TWIG SOLUTIONS LIMITED USER AGREEMENT

Effective Date: 21 November 2022



PART 1: GENERAL USE


1- Basic TWIG Services.

  1. Eligibility. To be eligible to use the TWIG Services, you must be at least 18 years old. You are required to have an eligible device in order to use the Service. We, at our own discretion, shall determine which devices are eligible to be used with the Service and shall provide you with a list of such devices or types thereof on request by You in the event you encounter an issue. Devices that have been unlocked in an unauthorised fashion or otherwise modified may not be eligible to use the Services. You are responsible for ensuring you maintain access to all devices and accounts (such as your registered email account and Your Account) as necessary to receive communications from us in relation to the Services.
  2. Client Classification. We will treat you as a Retail Client as defined by the DFSA’s Rules.
  3. TWIG Services. Your TWIG account ("TWIG Account") encompasses the following Services:
    (a) Access to the TWIG Platform (“Access”);
    (b) Automated saving plans (“Saving Plans”);
    (c) Budgeting tools and tailored insights (“Budgeting”);
    (d) Smart, customizable and user-specific Goals ("Goals");

    (Collectively the "Services").

    We are authorised by the DFSA to carry out money services including :
    • Financial Service
    • Providing Money Services as follows:
      1. providing Money Transmission;
      2. issuing Stored Value.
    • Arranging or Advising on Money Services:
      1. making arrangements for another Person to receive Money Services;
      2. giving advice to another Person on the merits of using a particular Money Services Provider;
      3. providing an Account Information Service;
      4. providing a Payment Initiation Service.


We may hold Client Money (as defined in the DFSA Rules) on your behalf. Client Money held on your behalf is subject to the DFSA’s Client Money Provisions, as a result: (a) all Client Money is held separate from money belonging to TWIG; and (b) in the event of insolvency, winding up or other distribution event (as defined in the DFSA Rules), the Client Money will be subject to the DFSA’s Client Money Distribution Rules.


We will not pay interest on any Client Money held on your behalf. We may hold Client Money in a jurisdiction outside of the DIFC. The market practices, insolvency and legal regime applicable in that jurisdiction may differ from the regime applicable in the DIFC.


Please see Annex III (Payment Terms) for further details as payments and fees.



2- Creating a TWIG Account.

  1. Registration of TWIG Account. In order to use the Services, you will need to register for a TWIG account (a "TWIG Account"). During the registration process, we will ask you for information, including your name and other personal information to verify your identity. We may, in our sole discretion, refuse to open a TWIG Account for you, or limit the number of TWIG Accounts that you may hold.
  2. Identity Verification. During registration of your TWIG Account, you agree to provide us with the information we request for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information. You will need to complete certain verification procedures before you are permitted to use the Services. Your access to one or more Services and the limits that apply to your use of the Services, may be altered as a result of information collected about you on an ongoing basis. The information we request may include certain personal information, including, but not limited to, your name, address, telephone number, e-mail address, date of birth, a government identification, and information regarding your bank account (such as the name of the bank, the account type, routing number, and account number). The KYC steps are further detailed under Annex I (“KYC Process”). In providing us with this or any other information that may be required, you confirm that the information is accurate and authentic. You agree to keep us updated if any of the information you provide changes. You authorize us to make inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full. This is an identity check only and should have no adverse effect on your credit rating. Additionally, we may require you to wait some amount of time after completion of a transaction, before permitting you to use further Services and/or before permitting you to engage in transactions beyond certain volume limits, which is further detailed under ITL Disclosures.

3- TWIG Mobile Application;
TWIG is a bank agnostic automated saving platform for the MENA region. TWIG offer 1) Automated Saving plans, 2) Smart budgeting tools, and 3) Personalized saving goals.


TWIG’s Automated Savings Plans include the Roundup (Save on every purchase), Routine (Recurrent time deposits) and Leftover (AI-based saving related to your budget).
TWIG’s Smart Budgeting categorizes the user's transactions and provides the user with insights on how to reduce their expenditures. TWIG’s budgeting tool is flexible based on the user's pay cycle.


TWIG’s Personalized saving goals allow the user to save money for what matters to them most. TWIG’s algorithm will allocate the money directly towards the goals, based on the user prioritizations, goal duration and amounts to be saved every month.


TWIG reserves the right to refuse to process or to cancel any pending transaction as required by law or in response to any regulatory notices, court order, or other binding government order or to enforce transaction limits as decided by Dubai Financial Services Authority (“DFSA”) from time to time. TWIG cannot reverse a transaction. If you have any questions about transactions, please write to [email protected].


4- Saving with TWIG
Our Automated Savings Plans include the Roundup (Save on every purchase), Routine (Recurrent time deposits) and Leftover (AI-based saving related to your budget).


User can create a new saving plan from the app by selecting the desired plan and setting the parameters. Users can pause, or delete plans at any times.


Savings will be initiated once the user set parameters / conditions are achieved. An example - Every Monday, deposit AED50 into User’s saving. On Monday, TWIG will send a notification to the user to confirm that they wish to deposit the AED 50 into their TWIG saving account


Once confirmed, TWIG will initiate a transfer transaction from the user bank account to TWIG client money account


5- Withdrawals of Savings
Withdrawals can be initiated by the user at any point in time and will be done through a bank transfer within 1 working day.


6- Completion of Transaction.
Transaction refers to a bank-to-bank transfer.

For savings the transaction flow will be from user to TWIG user account. The transaction will be completed once the funds are received to TWIG’s user account.

For withdrawal, the transaction flow will be from TWIG user account to user bank. The transaction will be completed once it is confirmed by the processing bank that the transaction is successful. 


A transaction is not complete while it is in a pending state. Funds associated with transactions that are in a pending state will be designated accordingly and will not be included in your TWIG Account balance or be available to conduct transactions. TWIG may charge network fees to process a Transaction on your behalf. TWIG will calculate the network fee in its discretion, although TWIG will always notify you of the network fee at or before the time you authorize the Transaction. TWIG reserves the right to delay any Transaction if it perceives a risk of fraud or illegal activity.


7- Storage & Transmission Delays. The user might face transmission delays as the transactions for deposits depends upon the bank’s reconciliation to complete the transaction which may take up to 2 business days under normal circumstances.

Withdrawals will be processed once a day with potential for additional delays from banks to process the transaction with up to 2 business days.


As a result of the above, it may be necessary for TWIG to retrieve certain information from offline storage in order to facilitate a Transaction in accordance with your instructions, which may delay the initiation or crediting of such Transaction for 48 hours or more. You acknowledge and agree that a Transaction facilitated by TWIG may be delayed.


8- ITL Disclosures.
TWIG declares that the current TWIG is holding with DFSA is Innovation Testing Licence (the “Licence” or “ITL”) is restricted, whereby certain restrictions apply on the Licence throughout the entire testing period. You hereby acknowledges and understands that:

  1. Maximum payment transaction value per day, per user will not exceed USD 1,000. On any given day, You may not send payments which, in aggregate, exceed the above limit (regardless of the currency in which payments are sent; we will apply exchange rates at the prevailing rate when determining whether the daily limit has been exceeded). We will not process any transaction which will cause You to exceed the daily limit.
  2. Total Balance with TWIG at any point should not exceed USD 5,000.
  3. The Services are provided to you by TWIG is for the sole purpose of aiding the TWIG in testing and developing such innovative services under the Licence and ITL Program.
  4. The ITL Program enables TWIG to test its business model in a controlled and restricted regulatory environment, in and from the DIFC, under a regulatory testing plan during a testing period.
  5. Your participation in testing of the Services may not be protected and may have limited rights if you suffer loss.
  6. TWIG makes no representations or warranties of any kind with respect to the Services, including any representation or warranty that the use of Services will (a) be timely, uninterrupted, error-free, free of defects, or (c) meet your expectations or requirements, (d) be entirely secure or that the information you shares with the Company will be secure.
  7. YOU UNDERSTAND AND AGREE THAT THE SERVICES ARE PROVIDED TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS. WITHOUT LIMITING THE FOREGOING, TO THE FULL EXTENT PERMITTED BY LAW, TWIG DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.

9- Payment Services Partners. TWIG may use a third party payment processor to process any payment between you and TWIG, including but not limited to payments in relation to your use of the Service - deposits or withdrawals from your wallet.


10- General Use, Prohibited Use, and Termination.
Limited License. We grant you a limited, nonexclusive, non-transferable license, subject to the terms of this agreement, to access and use the TWIG Site, and related content, materials, information (collectively, the "Content") solely for approved purposes as permitted by TWIG from time to time. Any other use of the TWIG Site or Content is expressly prohibited and all other right, title, and interest in the TWIG Site or Content is exclusively the property of TWIG and its licensors. You agree you will not copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part. "TWIG", and all logos related to the TWIG Services or displayed on the TWIG Site are either trademarks or registered marks of TWIG or its licensors. You may not copy, imitate or use them without wig's prior written consent.


Website Accuracy. Although we intend to provide accurate and timely information on the TWIG Site, the TWIG Site (including, without limitation, the Content) may not always be entirely accurate, complete or current and may also include technical inaccuracies or typographical errors. In an effort to continue to provide you with as complete and accurate information as possible, information may be changed or updated from time to time without notice, including without limitation information regarding our policies, products and services. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the TWIG Site are your sole responsibility and we shall have no liability for such decisions. Links to third-party materials (including without limitation websites) may be provided as a convenience but are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third party sites accessible or linked to the TWIG Site.


Third-Party Applications. If, to the extent permitted by TWIG from time to time, you grant express permission to a third party to access or connect to your TWIG Account, either through the third party's product or service or through the TWIG Site, you acknowledge that granting permission to a third party to take specific actions on your behalf does not relieve you of any of your responsibilities under this Agreement. You are fully responsible for all acts or omissions of any third party with access to your TWIG Account. Further, you acknowledge and agree that you will not hold TWIG responsible for, and will indemnify TWIG from, any liability arising out of or related to any act or omission of any third party with access to your TWIG Account. You may change or remove permissions granted by you to third parties with respect to your TWIG Account at any time through the account settings page on the TWIG Site.


Prohibited Use. In connection with your use of the TWIG Services, and your interactions with other users, and third parties you agree and represent you will not engage in any prohibited business or prohibited use as per the applicable laws and regulations. We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request. We reserve the right to cancel and/or suspend your TWIG Account and/or block transactions or freeze funds immediately and without notice if we determine, in our sole discretion, that your Account is associated with a Prohibited Use and/or a Prohibited Business.


Transactions Limits. The use of all TWIG Services is subject to a limit on the amount of volume, stated in U.S. Dollar terms, you may transact or transfer in a given period (e.g., daily). To view your limits, login to your TWIG Account. Your transaction limits may vary depending on your payment method, verification steps you have completed, and other factors. TWIG reserves the right to change applicable limits as we deem necessary in our sole discretion or as directed by DFSA.


Suspension, Termination, and Cancellation. This Agreement commences on the date that You register for an Account with Us on the App. The Agreement will continue unless and until terminated in accordance with the provisions of this Clause. Unless otherwise agreed in writing by You, You may terminate this Agreement at any time by sending a request to [email protected] Upon closure of Your Account, any pending transactions will be cancelled.


TWIG may: (a) suspend, restrict, or terminate your access to any or all of the TWIG Services, and/or (b) deactivate or cancel your TWIG Account if:

  • We are so required a regulatory notice, court order, or binding order of a government authority / regulator; or
  • We reasonably suspect you of using your TWIG Account in connection with a prohibited use or business; or
  • Use of your TWIG Account is subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your account activity; or
  • Our service partners are unable to support your use; or
  • You take any action that TWIG deems as circumventing TWIG's controls, including,
  • but not limited to, opening multiple TWIG Accounts or abusing promotions which
  • TWIG may offer from time to time.

If TWIG suspends or closes your account, or terminates your use of TWIG Services for any reason, we will provide you with notice of our actions unless a court order or other legal process prohibits TWIG from providing you with such notice. You acknowledge that TWIG's decision to take certain actions, including limiting access to, suspending, or closing your account, may be based on confidential criteria that are essential to TWIG's risk management and security protocols. You agree that TWIG is under no obligation to disclose the details of its risk management and security procedures to you. You authorize us to cancel or suspend any pending transactions at the time of cancellation.


Relationship of the Parties. TWIG is an independent contractor for all purposes. Nothing in this Agreement shall be deemed or is intended to be deemed, nor shall it cause, you and TWIG to be treated as partners, joint ventures, or otherwise as joint associates for profit, or either you or TWIG to be treated as the agent of the other.


Privacy ; User Information. We use Your personal data in the manner set out in Our Privacy Policy available at https://twig.ae/privacy and as further described in this Agreement. By using the Service and the App, You accept and acknowledge the collection and use of Your personal data in the manner set out in the Privacy Policy. If we decide to change Our Privacy Policy, We will post those changes on the Privacy Policy page so that You are always aware of what information We collect, how We use it and under what circumstances We disclose it. You should check the Privacy Policy frequently for changes. We will protect Your personal data and maintain its confidentiality including where it is held by an agent or third party on behalf of Us and ensure that We have in place and maintain adequate policies, procedures and controls. As a DIFC-based business, we are required to comply with the DIFC Data Protection Act 2020. Further details are set out in Our Privacy Policy.


Privacy of Others; Marketing. If you receive information about another user through the

TWIG Services, you must keep the information confidential and only use it in connection with the TWIG Services. You may not disclose or distribute a user's information to a third party or use the information except as reasonably necessary to effectuate a transaction and other functions reasonably incidental thereto such as support, reconciliation and accounting unless you receive the user's express consent to do so. You may not send unsolicited email to a user through the TWIG Services.


Password Security; Contact Information. You are responsible for maintaining adequate security and control of any and all IDs, passwords, hints, personal identification numbers (PINs), API keys or any other codes that you use to access the TWIG Services. Any loss or compromise of the foregoing information and/or your personal information may result in unauthorized access to your TWIG Account by third-parties and compromise of your data and the loss or theft of any funds held in your TWIG Account and any associated accounts. You are responsible for keeping your email address and telephone number up to date in your account profile in order to receive any notices or alerts that we may send you. We assume no responsibility for any loss that you may sustain due to compromise of account login credentials due to no fault of TWIG and/or failure to follow or act on any notices or alerts that we may send to you. In the event you believe your TWIG Account information has been compromised, contact TWIG Support immediately at [email protected].  


Taxes. It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the TWIG Services, and to withhold, collect, report and remit the correct amounts of taxes to the appropriate tax authorities. Your transaction history is available through your TWIG Account.


Unclaimed Property. If TWIG is holding funds in your account, and TWIG is unable to contact you and has no record of your use of the Services for several years, applicable law may require TWIG to report these funds as unclaimed property to the applicable jurisdiction. If this occurs, TWIG will try to locate you at the address shown in our records, but if TWIG is unable to locate you, it may be required to deliver any such funds to the applicable state or jurisdiction as unclaimed property. TWIG reserves the right to deduct a dormancy fee or other administrative charges from such unclaimed funds, as permitted by applicable law.


11- Customer Feedback, Queries, Complaints
Contact TWIG. If you have any feedback, questions, or complaints, write to us at [email protected] When you contact us please provide us with your name, address, and any other information we may need to identify you, your TWIG Account, and the transaction on which you have feedback, questions, or complaints.

TWIG’s complaint handling process is further detailed under Annex IV. For any complaints or queries, the User can write to [email protected].


12- General Provisions.
Computer Viruses. We shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of a reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from TWIG. Always log into your TWIG Account through the TWIG Platform to review any transactions or required actions if you have any uncertainty regarding the authenticity of any communication or notice.


Release of TWIG; Indemnification. If you have a dispute with one or more users of the TWIG services, you release TWIG, its affiliates and service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives from any and all claims, demands and damages (actual and consequential) of every kind and nature arising out of or in any way connected with such disputes. You agree to indemnify and hold TWIG, its affiliates and Service Providers, and each of its or their respective officers, directors, agents, joint venturers, employees and representatives, harmless from any claim or demand (including attorneys' fees and any fines, fees or penalties imposed by any regulatory authority) arising out of or related to your breach of this Agreement or your violation of any law, rule or regulation, or the rights of any third party.


Entire Agreement. This Agreement, Annexes, the privacy Policy, e-sign consent, and any appendices incorporated by reference herein comprise the entire understanding and agreement between you and TWIG as to the subject matter hereof, and supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), and every nature between and among you and TWIG. Section headings in this Agreement are for convenience only, and shall not govern the meaning or interpretation of any provision of this Agreement.


Amendments. We may amend or modify this Agreement by posting on the TWIG Site or emailing to you the revised Agreement, and the revised Agreement shall be effective at such time. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your account. You agree that we shall not be liable to you or any third party for any modification or termination of the TWIG Services, or suspension or termination of your access to the TWIG Services, except to the extent otherwise expressly set forth herein. If the revised Agreement includes a material change, we will endeavour to provide you advanced notice via our website and/or email before the material change becomes effective.


Assignment. You may not assign any rights and/or licenses granted under this Agreement. We reserve the right to assign our rights without restriction, including without limitation to any TWIG affiliates or subsidiaries, or to any successor in interest of any business associated with the TWIG Services. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns.


Severability. If any provision of this Agreement shall be determined to be invalid or unenforceable under any rule, law or regulation or any governmental agency, local, state, or federal, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of this Agreement shall not be affected.


Change of Control. In the event that TWIG is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control.


Survival. All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, sections pertaining to suspension or termination, TWIG Account cancellation, debts owed to TWIG, general use of the TWIG Site, disputes with TWIG, and general provisions, shall survive the termination or expiration of this Agreement.


Governing Law; Dispute Resolution. You agree that the laws of the Dubai International Financial Center, without regard to principles of conflict of laws, will govern this Agreement and any claim or dispute that has arisen or may arise between you and TWIG, except to the extent governed by UAE federal law. The disputes shall be adjudicated by DIFC courts.


Force Majeure. We shall not be liable for delays, failure in performance or interruption of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to, any delay or failure due to any act of God, act of civil or military authorities, act of terrorists, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.


English Language Controls. Notwithstanding any other provision of this Agreement, any translation of this Agreement is provided for your convenience. The meanings of terms, conditions and representations herein are subject to definitions and interpretations in the English language. Any translation provided may not accurately represent the information in the original English.


Additional Disclosures. You herewith confirm that you read and understood the additional disclosures incorporated under the Annex/s.


ANNEX I

KYC PROCESS


As a DFSA regulated financial service company, we are required to identify users on our platform. This ensures we remain in compliance with KYC/AML laws in the jurisdictions in which we operate, something that is necessary for us to be able to continue to offer Services to our customers. TWIG collects and verifies information about you in order to:


(a) protect TWIG and the community from fraudulent users, and

(b) to keep appropriate records of TWIG's customers.


All users who wish to use TWIG Services are required to establish a TWIG Account by:


  • Providing your name and valid email address, a password and your state of residence,
  • Certifying that you are 18 years or older,
  • Accepting User Agreement and Privacy Policy, and
  • Verifying your identity by submitting the following information:
    • Full Name
    • Date of Birth
    • Employment Details
    • Emirates ID
    • Passport
    • Address and Proof of Address

ANNEX II

ADDITIONAL DISCLOSURES


  1. We treat all activities in respect of an Account to be Yours. You must only use the Services to transact on Your own account and not on behalf of any other person or entity. All activities under any applicable supplemental account shall be considered as activities of the Account.
  2. You must update registration information promptly upon any change so that it is at all times complete and accurate. We reserve the right to refuse to provide or discontinue the Service to any person or entity at any time for any reason.
  3. Funding, payments and transfers are displayed in Your Account and You should check Your wallet balance and transaction history regularly. You should report any irregularities or clarify any questions You have as soon as possible.
  4. We will provide You with a history of the transactions that You make under this Agreement free of charge, including details of the amounts, the fees, charges and commissions, the dates and times of execution and the reference numbers for each transaction. This history is available on the App for you to view at any time. If you wish to request additional account history in a downloadable format, please contact us at [email protected].
  5. An approved governance framework is in place to properly identify and manage any risks arising from Application Programming Interfaces (APIs).
  6. Proper controls to support cybersecurity, cyber resilience and data protection is in place.
  7. TWIG is constantly engaging with the API providers and support team to ensure that personal data being transmitted or stored is encrypted to enable privacy and integrity of data.
  8. TWIG uses multifactor authentication in the manner detailed below:
    • When you initially access our service, to ensure secure access
    • When you use an API to access, process or transmit personal data.
  9. TWIG adopts standardized APIs especially with regard to the API designs, data standards and information security standards.
  10. There is no conflict of interest for TWIG to provide the services to the User.


ANNEX III

TRANSACTION CHARGES


You agree to pay all applicable fees whenever You use Our Service. Our fees are detailed hereunder:

0.49% of transaction amount as transaction fees.

TWIG will notify You of the applicable fees from time to time but prior to You authorising a payment transaction. All fees are within TWIG’s discretion. All Fees are stated exclusive of any applicable sales taxes or similar (such as VAT) which TWIG may be required to collect from You. You agree to pay all such applicable taxes to TWIG.

TWIG reserves the right to change Our Fees at any time. Fees are assessed against the amount of the transactions, including all applicable charges. We will notify You of any changes to the Fees at least thirty (30) days in advance of such changes coming into effect. If You do not agree to these changes, You can elect not to use the Services at Your convenience, and You may terminate this Agreement without cost to You provided You tell us You wish to terminate before the end of the period which is thirty (30) days from the date We notify You of the change to the Fees.


ANNEX IV

COMPLIANT HANDLING PROCEDURE


All complaints made by Client(s) (the “Complainant”) against TWIG in connection with the provision or conduct of, or failure to provide its Services, shall be directed to the SEO through the following email address: [email protected].


Once received, TWIG records the complaint in the Register of Complaints and requests the Complainant to fill the Customer Complaints Form to initiate formal processing. Thereafter, TWIG provides the Complainant within 7 days with the contact details of the SEO, and key particulars of TWIG’s handling procedures free of charge.

In the event that TWIG considers that another Authorized Firm or Regulated Financial Institution is either entirely or partly responsible for the subject of a complaint, it may refer the complaint, or the relevant part thereof, in writing to the other Authorized Firm or Regulated Financial Institution provided that the Complainant consents in writing to such referral; and in which case TWIG will:

  • inform the Complainant in writing that the complaint has been referred, and include adequate contact details of any individual at the other Authorized Firm or Regulated Financial Institution responsible for handling the complaint; and
  • continue to deal with any part of the complaint not referred to the other Authorized Firm or Regulated Financial Institution.

TWIG aims to resolve all complaints within 15 business days; otherwise, TWIG will provide a written update to the Complainant. The SEO will subsequently record the resolutions of complaints in the Register of Complaints, and TWIG will advise the Complainant in writing of such resolution, and provide him with clear terms of redress. TWIG will as well inform the Complainant of other avenues for resolution of the complaint and provide him with the appropriate contact details, given that such Complainant is not satisfied with the terms of redress offered by TWIG.