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Legal Information and Compliance
At Beeyond Investments, transparency, security, and regulatory compliance are at the core of our business. This page provides you with essential information on the legal standards and policies guiding our operations across jurisdictions. Here, you'll find details on relevant legislation, our commitment to privacy and data protection, the use of cookies on our website, and how we handle complaints and petitions. We are dedicated to ensuring that all our practices meet the highest legal and ethical standards, so you can trust us to act in your best interest and protect your rights as a client.
General information
1. Identification Data
The investment consultant C.I. ”BEEYOND INVESTMENTS" S.A. (hereinafter - "BEEYOND INVESTMENTS") is a joint-stock company, a legal entity registered in the State Register of Legal Entities of the Republic of Moldova on 23.01.2024, with identification number and tax code: 1024600004139.
C.I. ”BEEYOND INVESTMENTS" S.A. social capital size is 600,000 Moldovan lei and consists of 6,000 ordinary nominative shares with a nominal value of 100 Moldovan lei for each share.
BEEYOND INVESTMENTS maintains an organizational structure in accordance with the nature, scope, and complexity of the activities carried out.
According to the law on joint-stock companies no. 1134/1997, BEEYOND INVESTMENTS is administratively governed by the general meeting of shareholders/single shareholder, and at the executive level by 1 director and 1 deputy director.
BEEYOND INVESTMENTS has its registered office at: str. Mihai Eminescu 15, of. 1, mun. Chisinau, Republic of Moldova, MD-2012, tel. +373 67557775, e-mail: contact@investbeeyond.com.
2. Investment Advisory Services
Through its investment advisory activity, BEEYOND INVESTMENTS provides one or more of the following services:
analysis of the characteristics of financial instruments;
analysis of financial instrument markets, segments, institutions, and the activities of their participants;
consultancy regarding the formation and management of financial instrument portfolios;
consultancy regarding the characteristics of the investment process and the tax regime of investments;
consultancy regarding the assessment and management of investment risk in financial instruments;
consultancy regarding the technique of negotiation and trading on the financial instrument market.
3. Types of Financial Instruments
BEEYOND INVESTMENTS provides investment advisory services in connection with the following types of financial instruments:
securities;
units (securities) issued by collective investment undertakings in transferable securities;
options contracts, futures contracts, swap contracts, forward contracts on interest rates;
other financial instruments admitted to trading on a regulated market and/or within a multilateral trading facility.
4. Client Categories
A client can be any natural or legal person to whom the investment consultant will provide investment advisory services.
BEEYOND INVESTMENTS provides services to both retail clients - clients who are not professional clients, and professional clients - persons who meet the provisions of Article 137 (1) of the Law on the Capital Market no. 171/2012.
5. Ethical Rules of Activity
BEEYOND INVESTMENTS is unconditionally guided by the following principles in its activities:
conducts business with integrity;
promotes competent, prudent, and perseverant behavior;
maintains an appropriate level of financial resources;
ensures responsible organization and efficient control of its commercial activities, with the establishment of adequate risk management systems;
engages competent personnel with the necessary knowledge and experience to fulfill their assigned responsibilities;
pays due attention to the interests of its clients and treats them impartially and non-discriminatively, ensuring full equality of treatment;
evaluates the requirements of each client to provide them with appropriate services, considering the client's investment profile (requirements and expectations), level of knowledge in the capital market and the relevant regulatory framework, client's investment experience, and the level of risk accepted by the client;
pays due attention to the informational needs of its clients and communicates information to them in a correct, clear, objective, and non-misleading manner;
takes appropriate measures to ensure the suitability of recommendations and discretionary decisions for any client entitled to rely on them;
acts openly and cooperatively in its relationship with regulatory authorities and properly informs them of any matters about which the regulatory authority reasonably needs to be informed;
discloses to clients all necessary information regarding the legal effects of concluding and executing the contract for the provision of services and activities with securities, including not recommending transactions to the client without taking reasonable steps to ensure that the client understands the nature of the risk associated with them;
maintains professional secrecy, including the confidential keeping of information regarding any orders and balances of accounts and turnovers of client accounts, as well as other data concerning clients. Any exceptions to this rule must be provided for by law or by the client's exact instructions.
Legislation
Legal Framework
BEEYOND INVESTMENTS conducts its activities based on the authorization issued by the National Commission for Financial Markets.
BEEYOND INVESTMENTS is entitled to exclusively provide investment advisory services in accordance with Article 371 of the Law on the Capital Market no. 171/2012.
The investment advisory activity is carried out by the employees of the investment consultant, who have appropriate training confirmed by qualification certificates issued by the National Commission for Financial Markets.
Privacy Policy
Safety and confidentiality of your information are of fundamental importance to us. Through this Privacy Policy, we are committed to protecting your privacy and ensuring that your personal information is managed with the utmost care and responsibility.
Procedures for maintaining the security, integrity, and confidentiality of information
In order to maintain professional reputation and comply with legal standards, the investment consultant ensures the legitimacy of personal data processing and an adequate level of personal data security.
In the process of conducting activities, the investment consultant processes personal data in accordance with the provisions of:
a) Articles 91-94 of the Labor Code of the Republic of Moldova;
b) Law on the Protection of Personal Data no. 133/2011.
The following information is designed to inform you about the processing of your personal data and your rights regarding this processing in accordance with:
Law no. 133 of 08.07.2011 on the protection of personal data, published on 14.10.2011 in the Official Gazette no. 170-175 art. 492, Amended by the Parliament Law no. 155 of 15.07.2022, published on 05.08.2022 in the Official Gazette no. 246-250, in force from 05.09.2022.
1. General Information
We, C.I. "BEEYOND INVESTMENTS " S.A. (hereinafter - "BEEYOND INVESTMENTS") represent the data controller in accordance with the General Data Protection Regulation (hereinafter - "GDPR").
2. Purpose of processing and categories of processed data
In this regard, the purposes for which personal data are processed by BEEYOND INVESTMENTS are as follows:
consultation for the development of personalized investment strategies;
training for opening a brokerage account;
support for opening a brokerage account;
providing assistance in the online trading process.
To achieve the purposes related to the consultancy field, BEEYOND INVESTMENTS processes personal data in the following operations:
preparation of the necessary documents for consultancy contracts with our clients, at all stages;
periodic transmission of information and commercial offers through newsletters/email/promotional materials;
maintenance of internal databases;
accurate identification of clients when they wish to perform a service;
providing information about BEEYOND INVESTMENTS events;
participation in opinion polls regarding BEEYOND INVESTMENTS offers and services regarding customer satisfaction levels;
requesting and using information about the businesses presented to clients from various public sources.
Within BEEYOND INVESTMENTS, the following categories of data are processed:
Name, surname, domicile/residence, series and number of identity document, IDNP (Personal Identification Number), citizenship, date of birth, email address, fixed and/or mobile phone numbers, fax number (where applicable), data resulting from business ownership documents (including history and extracts from state authorities profiles);
Client contact with BEEYOND INVESTMENTS, such as registration on the website, an email or letter, or other records of contact with BEEYOND INVESTMENTS;
Information regarding the client's account, such as account numbers or other information related to the client's account or included in the commercial relationship management contract with each client;
Information regarding access legitimacy - BEEYOND INVESTMENTS will collect passwords, hints, and similar security information used for authentication and access to accounts and services (for online accounts opened by each client on the BEEYOND INVESTMENTS website);
Client preferences for certain products and services when clients will notify BEEYOND INVESTMENTS what they are or when BEEYOND INVESTMENTS will assume what they are, based on how clients use BEEYOND INVESTMENTS products and services; in this way, BEEYOND INVESTMENTS will be able to prioritize what interests the client;
Marketing preferences;
See the Cookies section for details on what BEEYOND INVESTMENTS collects using cookies;
Browsing history. If permission is given, BEEYOND INVESTMENTS collects the categories of websites that page guests have navigated from their mobile phone, device, or PC, such as news. However, BEEYOND INVESTMENTS will not hold a history of the websites that page guests navigate, this being limited to a short period of time to allow the connection to be made. BEEYOND INVESTMENTS uses this interest information to send personalized marketing offers or to display ads. Visitors can opt out of ads according to the Cookies section on the BEEYOND INVESTMENTS website or, in the case of marketing, by unsubscribing, which can be accessed with the first newsletter received;
Information that BEEYOND INVESTMENTS obtains from other sources, such as public or private authorities, fraud prevention agencies, as well as other data providers. These include demographic data, interest data, as well as browsing behavior;
For the loyalty program consisting of offering benefits, discounts, or rewards for loyalty;
Responses to invitations and participation confirmations at events.
The personal data we process are mainly identification, transactional, financial, demographic, location, or other personal data that we collect directly from you or from other sources when you become our client or when you use our products or services.
Sensitive personal data reveal your racial and ethnic origin, political opinions, religious and philosophical beliefs, genetic data, biometric data, health data, or data relating to your sex life or sexual orientation.
BEEYOND INVESTMENTS DOES NOT INTENTIONALLY COLLECT SENSITIVE PERSONAL DATA FROM YOU FOR STORAGE.
3. The legal basis for processing
The legal basis for collecting and processing your data for each of the purposes mentioned above is:
Contracts for consultancy services, as well as contracts with third parties of which you are a part or your request prior to concluding a contract;
BEEYOND INVESTMENTS' legitimate business interests, such as fraud prevention, maintaining the security of our services, direct marketing, and improving services whenever we rely on this legal basis to process your data, we assess our business interests to ensure they do not override your rights. In addition, in some cases, you have the right to object to this processing. BEEYOND INVESTMENTS' legitimate interest in allowing us to exercise rights provided by law in our favor, to take legal action against any illegal or detrimental activity to BEEYOND INVESTMENTS;
Compliance with an imperative legal requirement, such as accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures, and the right to restrict the use of your own data, which control the scope of our services to be provided;
Furthermore, to the extent you have given consent, this represents your consent. Processing personal data based on consent is an additional purpose of processing personal data for the execution of the contract to which you are a party and does not condition the provision/provision of services;
Processing is necessary for the performance of a task serving a public interest.
We will collect your personal data when, for example:
You use any of our services;
You register for a specific service;
You subscribe to a newsletter or other services offered by us;
You contact us through various channels, or request information about a service;
You visit or browse our website;
You have granted permission to other companies, such as our business partners or associates, as well as to third-party providers or contractors, to exchange information with us for the purpose of providing services to you;
When personal data is public; or
You are the client/recipient of a business activity we provide.
Additionally, we collect information from certain organizations, if applicable and to the extent we have legal grounds to do so. These include fraud prevention agencies, commercial directories, verification/control agencies, billing calculation agencies, and contracted service providers.
We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, transparent image files used to track your movements on our site). For further details on this and how to opt-out, please refer to the Cookies section on our website.
4. Categories of recipients to whom the collected personal data may be disclosed
To achieve the above-mentioned purposes, we use the following categories of product and service providers/authorized persons:
Providers (property owners) directly/indirectly involved in providing real estate services;
State authorities (including tax authorities);
Accountants, auditors, judicial experts, lawyers, or other similar external advisors of BEEYOND INVESTMENTS or to third parties providing products and services to BEEYOND INVESTMENTS(security service providers, IT systems providers, financial consultants);
BEEYOND INVESTMENTS providers directly/indirectly involved in the marketing and promotion process.
5. Data retention period
Your personal data will be retained by BEEYOND INVESTMENTS for a period not exceeding the time necessary to achieve the purposes described above and/or for any other duration required by applicable legal obligations, using the following criteria for determining this period:
When purchasing property rights through BEEYOND INVESTMENTS, we retain your personal data for the duration of our contractual relationship;
If you participate in a promotional offer, we retain your personal data for the duration of the promotional offer;
If you contact us for service provision, we retain your personal data for the duration necessary to process your inquiries, but no longer than 10 (ten) years from the date of the last correspondence sent, to comply with tax regulations;
If you register on our website, we retain your personal data until you request deletion or after a period of inactivity (without active interaction with us). In this regard, please note that data processed for this purpose will be deleted 5 (five) years after the last interaction;
If you have consented to marketing, we retain your personal data until you unsubscribe or request deletion, or after a period of inactivity (without active interaction with our brands) defined in accordance with regulations and guidelines. In this regard, please note that data stored in our databases for the purpose of direct marketing communications are deleted from these databases 10 (ten) years after the last interaction with you;
If cookie modules are stored on your computer, we retain them for as long as necessary to fulfill their purposes (e.g., for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with regulations and guidelines. In this regard, please note that data processed through cookie modules used to provide online behavioral advertising, personalize services for you, and allow the distribution of our content on social media sites (sharing buttons for displaying our website) will be retained for a maximum period of 10 (ten) years from their collection, based on your consent.
6. Your rights
The Regulation grants individuals whose personal data is processed a series of rights. Thus, in addition to the existing rights, we find the right to data portability and the right to erasure of data. In short, the rights you have are:
The right to withdraw consent at any time to stop processing data based on your consent. Withdrawal will not affect the legality of processing based on consent given before withdrawal, for the execution of a contract, to comply with a legal obligation, or for the purpose of pursuing our legitimate interests.
The right of access – means that you have the right to obtain confirmation from us whether we process personal data concerning you and, if so, you have access to that data and information about how it is processed.
The right to data portability – refers to the right to receive personal data in a structured, commonly used, machine-readable format, and the right for this data to be transmitted directly to another controller, where technically feasible.
The right to object – concerns your right to object to the processing of personal data when processing is necessary for the performance of a task carried out in the public interest or when it involves a legitimate interest of the controller. When the processing of personal data is for direct marketing purposes or processing is based on explicit consent, you have the right to object to processing at any time.
The right to rectification – refers to the correction, without undue delay, of inaccurate personal data. Rectification will be communicated to each recipient to whom the data has been transmitted unless this proves impossible or involves disproportionate effort.
The right to erasure (the right to be forgotten) – means you have the right to request the deletion of personal data without undue delay if one of the following reasons applies: they are no longer necessary for the purposes for which they were collected or processed; you withdraw your consent, and there is no other legal basis for processing; you object to the processing, and there are no overriding legitimate grounds for the processing; personal data has been unlawfully processed; personal data must be erased to comply with a legal obligation; personal data has been collected in relation to the offer of information society services.
The right to restriction of processing – can be exercised where the accuracy of the data is contested, for a period necessary for the verification of the accuracy of the data; the processing is unlawful, and you oppose the erasure of personal data, requesting instead the restriction; if the Company no longer needs the personal data for processing purposes, but the individual requests it for the establishment, exercise, or defense of legal claims; if the individual has objected to processing for the time period while it is verified whether the legitimate interests of the controller prevail over those of the individual.
To exercise these rights or for any additional questions regarding this information or regarding the Company's use of personal data, please contact our data protection officer using any of the communication methods described below.
You can contact us at: contact@investbeeyond.com
By using our services, you agree to the terms of this Privacy Policy. If you have any questions or concerns about the management of your personal information, please contact us at contact@investbeeyond.com.
Thank you for trusting BEEYOND INVESTMENTS with the management of your personal information.
Cookie Policy
This Cookie Policy (hereinafter referred to as the "Cookie Policy") governs the use of cookies and social media plugins on the websites of CI BEEYOND INVESTMENTS SA (hereinafter referred to as "BEEYOND INVESTMENTS") (www.beeyondinvestments.md/com), (hereinafter referred to as the "Website www.beeyondinvestments.md/com"). Cookies are small text files that are stored on the hard drive of a device and contain certain information and sometimes personal data. Social media plugins are small pieces of software developed and provided by social media service providers (such as Facebook, LinkedIn, etc.), which add social media integration when included on the Website www.beeyondinvestments.md/com.
By continuing to use the Website www.beeyondinvestments.md/com or by clicking "Yes, I agree" after being informed about the use of cookies and social media plugins, you acknowledge that you have carefully read this Cookie Policy and agree to it without reservation. You can change your cookie preferences at any time through the cookie settings.
1. Who is responsible for processing your personal data?
BEEYOND INVESTMENTS, with legal address in the Republic of Moldova, mun. Chisinau, str. Mihai Eminescu 15, is the entity responsible for your personal data covered by this Cookie Policy (hereinafter referred to as "We", "Us", "Our"). This Cookie Policy may be amended from time to time to ensure that it remains accurate and compliant with the law. If this happens, please note the changes and agree to them if you find them acceptable.
Your personal data is processed by BEEYOND INVESTMENTS.
Any term starting with a capital letter will be explicitly defined in this Privacy Policy.
Whenever possible, given the context, singular words should be interpreted as including the plural and vice versa. When referring to specific laws or regulations, such reference should include any amendments, replacements, or cancellations of the respective laws or regulations, including any related administrative orders.
BEEYOND INVESTMENTS reserves the discretionary right to modify, change, or supplement the Privacy Policy from time to time. Such modification, change, or supplementation will be communicated through the Website www.beeyondinvestments.md/com.
2. Cookies
We place a number of cookies when you visit the Website www.beeyondinvestments.md/com. These cookies are divided into 3 groups of cookies: functional cookies; analytical and statistical questionnaires; advertising and social cookies. You can withdraw your consent to the use of cookies by BEEYOND INVESTMENTS at any time.
You can prevent the placement of cookies by configuring your browser accordingly. Instructions on how to do this can be found here:
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-Site-ul www.satulgerman.md-preferences
Safari: https://support.apple.com/kb/PH21411?locale=nl_BE&viewlocale=en_US
However, disabling cookies when visiting the Website www.beeyondinvestments.md/com may result in the improper functioning of certain or all Website www.beeyondinvestments.md/com functions.
When you visit the site, BEEYOND INVESTMENTS places a number of cookies. Most data regarding these cookies, their placement, and use allow for your identification, and BEEYOND INVESTMENTS uses them to gain insight into how you and other visitors use the Website www.beeyondinvestments.md/com by collecting statistical and usage data, which allow BEEYOND INVESTMENTS to provide a better experience on the Website www.beeyondinvestments.md/com.
You can withdraw your consent to the use of cookies by BEEYOND INVESTMENTS at any time. To exercise this right, simply delete the cookies that have been placed on your device. To do this, you are asked to refer to the appropriate instructions from your browser manufacturer, as listed above.
3. Why do we process your personal data?
We process your personal data through cookies for several purposes: to improve our website and the experiences and services we offer; to display advertisements; to provide information to third parties and to keep the web experiences we offer, our website, you, and us safe.
- BEEYOND INVESTMENTS processes your personal data to provide you with more personalized content and ads and to perform statistical analysis so that we can improve our website, ads, products, and services or develop new products and services.
- BEEYOND INVESTMENTS may process your personal data to inform any third party in the context of a possible merger with, acquisition/division or division by that third party.
- BEEYOND INVESTMENTS may process your personal data to maintain the legitimate interests of BEEYOND INVESTMENTS, partners, or a third party, if and when your registration or use of the Website www.beeyondinvestments.md/com may be considered (a) a violation of any applicable terms of use or intellectual property rights or any other right of a third party; (b) a threat to the security or integrity of the Website www.beeyondinvestments.md/com; (c) a danger to the Website www.beeyondinvestments.md/com or to any of us or to subcontractors' systems due to viruses, trojans, spyware, malware, or any other form of malicious code or (d) obscene, discriminatory, racist, defamatory, harassing, harmful, or inappropriate or illegal in any way.
- Your personal data may be transferred on our own initiative to the police or judicial authorities as evidence or if there are justified suspicions of illegal acts or offenses committed by you through your registration or use of the Website www.beeyondinvestments.md/com.
4. What makes the processing of your personal data legitimate?
The law requires us to specify exactly the legal basis on which we process your personal data. We may process your personal data because you have consented to it, because the law requires us to do so, or because it is in our legitimate interest or that of a third party.
For the processing of your personal data for the purposes described in clauses 3.1 and 3.2 of this Cookie Policy, BEEYOND INVESTMENTS, as the responsible party, requests your consent. BEEYOND INVESTMENTS obtains your consent through the cookie banner. By clicking affirmatively on this banner and continuing to use the Website www.beeyondinvestments.md/com, you acknowledge that you have carefully read this Cookie Policy and agree to it without reservation.
The processing of your personal data for the purposes described in clause 3.3 of this Cookie Policy is also necessary for the legitimate interests of BEEYOND INVESTMENTS, which are to maintain the Website www.beeyondinvestments.md/com and the Social Media Channels, our products and services safely against abusive use and illegal activity.
The processing of your personal data for the purposes described in clause 3.4 is necessary for BEEYOND INVESTMENTS to fulfill its legal obligations.
5. Who receives your personal data?
Our general approach is that we do not share your personal data with third parties unless you consent to it. However, sometimes it is inevitable for third parties to receive your personal data.
BEEYOND INVESTMENTS relies on third-party operators to provide you with the Website www.beeyondinvestments.md/com, as well as to process your personal data on our behalf. These third-party operators are permitted to process your personal data only on behalf of BEEYOND INVESTMENTS, based on express written instructions from BEEYOND INVESTMENTS. BEEYOND INVESTMENTS guarantees that all third-party operators are chosen with due care, and they are required to comply with the security and integrity of your personal data.
BEEYOND INVESTMENTS does not transfer your personal data in an identifiable manner to any third party without your explicit permission to do so. BEEYOND INVESTMENTS may transfer anonymous and/or aggregated data to other organizations that may use this data to improve products and services, as well as to customize the marketing, display, and sale of these goods and services.
6. What are the safeguards regarding your personal data?
We will not process more personal data than we need for the purposes we have communicated to you. Additionally, we will process your personal data only for as long as necessary to achieve the purposes we have communicated to you or until you withdraw your consent for their processing, and there is no other legal basis that allows us to continue processing personal data. We also guarantee the security of keeping your personal data safe.
BEEYOND INVESTMENTS does everything possible to process only those personal data that are necessary to achieve the purposes listed in Article 3.
Your personal data is processed only for as long as necessary to achieve the purposes listed in Article 3 of this Cookie Policy or until you withdraw your consent for their processing. Please note that withdrawing consent may mean that you can no longer use the entire or part of the Website www.beeyondinvestments.md/com. BEEYOND INVESTMENTS will anonymize your personal data when they are no longer needed for the purposes described in Article 3, except when there is:
a) a significant interest for BEEYOND INVESTMENTS, your financial institution, the payment service provider, or any other third party in keeping your personal data in an identifiable form;
b) a legal or regulatory obligation or a judicial or administrative decision that prevents us from making them anonymous.BEEYOND INVESTMENTS will take appropriate technical and organizational measures to keep your personal data protected against unauthorized access or theft, as well as accidental loss, manipulation, or destruction. Access by BEEYOND INVESTMENTS personnel or third-party operators will be based only on the need to know and will be subject to strict confidentiality obligations. However, please understand that security and safety are diligence obligations that can never be guaranteed.
7. What are your rights according to this Cookie Policy?
As a data subject, you have several rights regarding the processing of your personal data. These rights include the right of access, the right to rectification, the right to withdraw consent previously given, the right to erasure, the right to object to the processing of personal data, and the right to receive from us in a commonly used and electronically readable format all personal data you have provided to us.
If you wish to exercise one or more of the rights listed above, you can send an email to contact@investbeeyond.com
You have the right to request access to all personal data processed by BEEYOND INVESTMENTS regarding you.
You have the right to request that any personal data that belongs to you and is inaccurate be corrected free of charge. If a request for correction is made, this request will be accompanied by proof of the nature of the incorrect data for which correction is requested.
You have the right to withdraw previously given consent for the processing of your personal data.
You have the right to request the deletion of personal data regarding you if they are no longer necessary in light of the purposes described in Article 3 or if you withdraw your consent for their processing. However, you should note that a request for deletion will be evaluated by us taking into account:
- our overriding interests, those of your financial institution, the payment service provider, or any third party;
- legal or regulatory obligations or administrative or judicial decisions that may prohibit such deletion.
Complaints and Petitions
These procedures regulate the manner in which the investment consultant examines and resolves complaints from its clients arising in its activity and are mandatory for all employees holding qualification certificates issued by CNPF (National Commission for Financial Market). The investment consultant keeps records of complaints from its clients.
All petitions/complaints can be submitted in person, by courier, by email, or sent by mail to the address of the investment consultant and must be registered in the Correspondence Register. The petition is submitted on paper or electronically in Romanian or in another language in accordance with the legislation.
The client's complaint/petition must contain the following information: informative data about the complainant, the complainant's name and surname, address of residence, phone number, email address (if available), clear description of the subject of the complaint/report, date of submission of the complaint, signature of the person who submitted the complaint/report.
The electronic petition must meet the requirements for electronic documents and contain information regarding the name, surname, residence, and email address of the petitioner, as well as other contact details.
Petitions containing information concerning national security or public order are forwarded for examination to the competent authorities.
All client correspondence is recorded in the consultant's records. Correspondence will include: order number, date of submission, name and surname of the sender, content (briefly).
In order to resolve the issues addressed in the petition as quickly and efficiently as possible, the responsible employee of the investment consultant may invite the petitioner to its headquarters, requesting, as appropriate, explanations, comments, and additional materials.
Repeated petitions that do not contain new arguments, facts, or information are not re-examined, and the petitioner shall be informed in writing or electronically about this fact. In the event that a person submits multiple petitions on the same subject during the same period, these petitions shall be consolidated, and the petitioner shall receive a single response.
If, after sending the response, a new petition with the same content or referring to the same issue is received, it shall be attached to the original petition, with a mention that a response has been provided, and the petitioner shall be informed accordingly.
In case a petition is signed by multiple individuals or legal entities, the person to whom the response shall be sent will be indicated. In the absence of this mention, the first signatory is considered the petitioner to whom the response shall be sent.
If a petition is illegible or does not contain sufficient information for examination, the petitioner shall be notified of this fact within 3 working days, requesting clarification of the addressed issues.
If a petition is addressed incorrectly, it shall be returned to the petitioner within 3 working days.
If a petition raises concerns regarding the conduct of an employee of the investment consultant, it cannot be examined by the person in question or by one of their subordinates.
Petitions shall be examined within a maximum period of 30 days, and those that do not require further study or examination shall be processed promptly or within 15 days from the date of registration. The examination period of petitions submitted by CNPF shall not exceed 15 days from their receipt, and if another deadline is indicated, it shall be adhered to.
In exceptional cases, the examination period may be extended by the head of the investment consultant by up to one month, and the petitioner shall be informed accordingly. Petitions requesting confidential information shall be examined within the deadlines established in the legislation on access to information.
The result of the examination shall be communicated to the petitioner on paper, and at their request, electronically or verbally, with appropriate entries in the Correspondence Register.
The employee of the investment consultant shall take measures to amicably resolve issues related to the quality of services provided by the investment consultant mentioned in the complaints/reports received from clients.
Petitions, responses to them, and documents related to the examination of petitions shall be kept in separate files. The files containing the examination materials of petitions shall be kept in office spaces or specially designated archive rooms, equipped with adequate means of preservation to prevent degradation, destruction, or theft of documents.
The investment consultant must ensure the confidentiality of data subject to the petition, as well as personal data regulated by Law no. 133/2011 "On the protection of personal data."
The head of the investment consultant is directly responsible for the proper organization and conduct of the activities related to receiving, examining, and resolving petitions, as well as the legality of the solutions and their timely communication.
Any situations arising in connection with the organization and conduct of activities related to the examination of petitions by the investment consultant, not provided for in this Regulation, shall be resolved in accordance with the applicable legislation.
The monitoring of compliance with this procedure is the responsibility of the executive body.