.
  • EUROS. The User may only withdraw cash in EUROS. In the event that the User wishes to withdraw cash in another currency, the exchange rate of the ATM issuer will be applied, in addition to the costs that may be incurred in these operations, which will be passed on to the User.

If the user chooses to withdraw money using the currency conversion offered by the ATM owner, 2gether has no liability to the user for that currency conversion. Please note that the ATM provider may, in addition, charge its own fee for withdrawals from ATMs over which 2gether has neither control nor responsibility.

 

Notifications of card and account movements

Once the User has successfully logged in, 2gether will notify the User by means of a notification in the application of the movements made by the User with their accounts, whether transfers, payments with the Card or cash withdrawals at ATMs.

User responsibility for transfers, use of prepaid VISA card, cash withdrawals at ATMs

  • The User warrants that they are an individual acting solely on their own behalf and that they are acting for a purpose other than that of a trade, business or profession.
  • If the User believes that a transfer made, a transfer received, cash withdrawal at ATMs and/or purchase with the prepaid VISA card (hereinafter referred to as the card, or the VISA card) has been executed incorrectly or has not been authorized by the User, the User shall inform us as soon as possible via email: support@2gether.global. If the User fails to notify 2gether immediately at the moment they become aware of the occurrence or within 60 days from the date of the transfer made, a transfer received, cash withdrawal at ATMs and/or purchase with the unauthorized or incorrectly executed prepaid VISA card, they shall lose their right to correct the problem.
  • When it is proven that the User did not authorize a transfer made, a transfer received, ATM cash withdrawal and/or purchase with the prepaid VISA card, or that 2gether initiated or executed incorrectly (provided that 2gether can prove that an incorrect transaction has been made) and the User has notified 2gether in a timely manner within 13 months after the date of the transfer made, a transfer received, cash withdrawal at ATMs and/or purchase with the prepaid VISA card, unless the following Clause applies, 2gether will refund the amount improperly transferred or transacted at the earliest opportunity.
  • The User shall be liable for all losses incurred with respect to a transfer made, a transfer received, the withdrawal of cash at ATMs and/or purchase with the prepaid VISA card made by 2gether not authorised by the User, if the User has acted fraudulently, or has intentionally or by gross negligence attempted to, has not complied with the obligations set out in the Clauses of the General Terms of Use relating to security or Diligence or has not notified us in time in accordance with the above Clause.
  • The User is responsible for all financial or other liabilities, incurred by 2gether, Pecunpay (acting as issuer of the Card), a 2gether User, or a third party, caused by their breach of these Terms, their use of the 2gether Services and any use of their 2gether account. The User agrees to reimburse 2gether, Pecunpay (acting as issuer of the Card), a 2gether User, or a third party, as applicable and if applicable, for these liabilities to the extent not prohibited by applicable law.
  • The User remains liable under these Terms with respect to all charges and other amounts incurred through the use of their 2gether Account at any time, regardless of termination, suspension or closure of their 2gether Account.
  • The User alone is responsible for understanding and complying with any and all laws, rules and regulations of their specific jurisdiction that may be applicable in connection with their use of the 2gether Services, including but not limited to those relating to export or import activity, taxes or foreign currency transactions. The User is independently liable to the State and its competent bodies for all tax obligations. 2gether shall not be responsible for the execution of tax obligations, nor for the calculation and transfer of taxes applied by the User.
  • The User shall be liable and shall assume damages, to 2gether, its external suppliers, its employees or agents who are authorized to act on its behalf without prejudice to any claim or demand (including legal fees) made or incurred by any third party, due to its breach of the General Terms and Conditions of Use and of each Service, for violation of any law and/or improper use of the 2gether Services.
  • Nothing in these Terms and Conditions of Use of the Service, whether General Terms and Conditions or specific to each Service, shall operate to exclude liability for death or personal injury or for fraud or fraudulent misrepresentation or for any liability which cannot be excluded or amended by law.

 

Responsibility of 2gether with regard to transfers, use of prepaid VISA card or cash withdrawals at ATMs

 

  • Except in cases where the User has acted fraudulently with respect to a transfer made, a transfer received, cash withdrawal at ATMs and/or purchase with the prepaid VISA Card that has not been authorized by the User, the User shall not be liable for what occurs after the User has notified 2gether, without delay, upon becoming aware of the loss, theft, misappropriation or unauthorized use of the VISA Card or the Mobile PIN or the Card PIN that relates to such losses. The User may notify us by email: support@2gether.global.
  • 2gether shall not be liable for defective or non-executed execution in connection with a transfer sent or received that we have made in accordance with a unique identifier that has not been provided by the User and that the User proves to be incorrect. However, we will make all reasonable efforts to recover the funds involved in that transaction and may charge the User for doing so, including passing on to the User any charges made by intermediary banks and/or the beneficiary’s bank for their assistance in the tracing process.
  • 2gether is not liable to the User for the correct execution of a transfer made, a transfer received, cash withdrawal at ATMs and/or purchase with the prepaid VISA card, if it can prove to the User (and where applicable, to the payment service provider of any beneficiary) that the payment service provider receives the payment within the appropriate time period. However, we will make efforts to trace any unexecuted or defectively executed payment transaction or any Transfer that has been properly executed to an account that is deemed fraudulent and we will notify the User of any results related to our search.
  • 2gether is liable to the User for the correct transmission of a payment order representing a Top-Up via a card saved by the User in his personal session within the 2gether application within the relevant time limit.

2gether shall not be liable to the User for:

  • Delay or failure to perform 2gether’s obligations under these Terms (including any delay in payment) due to any cause beyond 2gether’s reasonable control, including, without limitation, any action or inaction of the User or any third party, any Force Majeure Event, banking delay, postal delay, failure or delay of any facsimile or electronic transmission, any accident, emergency, natural catastrophe or any abnormal or unforeseeable circumstance;
  • Consequential or indirect loss (such as loss of profit or opportunity) that may be incurred by the User as a result of their failure to comply with the provisions in relation to the transfer service and all the Terms and Conditions of Use of the 2gether services.
  • Losses as a result of requirements imposed by Royal Decree-Law 19/2018 of 23 November 2018 on payment services or European Commission Directive (EU) 2015/2366 or European Commission Directive 110/2009 or 2gether’s obligations under the laws of any state of the European Union or any other jurisdiction under which 2gether operates.
  • In no event shall 2gether be liable for any lost profits or any special, incidental or consequential damages arising out of these Terms and Conditions of Use, the General Terms and Conditions, or otherwise in connection with the 2gether Services.
  • Furthermore, 2gether is not responsible for:
    • Any loss incurred by the User as a result of the travel insurance abroad.
    • Any loss incurred by the User as a result of the use of the prepaid VISA Card.
  • To the extent permitted by applicable law, 2gether is not responsible for, and the User agrees to be liable for, any damage or loss (including, without limitation, loss of money, goodwill or reputation, profits or other intangible losses) or any special, indirect or consequential damages) resulting directly or indirectly from:
    • The User’s inability to use the 2gether Services for any reason whatsoever;
    • Delays or interruptions in the 2gether Services;
    • Viruses or other malicious software obtained by accessing the website or any associated site or service;
    • Failures, errors or inaccuracies of any kind in the 2gether Services;
    • The content, actions or inactions of third parties;
    • A suspension or other action taken with respect to the User’s account on 2gether;
    • The User’s need to modify practices, content or behaviour, or its loss or inability to do business, as a result of changes to these Terms or 2gether’s policies;
    • Illegal actions and operations of third parties carried out with forged and/or illegal documents or illegally received data;
    • Of the possible losses that could arise in the event of not being able to execute the orders due to the blocking that 2gether could carry out for security reasons in the event of the detection of a suspicious transaction, the existence of reasonable doubts regarding the identity of the person carrying out the transaction or any other reason that could be an indication of fraud.

 

Limitations for transactions and transfers

 

  • Establishing limitations. 2gether reserves the right to impose, at its sole discretion, limits on transactions and transfers, according to criteria determined by us and which must not be disclosed and always in accordance with the provisions of current legislation relating to the Prevention of Money Laundering.
  • Current limitations. The limits for transactions are also detailed in the table below, which sets out the general limits for transactions with 2gether, as set out in the General Terms and Conditions of Use.
  • Card Payment (Sum of FIAT and Crypto)
    • 2.500 € (Daily Limit)
    • 15.000 € (Monthly Limit)
    • 90.000 € (Annual Limit)
  • ATM Withdrawals (Sum of FIAT and Crypto)
    • 300 € (Daily Limit)
    • 3.000 € (Monthly Limit)
    • 18.000 € (Annual Limit)
  • Deposits (Sum of FIAT and Crypto)
    • 5.000 € (Daily Limit) 
    • 30.000 € (Monthly Limit)
    • 150.000 € (Annual Limit)
  • Withdrawals 
    • 300 € (Daily Limit)
    • 3.000 € (Monthly Limit)
    • 18.000 € (Annual Limit)

 

Miscellaneous

  • Applicable Law and Jurisdiction. These Terms shall be governed by the laws of Spain and any claim or dispute under these Crypto Terms of Service shall be subject to the non-exclusive jurisdiction of the Courts of Spain.
  • Duty to inform. 2gether may report any illegal activity (or suspicious activity) carried out by the User or any other person to the police or other competent authorities, and cooperate with them in any investigation. 2gether may also require the reasonable cooperation of the User in any investigation that 2gether or an authority carries out into unauthorized use of its Crypto Services or any other service offered by 2gether.
  • Modifications. 2gether may make modifications to these Terms in accordance with the provisions of the General Terms and Conditions of Service.
  • Taxes. It is the responsibility of the User to determine which taxes, if any, apply to payments they make or receive, and it is their responsibility to collect, report and remit the correct tax to the appropriate tax authority. 2gether is not responsible for determining whether taxes apply to your transactions through all services offered by 2gether. It is the User’s responsibility to comply with any and all applicable tax laws in connection with your use of the Crypto Services and all Services offered by 2gether.
  • Transfer of rights. The User may not assign any right, interest or obligation they have under these Terms without the prior written consent of 2gether.
  • Right of correction. 2gether reserves the right, but shall have no liability, to edit, modify, refuse to post or remove any Vendor Content, in whole or in part, that in its sole and absolute discretion is objectionable, erroneous, unlawful, fraudulent or otherwise in violation of these Terms.

 

Terms and Conditions 2GT Tokens

 

 

Introduction

The field of cryptocurrencies has been regulated in Europe in the field of prevention of money laundering through the 5th Directive and is in the process of being regulated globally. 2gether will at all times comply with state regulations arising from the transposition of the European Directives on Payment Services, Electric Money or Money Laundering, but beyond these that affect cryptocurrencies or cryptocurrencies, it is important to note that these are not regulated in terms of their purchase, sale or price.

Any terms not defined herein shall be construed in accordance with the General Terms and Conditions of Service.  In the event of any conflict or inconsistency between our General Terms of Service; and these 2GT Token Terms and Conditions, the latter shall prevail and take precedence.

These Terms are independent of the General Terms and Conditions and of the specific Terms and Conditions of the 2gether Services when any dispute, failure, material or physical loss, or any other loss suffered by the User is the result of the transaction with 2GT tokens.

Notwithstanding the foregoing, the Terms and Conditions of the purchase of 2GT tokens by the User shall be governed by a bilateral contract, signed by the User and 2gether, Simple Agreement on Token Futures – 2GT Token (hereinafter referred to as SAFT). This SAFT shall regulate all conditions subject to the acquisition of 2GT tokens acquired by the User.

These Terms and Conditions explain and regulate the 2GT Token service, but the acquisition is solely governed by the SAFT that the User signed with 2gether. If there is a dispute between these Terms and Conditions and the SAFT, the contents of the SAFT shall prevail.

 

2GT Token

The 2GT token is an ERC20 token issued by 2gether.

  • Limited one-off issue. There will be a single issue of 2.4 billion 2GT tokens. No more tokens will ever be issued. The issue price of the token is €0.05.
  • Minimum acquisition of 200 2GT to become Founder of 2gether. When the user registers on the 2gether application, and after accepting all the legal terms for its acquisition and use, he/she will optionally acquire tokens issued by 2gether, called «2GT». The user will be able to acquire more 2GT, but it will always be a minimum purchase of 200 2GT. To acquire these 200 2GT and issue the payment, the User will have to link a credit or debit card to make the payment. This card will be saved in the 2gether application and can be removed from the cards saved in the application whenever the User wishes. The User may purchase 2GT by paying with Bitcoin or Ether. Furthermore, 2gether may gift Users who purchase a certain number of 2GT with an additional bonus of 2GT. This bonus will be defined by 2gether and the bonus amounts depending on the purchase of 2GT may vary according to the considerations adopted by 2gether.
  • Signing of the SAFT. After issuing the payment of the 200 2GT, amounting to a value of 10 €, the User shall sign a Simple Agreement on Token Futures – Token 2GT (hereinafter referred to as SAFT). This contract shall be of a bilateral nature and shall be signed by the User with 2gether. The SAFT regulates all the Terms of the 2GT purchase and the User shall be able to access it after making payment and having previously completed all the registration steps as specified in the General Terms and Conditions.
  • Return policy. The purchase of 2GT tokens, once made by the user, may not be returned. 2gether will refund the purchase of 2GT tokens only in the cases established by Spanish and European legislation for this type of transaction.

If the user meets any of the cases listed in the legislation for the return of the 2GT purchase, the user must contact the 2gether customer service department to proceed to process the return. In all cases, the user must bear in mind that any possible costs and commissions generated by the return shall be borne by the user, provided that the return is due to causes beyond the control of 2gether.

Once 2gether has approved the refund of the purchase of 2GT tokens, the refund will be made by bank transfer, within a maximum period of 30 days from the date on which the request has been received and the conditions for the refund have been verified.

Important information

  1. Prior information. The user must inform themself adequately and observe and comply with all applicable laws and regulations in the relevant country. Prospective purchasers of 2GT tokens and 2GT tokens issued and offered by 2gether must inform themselves about the legal requirements applicable to the purchase of 2GT tokens and 2GT tokens as well as the current exchange control regulations and taxes in their country of residence or domicile or their country of nationality.
  2. Exclusion of sale in the United States. The offer to purchase 2GT token rights and 2GT tokens has not been registered and will not be registered under the U.S. Securities Act of 1933, as amended or replaced, or under any state or federal securities laws, and the 2GT tokens and 2GT token rights have not been, and will not be, registered under the U.S. Securities Act of 1933, as amended or replaced, or under any state or federal securities laws, or under any state or federal securities laws, and the rights to 2GT tokens and 2GT tokens may not be offered or sold, directly or indirectly, in the United States of America, its territories or possessions, or any area subject to its jurisdiction («U.S.»), nor may they have any rights under the 2GT tokens or 2GT tokens in the United States of America, its territories or possessions, or any area subject to its jurisdiction («U.S.»). They may not be offered or sold, directly or indirectly, in the United States of America, its territories or possessions, or any area subject to its jurisdiction («U.S.»), nor may they be directly or indirectly to any U.S. person. 
  3. European Union. In relation to each Member State of the European Economic Area which has transposed into its legislation Directive 2003/71/EC of the European Parliament and of the Council of 4 November 2003 on the prospectus to be published when securities are offered to the public or admitted to trading, or which, pending such transposition, applies Article 3. 2 of the said Directive, the rights to the 2GT tokens may only be offered by means of the SAFT agreement that 2gether will enter into with the User in cases where the publication by 2gether of a prospectus is not required in accordance with the provisions of Article 3 of the said Directive. Likewise, in relation to each Member State of the European Economic Area that has transposed Directive 2014/65/EU of the European Parliament and of the Council.
  4. Announcements and Information. No intermediary, trader or person in any other capacity may issue any announcement, give any information or express any representation in connection with the sale of the rights to 2GT tokens or 2GT tokens without the prior written consent of 2gether and, in any event, if issued or expressed without such prior written consent, may not be relied upon as having been authorised by 2gether or its directors to make any decision on such information or representation.
  5. Cashback system with 2GT. 2gether reserves the right to grant cashback depending on the operation carried out by the user.
  6. Risk Factors
    • Investment in cryptoassets is not regulated, and may not be suitable for retail investors and the entire amount invested may be lost. It is important to read and understand the risks of this investment which are explained in detail at this location: https://www.2gether.global/files/riesgos.pdf .
    • These risks are subject to contingencies that may or may not occur and 2gether cannot express any opinion as to the likelihood that such contingencies will or will not occur. If any of the risks described in these Terms and Conditions were to materialize, it could have a serious effect on 2gether’s financial situation and results of operations, as well as on its ability to meet the obligations it assumes in the SAFT that it will sign with the User.
    • The risks and uncertainties explained below are those identified by 2gether at the present date, but these risks and uncertainties may not be the only risks and uncertainties to which 2gether is exposed. These other risks and uncertainties, including those of which 2gether is not yet aware, could have a serious effect on 2gether’s financial condition and results of operations, as well as on its ability to meet the obligations it assumes in entering into the SAFT with the User. Potential purchasers should also be aware that the risk may be amplified if various risk factors are combined.
    • The SAFT and any information contained in these Terms or provided in connection with the rights to 2GT tokens: (1) are not intended to serve as the basis for a creditworthiness or any other evaluation and (2) are not to be considered a recommendation by 2gether to the recipient hereof to purchase any rights to 2GT tokens or 2GT tokens issued by 2gether. Prospective purchasers should make their own independent assessment of all risk factors and carefully read all other sections of SAFT before entering into a contract.
    • 2gether cautions prospective purchasers that the projections and expectations contained in the SAFT and these Terms are associated with risks and uncertainties that could cause actual results and circumstances to differ from those expressed or that could be inferred from such projections and expectations, and that such projections and expectations do not bind 2gether with respect to future results. Further, there can be no assurance that future results or expectations will be achieved.
    • Risks related to the purchase of 2GT token entitlements. The purchase of 2GT tokens may not be suitable for all Users. Interested purchasers are recommended to consult with an independent investment advisor regarding the suitability of the purchase of 2GT tokens before making a decision to purchase. In particular, the potential investor should consult with an expert to determine whether:
      • They have sufficient knowledge and experience to make a proper assessment of the 2GT token rights, the benefits and risks of purchasing 2GT token rights and the information contained in the SAFT or any supplement thereto.
      • They have sufficient financial resources and liquidity to meet all the risks of a purchase of 2GT token rights, even if the currency is different from the currency used by the potential investor.
      • They fully understand the terms of the 2GT token rights and are familiar with the behaviour of indices and financial markets.
      • They are able to assess (on their own or with the help of a financial advisor) the possible scenarios related to economic, interest rate or other factors that may affect their purchase and their ability to cope with the corresponding risks.
    • Risks when buying tokens. The purchase of rights to 2GT tokens involves certain risks, including, but not limited to, the following:
      • Value of 2GT Tokens: The value of 2GT tokens may fluctuate upwards or downwards and past performance is not indicative of future results.
      • Nonexistence of previous markets: Prior to the issuance of 2GT tokens there has been no public market or trading history for 2GT tokens. Due to the non-existence of any prior market for 2GT tokens, there can be no guarantee that the issue price of 2GT tokens corresponds to the price at which 2GT tokens were traded in the market after their issuance.
      • Volatility: the cryptocurrency and token markets are generally volatile and susceptible to price fluctuations and these fluctuations can be significant, frequent and unexpected. The Company has no control over the events and circumstances that cause fluctuations in the cryptocurrency and token markets and, accordingly, purchasers are cautioned that their purchase of 2GT tokens is susceptible to the volatility that generally characterises these markets.
    • Orderly and liquid market: the existence of an orderly and liquid market for 2GT tokens depends on a number of factors, including the presence of buyers and sellers interested in buying and selling 2GT tokens at any given time and the general economic conditions in the market in which 2GT tokens are traded. These factors depend on the individual decisions of investors and general economic market conditions, over which the Company has no control. Accordingly, there is no guarantee that the investor will be able to trade or sell the 2GT Tokens at or above the initial purchase price or even that they can be traded or sold.

 

Terms and Conditions | Contact for the Use of Crypto Services

 

Introduction

 

Please read the following risk warnings carefully before agreeing to these Terms.

  1. Trading in goods and products, real or virtual, as well as virtual currencies, cryptocurrencies, or crypto-currencies (hereinafter any of the three meanings) involves significant risk. Prices can fluctuate on any given day. Due to such price fluctuations, you may gain or lose value in your assets at any time. Any currency, virtual or otherwise, can be subject to large swings in value and may even lose value. There is an inherent risk of loss as a result of buying, selling or exchanging anything in a market.
  2. Cryptocurrency exchanges also carry special risks that are generally not shared with official or regulated currencies (hereafter, FIAT) or goods or products in a market. Unlike most currencies, which are backed by governments or other legal entities, or by commodities such as gold or silver, cryptocurrency is a unique type of currency, backed by technology and trust. There is no central bank that can take corrective action to protect the value of cryptocurrency in a crisis or issue more currency.
  3. Cryptocurrencies are a global system of currency firms and individuals that is so far not autonomous and largely unregulated. Traders of such currencies rely on a digital, decentralised and partially anonymous system that relies on peer-to-peer networks and cryptography to maintain its integrity.
  4. Cryptocurrency exchanges are likely to be susceptible to bubbles, rational or irrational, and loss of confidence, which could collapse demand relative to supply.
  5. The price or value of cryptocurrency can rise or fall rapidly at any time and may even fall to zero. The risk of loss in trading or holding cryptocurrencies can be substantial and may result in the loss of your entire exposure.
  6. There may be additional risks that we have not foreseen or identified in these Terms and Conditions or in these risk warnings.
  7. The User should carefully assess whether his financial situation and risk tolerance are appropriate for any form of exposure to cryptocurrencies.
  8. Our banking providers do not transfer cryptocurrencies, exchange cryptocurrencies, or offer any services in connection with cryptocurrencies.

 

Crypto Services

 

Accounts. The User may trade on the unregulated cryptocurrency market through the Accounts provided by 2gether in its mobile application. The User, without leaving the environment provided by 2gether, will be able to trade on this market, but the deposit of his funds will be on the platform of a third party, KRAKEN .

Accounts

  1. Operational. The User may exchange cryptocurrencies on the 2gether application, or convert them into another currency using the functions provided by the 2gether application. The cryptocurrencies that can be purchased and stored on their 2gether account are limited to those set out in the General and Specific Terms and Conditions of each 2gether Service and shall be subject to changes that 2gether may deem at its discretion and of which it shall notify the User.
    • You will be informed, in the Control Panel of the 2gether application, before submitting your request to enter Accounts, of:
      • the amount of cryptocurrency you will use to purchase the required amount of cryptocurrency;
      • the amount and currency of the Cryptocurrency you wish to purchase;
      • the exchange rate of the platform where you trade with your Accounts, if applicable.
    • Confirmation. To submit the application to join the cryptocurrency exchange, you must confirm the details entered by pressing the exchange button in the corresponding part of the 2gether Control Panel. With these Terms, you accept sole responsibility for logging into the Accounts. 2gether shall not be liable for any loss you incur as a result of using this function.
    • Notification. 2gether shall inform the User, by means of a notification in the application, of the operation they have carried out on the Accounts.
    • Exchange rate or spread. 2gether shall establish an exchange rate that may be subject to change without notifying the user. Without prejudice to the fact that it may be modified when 2gether considers it necessary, the exchange rate or spread may be adapted according to exceptional market conditions (e.g. high volatility or currency liquidity).
  2. Acceptance. By registering with 2gether and using the Crypto services provided by 2gether, you acknowledge that:
    • You agree to these Terms and Conditions and the General Terms and Conditions of the 2gether Services.
    • You have the full capacity to accept these Terms and Conditions and to participate in a transaction involving cryptocurrencies;
    • You are a resident within the European Economic Area, Andorra, Monaco or San Marino;
    • You will not use the Crypto Services except for the purposes intended and not contrary to the general prohibitions with respect to your Account in accordance with our General Terms of Use; and
    • You are familiar with the nature and operation of the technology behind cryptocurrency and, in particular, the irreversibility of transactions and the apparent risks associated with exposure to cryptocurrencies.
    • By agreeing to these terms, you agree not to violate them.
  3. Activation. To access the Crypto Services, you will need to activate these services through the Mobile Application and by accepting Terms and Conditions, you will be able to manage your cryptocurrency accounts, within your Mobile Application. This can be done in the Crypto environment on the 2gether Mobile App.
  4. Access to Accounts. Once you have cryptocurrency available in your Accounts, you will be able to access the provided environment and trade on the cryptocurrency exchange.
  5. Changes to the Terms and Conditions. 2gether will notify users of 2gether of any future changes to these Terms and Conditions via the mobile application or by email.
  6. Technical and customer support. For more information about cryptocurrency wallets, please see our Frequently Asked Questions or FAQs. If you have any questions about these Terms and Conditions of Use, you can also contact 2gether via email at support@2gether.global.
  7. Available cryptocurrencies. The User may use the cryptocurrencies or cryptocurrencies currently on his 2gether account and may expose them on the Exchange. For more information on any of these cryptocurrencies, please see our Frequently Asked Questions or FAQs. Through the 2gether Dashboard, within the mobile application, the consumer will be notified when additional cryptocurrencies are added to the Crypto Services. 2gether may also communicate this via email.
  8. Exchange. 2gether provides the User with the possibility to enter into an environment where they can trade their investment coins or cryptocurrencies on a third-party cryptocurrency exchange, Kraken. The User’s cryptocurrency accounts will be deposited on Kraken’s own Exchange and the rules of the Exchange will be those of Kraken. 2gether only makes it possible to access the Kraken Exchange without leaving the 2gether mobile application. You can consult the Kraken Exchange Terms and Conditions here:

 

Transfers in crypto services

  • Transfers. The User will be able to transfer cryptocurrencies to other 2gether users within the mobile application. This will be done in the user’s account environment, where the user can Deposit or Send.
  • Limitations. All transfers, whether in cryptocurrencies or cryptocurrencies or in FIAT currency are subject to the limits set out in the General Terms and Conditions and in the Crypto Services Terms and Conditions. These limits are also detailed in the 2gether application when using the Crypto Services and before any proposed transaction is accepted.

 

Availability of crypto services

  • 2gether does not guarantee that the User will be able to obtain the requested exposure to a cryptocurrency at the time of his/her request.
  • 2gether does not guarantee the value of any cryptocurrency at the time of your application for exposure. 2gether provides the User with access to a third-party exchange, Kraken, from its application.
  • Crypto services are provided without warranty of any kind, either express or implied.
  • 2gether does not guarantee that the Crypto service will be available 100% of the time to meet your needs. 2gether shall endeavour to provide the User with the Crypto service as soon as possible, but there is no guarantee that access will not be interrupted, or that there will be no delays, failures, errors, omissions or loss of transmitted information.
  • However, 2gether shall make all reasonable efforts to ensure that the User can access the Crypto Services in accordance with the Terms and Conditions.
  • 2gether may suspend the use of the Crypto Services for maintenance and shall make reasonable efforts to notify the User thereof. The User, by accepting these Terms and Conditions, acknowledges that this may not be possible in an emergency.

 

Crypto service prices

  • Service Fees. Initially, there are no fees for the Use of the Crypto Service. 2gether may establish fees at a later stage of the Service upon prior notice to the User.
  • Exchange rate or Spread on the Exchange. Overall, it will establish the exchange rate that will be subject to change after prior notification to the user. The spread could be adapted following exceptional market conditions (e.g. high volatility or currency liquidity).
  • FAQs. For more information about our fees in relation to the Crypto service, please see our Frequently Asked Questions or FAQs.

 

Termination of terms and conditions of service

  1. 2gether may terminate these Terms and Conditions immediately at any time by informing the User via the application or via email.
  2. 2gether may immediately terminate these Terms and Conditions by written notice if:
    • The User commits a material breach of any of these Terms and (if such breach is remediable) fails to remedy that breach within 30 days after being notified in writing to do so;
    • The User repeatedly breaches these Terms in a manner that reasonably warrants a belief that the User’s conduct is inconsistent with the intent or ability to comply with the terms of these Terms;
    • The User uses the Crypto Services to commit any act of fraud or any other unlawful activity;
    • The User becomes bankrupt or goes through a similar event;
    • There is a legal obligation to do so;
    • The User dies;
    • If 2gether has reason to believe that the use of the Crypto Services by the User: damages, corrupts, degrades, destroys and/or adversely affects the Crypto Services or the 2gether Services, or any other software, firmware, hardware, data, systems or networks accessed or used by the User.
  3. As a subject obliged to prevent money laundering and the financing of terrorism, 2gether may block the activity of a user if they do not comply with the requested requirements. If they refuse to provide the requested information/documentation, the business relationship will be terminated.
  4. Termination of these Terms entails the withdrawal of your access to the Crypto Services and, depending on the nature of the termination, the closure of the User’s account with 2gether and the cancellation of the prepaid VISA Card. In such cases, 2gether, together with the Card Issuer, will deal with your remaining balance in accordance with the General Terms and Conditions of Service and the Terms of the prepaid VISA Card.

 

Financial Advice

 

For the avoidance of doubt, 2gether does not provide any investment advice in relation to the Crypto Services contemplated by these Terms and Conditions. 2gether may provide information on the price, range, volatility of certain cryptocurrencies and events that have affected the price of cryptocurrencies, but this is not considered investment advice and should not be construed as such. Any decision to gain exposure to cryptocurrencies offered as part of the Crypto Services is the User’s decision and 2gether shall not be liable for any loss suffered. If the User is unsure whether an exposure to cryptocurrency is financially suitable, he/she should contact an independent advisor.

 

 

Limitación de responsabilidad

  1. Nothing in these Terms and Conditions excludes or limits 2gether’s or the User’s liability for fraud (including fraudulent misrepresentation or concealment), breach of contract, intentional breach, negligence or any other liability which cannot be legally excluded or limited (including any liability in respect of death and personal injury resulting from our negligence, or that of our employees, agents or subcontractors).
  2. Any liability arising from a breach of these Terms and Conditions shall be limited to any loss or damage which is a reasonably foreseeable consequence of such breach and which arises directly from the actions of the breaching party. Neither party shall be liable for any loss of profits, sales business or revenue.
  3. 2gether is not liable to the User for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty or otherwise, arising out of or in connection with its:
    • use or inability to use the Website, the Mobile App or the Crypto Services;
    • use of or reliance on any content displayed on the mobile application, except where liability arises as a result of our breach of contract, negligence or fault.
  4. 2gether shall not be liable for any loss or damage which the User may suffer due to abnormal or unforeseeable circumstances beyond 2gether’s reasonable control which would have been unavoidable despite all efforts to the contrary, for example, delays or failures caused by problems with another system or network, any breakdown or failure of transmission, communication, data processing or computer facilities, mechanical breakdown, an act of state or government, war, riot or terrorism, any natural disaster, the suspension of any market, postal or other strike or similar industrial action or any prevention or hindrance in obtaining any material, power or other supplies necessary for the performance of our obligations under these Terms and Conditions.
  5. 2gether uses industry standard techniques to protect its website and mobile application free from viruses and attacks, but 2gether cannot guarantee that they are free from viruses or other malicious software. We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack or other technologically harmful material that infects your computer equipment, computer programs, data or other proprietary material due to your use of the Website or the Mobile Application or to your downloading of any content on it, or on any website linked to it.
  6. For the avoidance of doubt, if you have been the victim of fraud or an unauthorised transaction on your 2gether account, 2gether’s liability shall be limited to that set out in our General Terms and Conditions.

 

Customer service and complaints

 

  • Any complaints about 2gether or the services it provides should be addressed to the postal address detailed in the General Terms and Conditions or to the email address: support@2gether.global. The User must clearly indicate that they wish to submit a complaint to us. The 2gether complaints procedure sets out the process for submitting and resolving any complaint.
  • A final response to your complaint, or a letter explaining why the final response has not been completed, will be sent to you within 15 working days of the submission of your complaint and, in exceptional circumstances, within 30 working days. If this is not possible due to unforeseen circumstances or lack of information, we will contact you.
  • However, the user must bear in mind that, if the complaint is related to cryptocurrency trading, it is not regulated and, therefore, 2gether cannot guarantee any solution to your complaint beyond what is set out in these Terms and Conditions of the Crypto Service.

 

Limits for transactions and transfers

  • Boundary setting. 2gether reserves the right to impose, at its sole discretion, limits on transactions and transfers, according to criteria determined by us and which must not be disclosed and always in accordance with the provisions of current legislation relating to the Prevention of Money Laundering.
  • Current limits. The limits for transactions are also detailed in the table below, which sets out the general limits for transactions with 2gether, as set out in the General Terms and Conditions of Use.
    • Card Payment (Sum of FIAT and Crypto)
      • 2.500 € (Daily Limit)
      • 15.000 € (Monthly Limit)
      • 90.000 € (Annual Limit)
    • ATM Withdrawal (Sum of FIAT and Crypto)
      • 300 € (Daily Limit)
      • 3.000 € (Monthly Limit)
      • 18.000 € (Annual Limit)
    • Deposits (Sum of FIAT and Crypto)
      • 5.000 € (Daily Limit)
      • 30.000 € (Monthly Limit)
      • 150.000 € (Annual Limit)
    • Withdrawals (Sum of Cryptos)
      • 10.000 € (Daily Limit)
      • 30.000 € (Monthly Limit)
      • 150.000 € (Annual Limit)

Acceptance of 2gether as a trusted third party in the present process

 

The 2 parties (Sender of the Contract and Recipient Signatory Client) agree to the execution of this electronic signature contract, with a trusted third party, 2gether, acting as a trusted service provider.

Therefore, the Issuer shall provide the Customer with access to a copy of the contract. 2gether shall provide through this procedure what is necessary for the execution of the digital signature of the contract. Access to the copy of the contract shall be recorded electronically by 2gether. Once the user proceeds to accept the conditions set out in the contract, this event will also be recorded electronically by 2gether.

On completion of the process, 2gether will send both parties the electronic certificate accrediting the contract. The Sender has the certificate in the mailbox configured for them and/or in their 2gether client web panel. In the same way, the Signatory Client Receiver received the certificate at the email address they indicated during the digital signature procedure.

The mechanisms provided by 2gether for the Signatory Client Recipient to complete the digital contracting process are as follows, as requested by the Contract Issuer:

  • Identification procedure by capturing a Selfie (Recipient Facial Photograph).
  • Identity validation procedure by capturing images of identity documents. (OCR / MRZ validation).
  • Payment settlement procedure, by means of payment with bank cards or SEPA mandates.
  • Streaming video identification for the capture of documents and the explicit consent of the customer.
  • Electronic signature of the customer.

As a legal guarantee of this e-procurement procedure, the 2 parties agree as follows:

  • They accept the use of the 2gether electronic signature solution and agree that they will have full legal validity with it, in accordance with the provisions of article 3.10 of the current Electronic Signature Act.
  • Establish 2gether as the Commercial Agent appointed by the Issuer of the Contract, in charge of negotiating and/or concluding the purchase/sale transaction and/or provision of services with the Recipient. 2gether being thus responsible for the processing of all payments established by the Issuer of the Contract and accepted in full by the Beneficiary, who hereby authorises 2gether to debit each payment to the cards or bank accounts indicated therein.
  • They establish 2gether as the trusted third party within the procedure, being in charge of the issuing and custody of the electronic certificate for a maximum of 5 years, a document that accredits the procedure.
  • All the necessary data is provided to 2gether to provide the trust service and to issue and safeguard the electronic certificate, 2gether being considered a data processor in accordance with the provisions of articles 28 and following of Law 3 / 2018 of 5 December 2018, on the Protection of Personal Data and guarantee of digital rights.

 

Miscellaneous

  • Applicable Law and Jurisdiction. These Terms shall be governed by the laws of Spain and any claim or dispute uner these Crypto Terms of Service shall be subject to the non-exclusive jurisdiction of the Courts of Spain.
  • Duty to inform. 2gether may report any illegal activity (or suspicious activity) by the User or any other person to the police or other appropriate authorities, and cooperate with them in any investigation. 2gether may also require the reasonable cooperation of the User in any investigation by 2gether or an authority into unauthorized use of its Crypto Services or any other service offered by 2gether.
  • Modifications. We may make modifications to these Terms in accordance with the General Terms and Conditions of Service.
  • Taxes. It is your responsibility to determine which taxes, if any, apply to payments you make or receive, and it is your responsibility to collect, report and remit the correct tax to the appropriate tax authority. 2gether is not responsible for determining whether taxes apply to your transactions through all services offered by 2gether. It is the User’s responsibility to comply with any and all applicable tax laws in connection with your use of the Crypto Services and all Services offered by 2gether.
  • Transfer of rights. You may not assign any right, interest or obligation you have under these Terms without the prior written consent of 2gether.
  • Right of correction. 2gether reserves the right, but shall have no liability, to edit, modify, refuse to post or remove any Vendor Content, in whole or in part, that in its sole and absolute discretion is objectionable, erroneous, unlawful, fraudulent or otherwise in violation of these Terms.

 

 

Explicit, free and lawful consent

 

I confirm that I have read these General Terms and Conditions of Use of the 2gether Service and Products, I have understood them and I therefore freely accept their provisions and clauses.

 

Privacy Policy

Last revision of the Data Protection conditions: 30/08/2021

 

Introduction

 

Your privacy is important to 2gether. We believe that you should always know what data we collect from you and how we use it. This Privacy Policy is designed to help you understand how 2gether («2gether Money Management SL», «we», «us», «the Company» or «the Controller») collects, uses, processes and discloses the information and personal data that you provide when accessing, using its website, www.2gether.global, or using the services that 2gether provides to you through its website (hereinafter «website») or through its mobile application (hereinafter «application» or «app»).

The processing of personal data by 2gether is based on two principles for you as a User, although 2gether complies with all the principles in this area.

Transparency. We will always keep you informed of our practices in the area of privacy of your personal data.

Security. While we cannot promise perfection, we have implemented security tools to protect your information in accordance with industry standards and as required by law.

 

Controller of personal data

The Entity Responsible for Personal Data Processing is the commercial entity «2gether Money Management SL» with registered office at Bravo Murillo 101, 28020, Madrid, with mailing address support@2gether.global and VAT number B87586400.

You may also consult 2gether’s Data Protection Officer (dataprotection@2gether.global), who is responsible for ensuring that the rights and freedoms of data subjects are not adversely affected by data processing operations, for an opinion on the processing of personal data.

2gether takes the privacy and security of its Users very seriously, guaranteeing the confidentiality of the Personal Data to which it has access. The processing of personal data shall always be carried out in accordance with this Privacy Policy and the privacy and data protection legislation applicable at all times.

2gether, in its capacity as Controller of Personal Data, guarantees Users that it will always apply the required technical and organisational security measures established in current legislation, given the nature of the Personal Data processed and the circumstances of the processing, as well as those that are advisable given the state of technology, guaranteeing the integrity, security and confidentiality of the Personal Data.

 

Purpose and general information

 

Both access to and use of the website www.2gether.global, and access to and use of the application shall be governed by the provisions of this Privacy Policy, as well as by the General Conditions of Use and the Cookies Policy, which the User accepts and undertakes to respect, and by the privacy and data protection legislation applicable at all times.

Please read all three documents carefully before using the website or the application.

 

Personal data processed

 

2gether shall collect and process the Personal Data of Users, registered on the Website or in the Application, in accordance with the provisions of this Privacy Policy, as well as under the specific data protection clauses for certain products or services that may be applicable in each case.

Mandatory data for the provision of 2gether services:

The data that the User must provide in order for 2gether to be able to provide its services are:

  1. Email address.
  2. DNI or Passport (name and surname, postal address, date of birth).
  3. Telephone number.
  4. Handwritten signature.
  5. Facial photograph.
  6. Occupation.

Data obtained through the use of the application and the website: Through the use of the website and the application, and through the use of the services provided.

  1. Mobile device advertising identifier, mobile device characteristics, language preference and country of location.
  2. Login data (referring domain, visits to the website, date and time of access to the website).
  3. Access codes to account information added by the User, the log of account movements, as well as data derived from actions performed by the User through the utilities of the Service provided by 2gether through the website or the application.
  4. Credit and debit card information.

All personal data may be provided directly by Users or indirectly collected through the use of the Services and under the legally established terms, and will be processed and treated for the purposes described in this Privacy Policy.

2gether shall limit the collection and processing of Personal Data only to the purposes of the processing of personal data, as detailed in the following clause.

Purposes of the processing of personal data

The personal data collected will be processed for the purpose of:

  1. Providing the service. The service provided by 2gether, (hereinafter the «Service»), shall include:
    1. Prepaid card and shared IBAN. 2gether will provide the User with a prepaid VISA card and an IBAN number to send transfers, but not to receive.
    2. Cryptocurrency. 2gether will provide the User with a mobile application environment for trading cryptocurrencies.
      • Investments: The User may trade on the unregulated cryptocurrency market through the Accounts provided by 2gether in its mobile application. The User, without leaving the environment provided by 2gether, will be able to trade on this market, but the deposit of his funds will be on the platform of a third party, KRAKEN.
    3. Transfers. The User may make transfers in EUROS (FIAT) regulated currencies in the Accounts environment. Transfers in FIAT currency, namely EUROS, are made via a shared IBAN. 
    4. ATM / Cash withdrawal at the cash dispenser. The User may withdraw money in EUROS with his or her 2gether card from ATMs previously designated by 2gether for this purpose. 
    5. 2GT Tokens. When the User registers on the 2gether application, and after accepting all the legal terms for its contracting and use, they will optionally acquire a variable quantity of 2GT. The User may consecutively acquire more 2GT.
    6. Returns. Refunds made by 2gether to the User, whatever the reason (failed purchase made by card, withheld transaction or error in the purchase of cryptocurrency), shall always be made in EUROS.

In the future, the 2gether service may also consist of:

  1. Bank Account Aggregator. The 2gether application will enable the user to add accounts they have subscribed to at other banks in one place.
  2. Market Place. The User will be able to access and contract financial products and services from other financial institutions around the world.
  3. Rating. Develop reports and analytics on the User’s activity to better manage their spending and their financial and non-financial assets.
  4. Advertising. Personalised advertising on the 2gether website and App.
  1. Improve the service and generate new products and services. The data generated by the User through the use of the service will help 2gether to evaluate the impact and performance of the services and products offered and, if necessary, to create new products and services for Users.
  2. Analytics. 2gether will generate reports and market analytics on aggregated data extracted from averages and trends of User usage and spending.
  3. User Experience. With the data generated by Users, 2gether will be able to improve the User experience, in particular by analysing the browsing and access behaviour of Users on the website or application, thanks to the cookies and tracking code incorporated into our website and application. The CEM (Customer Experience Management) tool allows us to improve our applications and your experience as a 2gether User.
  4. Security. By using Users’ data, 2gether will be able to evaluate and improve the security of the Users.

Communication. It will send advertising and communications relating to the service to Users by email.

 

Recipients of personal data and third parties

 

Data processors

2gether does not share Users’ personal data with third parties.

However, 2gether allows access to the personal data of its Users to third parties with whom 2gether has previously established professional relationships. These third parties, known as Processors, access the User’s personal data for the purpose of fulfilling the specific purposes for which 2gether processes personal data, as set out in the preceding clause. These relationships between 2gether and its Data Processors are regulated and delimited in their corresponding contracts, and comply with all the requirements of current Spanish and European legislation on the Protection of Personal Data.

Likewise, 2gether ensures that its Data Processors comply with all the security requirements required by current Spanish and European legislation on the Protection of Personal Data.

 

Dissociated data

2gether may share dissociated information (not considered as personal data due to the impossibility of ascertaining from which identified or identifiable persons the data originate) of the transactions that appear in the User’s record of movements of the service with third parties operating in the same economic and commercial sectors as 2gether or in other sectors such as energy, food or insurance.

Disassociated data consists of replacing the exact details of the User’s Personal Data with inaccurate ones (e.g. replacing the number of transactions by ranges, grouping detailed information into higher criteria, etc.), thus making it impossible to personally identify the User or to know details of his or her consumption. A paradigmatic dissociated data is an anonymous statistic.

2gether shall under no circumstances disclose the name, surname, telephone number, email, or other data that may identify the User, except by legal obligation or in compliance with judicial or administrative decisions.

 

Transfer of personal data to third parties in the European Union

2gether may not transfer Users’ personal data to third party companies without the prior and informed consent of the User, which, where necessary, shall be obtained through the corresponding electronic or paper forms, as required.

In any case, 2gether shall inform the User of the purpose of the processing and of the sectors of activity of the possible assignee of the personal data and, beforehand, shall offer the User the possibility of accepting or not accepting the assignment.

In any event, the transferees will be within the European Union, thus ensuring that the level of privacy and confidentiality protection applicable to the Personal Data will be equivalent to that which applies in full in their capacity as Data Controller.

Without prejudice to the foregoing, we inform you that 2gether may communicate your Personal Data to the competent judicial and administrative bodies of the European Union, for the purposes of complying with the legislation applicable at all times in the banking and financial sector, with the prevention of money laundering and the financing of terrorism and with the legislation relating to consumer protection.

 

Transfer of data to third parties outside the European Union

2gether may transfer Personal Data to a third party from a non-EU member state or to an international organization, provided that the European Commission has established that such non-EU country or international organization offers an adequate level of protection for your Personal Data. The list of countries with an adequate level of protection according to the European Commission can be found here.

2gether will not transfer personal data to a third party or international organisation outside the European Union without the adequate level of protection of personal data according to the above mentioned decisions of the European Commission, unless:

(1) provide adequate data protection guarantees, as set out in the laws and regulations of the European Union on personal data protection; the User is entitled to obtain a copy of these guarantees from 2gether or from 2gether’s Data Protection Officer (for contact information see above «PERSONAL DATA CONTROLLER»); (2) there are Binding Corporate Rules previously approved by the Spanish Data Protection Agency, (3) the data subject, or the User, has given his or her explicit consent to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and safeguards, (4) the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures at the request of the data subject, (6) the transfer is necessary for the performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person, (7) the transfer is necessary for important reasons of public interest, (8) the transfer is necessary for the establishment, exercise or defence of legal claims; (9) the transfer is necessary to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent; and (10) the transfer is made from a register which, in accordance with Union or Member State law, is intended to provide information to the public and is open to consultation by the general public or any person who can demonstrate a legitimate interest, but only in so far as the conditions laid down by Union or Member State law for consultation are met in each individual case.

 

Retention period of personal data

The personal data provided by the User shall be kept by 2gether for as long as the User uses the regular service.

2gether shall review the personal data of its non-active users and shall block their data after 6 months of inactivity. This blocked personal data shall be kept by 2gether in accordance with the periods established in the legislation in force, in accordance with the provisions of the regulations on the Prevention of Money Laundering and Terrorist Financing, as well as for the attention of possible liabilities that may arise from the processing, but shall not be processed. Once these periods have expired, they will be deleted from the 2gether databases.

 

Legitimacy for the processing of personal data

 

The legal bases for the processing of the User’s Personal Data in accordance with the purposes described above are as follows:

  • Explicit and free consent to process the User’s Personal Data as set out in this Privacy Policy, and always in accordance with the applicable Spanish and European legislation on Personal Data Protection and Privacy at all times. The contractual obligations to provide the service to the User and in the event that the User contacts our Customer Service in order to process requests and offer an optimal service.
  • 2gether’s obligations for the detection and prevention of identity fraud and the detection of suspicious activities in accordance with the provisions of the legislation on money laundering.
  • 2gether’s legitimate interest in:
    • The sending of commercial communications, provided that the consent of the interested party has been obtained.
    • To carry out tests to correct possible errors, improve the Service and provide an optimal Service to the User.
    • The preparation of internal analyses and reports to evaluate the results of different campaigns or promotions launched by 2gether.

 

User Rights

 

2gether informs you that you can exercise your rights of:

  • access,
  • rectification,
  • cancellation/deletion,
  • limitation of the processing of your personal data,
  • revocation of consent to the processing of your personal data,
  • objecting to the processing of your personal data, and
  • portability

In accordance with the terms established in current legislation. Here you can consult in more detail what these rights consist of and how to exercise them.

To initiate the procedure for exercising one or more of these rights, you can send an email to the 2gether Data Protection Officer (dataprotection@2gether.global).

2gether advises you of your right to withdraw, at any time, the consent given to collect and process your Personal Data, without affecting the lawfulness of the processing on the basis of the consent prior to its withdrawal. If you withdraw your consent to the processing of your Personal Data, this will automatically result in the deletion of your User account on 2gether. You may withdraw your consent and unsubscribe from the 2gether Services by accessing, in the 2gether App, the Personal Area> Personal Data> Delete Account.

You may also revoke consent by sending an email to dataprotection@2gether.global, or by sending a request to 2gether’s postal address referenced in the heading of this Privacy Policy.

The User also has the right to data portability as a whole by means of his/her own request, or to receive personal data concerning him/her, which he/she has provided to a Controller, in a structured, commonly used and machine-readable form, and has the right to transmit such data to another Controller without hindrance from the Controller to whom the personal data has been provided.

As stated in this Privacy Policy, in the clause «PERSONAL DATA PROCESSING CONTROLLER», you may also consult the Data Protection Officer (DPO) of 2gether, who is responsible for ensuring that the rights and freedoms of data subjects are not adversely affected by data processing operations.

Finally, we would like to remind you that, by law, you have the right to lodge a complaint with the Spanish Data Protection Agency or other European bodies responsible for Personal Data Protection. This applies if you are a citizen of a Member State of the European Union and if you consider that the data processing does not comply with European regulations.

 

Promotional communications

 

By registering with 2gether, you may receive periodic emails from 2gether if you agree to receive promotional email communications. You may opt out of receiving communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your email preferences in your account settings; or (iii) contacting us through support. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails related to our ongoing business relationship. Service emails contain service-related announcements that relate to your account.

Mobile applications, browser extensions and websites may send notifications, such as alerts, sounds and icon badges. Push notifications or in-app messages may include operational messages and promotional messages about products, services and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device.

 

Third party links

 

The User may find links on the Website to other websites controlled by third parties. 2gether does not have the power to control the content provided by these other websites and is not responsible for the processing of Users’ personal data carried out by those responsible for these websites. We remind you that this Privacy Policy only applies to Personal Data collected and processed by 2gether through the Website or the Application. Therefore, 2gether is not responsible for any aspect related to the processing of User data that may be carried out by those responsible for these third-party websites.

 

Social Media

 

 

2gether currently has profiles on various social networks: Facebook, Twitter, Medium, Reddit, BitcoinTalk, Telegram, LinkedIn and Discord. The data processing carried out by 2gether as data controller on these social networks is the same as that carried out by the various social networks for the profiles available on these social networks. Through the aforementioned social networks, we keep you informed about updates and activities on our website or any of the blogs that are part of our network. In any case, we do not export data from the different social networks unless we previously and expressly request the consent of the User for a specific purpose.

 

Changes and updates to the Privacy Policy

 

This Privacy Policy is effective as of the effective date set forth above. 2gether reserves the right to change this Privacy Policy at any time in accordance with applicable data protection laws in Spain and Europe. If we make changes to this Privacy Policy, we will notify you by means of a notice on our website or also, if applicable, by means of a communication via email or notification in your User area.

In any case, the date of the last update will be stated in the heading of this Privacy Policy.

By continuing to access or use the 2gether Services after such changes or updates have been made, the User agrees to be bound by the revised Privacy Policy.

 

 

Contact

 

If you have any questions about this Privacy Policy or the use of your personal data, or if you wish to correct or delete data, please send an email to support@2gether.global or to dataprotection@2gether.global

 

Cookies Policy

 

 

What are cookies?

 

This website uses cookies and/or similar technologies that store and retrieve information when you browse. In general, these technologies can serve very diverse purposes, such as, for example, recognizing you as a user, obtaining information about your browsing habits, or customizing the way content is displayed. The specific uses we make of these technologies are described below.

 

What does this website use cookies for?

This website uses cookies for a number of purposes, including:

  • Analysis: are those that, processed by us or by third parties, allow us to quantify the number of users and thus carry out the measurement and statistical analysis of the use made by users of the service offered. For this, your browsing on our website is analyzed in order to improve the offer of products or services that we offer you.
  • Behavioral advertising: are those that, processed by us or by third parties, allow us to analyze your Internet browsing habits to show you advertising related to your browsing profile.

 

Who uses cookies on this website?

The identification of who uses the cookies, the type of cookies used and other details, is indicated below:

Entity: Google Analytics

Type: Third Party

Purpose: Collect information on the navigation of users through the site in order to know the origin of visits and other similar data at a statistical level. Google Analytics also uses these cookies to show you advertising related to your browsing profile.

More information: Google AnalyticsGoogle Privacy Center

 

Note: «Own» cookies are used only by the owner of this website and «Third-party» cookies are also used by the service provider detailed in the table above.

You can find out about transfers to third countries that, where appropriate, made by third parties identified in this cookie policy in their corresponding policies (see the links provided in the «More information» section of the table above).

 

How can I disable or delete these cookies?

 

You can allow or block cookies, as well as delete your browsing data (including cookies) from the browser you use. Please refer to the options and instructions provided by your browser to do so. Please note that if you accept third-party cookies, you must delete them from your browser options.

Below, you have available the links with the information to manage cookies from the most used browsers:

  • Firefox: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-los-sitios-we
  • Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
  • Internet Explorer: https://support.microsoft.com/es-es/help/278835/how-to-delete-cookie-files-in-internet-explorer
  • Microsoft Edge: https://support.microsoft.com/es-es/help/4027947/microsoft-edge-delete-cookies
  • Safari: http://support.apple.com/kb/ph5042
  • Opera: http://help.opera.com/Windows/11.50/es-ES/cookies.html
    Other browsers: please refer to the documentation for the browser you have installed.

 

 

Google Analytics Opt-Out Browser Add-on

 

If you wish to refuse Google Analytics analytics cookies in all browsers, so that information about you is not sent to Google Analytics, you can download an add-on that performs this function from this link: https://tools.google.com/dlpage/gaoptout.

 

Exercising your rights

 

You can learn about and exercise your data protection rights by accessing our Privacy Policy.