APPLICABLE GENERAL USER TERMS AND CONDITIONS FOR PIS V.1.0 (THE “TERMS”)

1. GENERAL INTRODUCTION

1.1 These terms and conditions apply when you, in the capacity of a natural person, (“you”, the “User”), use Trustly’s payment initiation services (“PIS” or the “Service”).

1.2 You are using the Service because you are on a website or app belonging to an online supplier of a product or service (a “Supplier”) and want to initiate a payment. You will find detailed information about the Service in section 4 below. 

1.3 The Service is provided by Trustly Group AB, company reg. no. 556754-8655, with address at Rådmansgatan 40, floor 5, 113 57 Stockholm, Sweden, (”us”, “Trustly") on the terms and conditions set out below (the “Terms”). 

2. THE TERMS

2.1 These Terms apply each time you use the Service. These Terms do not constitute a framework agreement between you and Trustly. You must agree to the Terms in force at any given time in order to use the Service, so please make sure to read these Terms carefully each time you use the Service. If you do not agree to these Terms, do not proceed with  use of the Service. The Terms may be revised from time to time without prior notice and the revised version will be labelled with a new version number. 

2.2 Once you have entered all the required details into the various parts of the Trustly online interface and clicked “continue” (or similar call for action button), you will be deemed to have expressly requested and authorised Trustly to perform the Service in accordance with these Terms. You hereby acknowledge and agree that this authorisation is received by Trustly immediately following your request and that you cannot withdraw or revoke the authorisation after this time. 

2.3 You are entitled to receive these Terms in the physical form of a document or in some other permanent form, by contacting our Support team (see contact details in Section 15 below). You can view the latest version of these Terms at any time via our website and in direct connection with using our Service. 

3. ABOUT TRUSTLY

3.1 Trustly is a Swedish licensed payment institution authorised and supervised by the Swedish Financial Supervisory Authority (Sw. Finansinpsektionen). Trustly performs the Service in accordance with the Swedish Payment Services Act (2010:751) and Directive (EU) 2015/2366 on payment services (PSD2). 

4. ABOUT THE SERVICE

4.1 As described above, you are using the Service because you are on a website or app belonging to a Supplier and want to make a payment or transfer of money from your bank account.  

4.2 The Service consists of an additional interface between you and the interface of your online bank, designed specifically for the purpose of allowing you to execute a swift and secure bank transfer, in a user-friendly interface without any additional software or registration arrangements. To use the Service you need a device with internet connectivity that supports an internet browser as well as access to whatever technical equipment and / or software that your bank requests that you use in order to authenticate yourself towards your bank. The Service is of a one-off nature limited to each use of PIS.

4.3 The login information and security credentials (“Credentials”) provided by you when using the Service may be collected and processed by Trustly. Trustly will, when relevant, forward the information, through the Service interface, to the corresponding interface of your online bank through a secure connection. All communication transferred when using the Service is encrypted and your Credentials are only forwarded to the corresponding input-field of the selected bank but is never stored. Neither Trustly nor the Supplier will be able to access your Credentials at any time and neither Trustly nor the Supplier will store your Credentials.

4.4 Trustly provides a regulated PIS. This is a payment solution supporting the execution of single payment transactions from bank accounts in many European countries to a Supplier (“Transaction”). 

4.5 When you choose to make a Transaction, you will typically be directed to a Trustly page to select your bank and the bank account from which you wish to make a Transaction. In order to allow you to select the bank account from which you will make the Transaction, Trustly may use AIS to collect a list of available bank accounts (see further information in separate terms for AIS available here). Alternatively, you will be directed to a Trustly page to select your bank and then be redirected to an interface controlled by your bank to select your bank account. By selecting your bank, and when relevant bank account, you consent to use the Service and instruct Trustly to initiate a Transaction of your chosen amount, details of which will be clearly displayed to you. After you select your bank and bank account, you will undergo authorization of the Transaction using Credentials issued by your bank. Once you have authorized the Transaction with your bank, funds will usually leave or be reserved on your bank account immediately. Trustly will then confirm the successful initiation of the Transaction. Following this, you cannot request Trustly to revoke the Transaction.

5. USER REQUIREMENTS

5.1 To use the Service, you must be of at least eighteen (18) years old, or of such older age as required by the Supplier. Moreover, you must have the capacity to enter into legally binding contracts and have the right to dispose of the assets available on your online bank. By agreeing to the Terms, you hereby guarantee that these requirements are met. 

5.2 To be able to use the Service, you must personally fill out and complete all steps presented to you in the flow described in section 4 above.

6. USER RESPONSIBILITIES 

6.1 Any use of the Service, including but not limited to the use of Credentials, shall be deemed to be carried out by the authorized owner of the relevant bank account. 

6.2 You hereby warrant that you:

(i) will not use the Service in the capacity of a legal person or by using a corporate account,

(ii) will not use the Service for any fraudulent, unlawful or abusive purpose, 

(iii) the Credentials you use are your own and you are duly authorised to use those in order to use our Service, 

(iv) will provide Trustly with true and complete data, and not misrepresent, withhold, or modify any data,

(v) are the holder of the bank account where the Account Information Data, as defined in our separate terms for AIS available here, will be retrieved from and have the right to make available the data to Trustly, and transfer it to the Supplier, including, where relevant, with the consent of any co-holder of the relevant bank account, 

(vi) are the holder of the bank account from which the Transaction will be made and have the right to complete the Transaction and make a payment to the Supplier, including, where relevant, with the consent of any co-holder of the relevant bank account,

(vii) protect your technical equipment and the confidentiality of your Credentials, to make sure that this is not used by any unauthorized party, 

(viii) are using the Service personally and do not allow any third party to use it, 

(ix) shall not use the Service for any purpose that is in violation of your agreements with third parties, these Terms or applicable law. 

6.3 You are personally responsible for any and all violations of the Terms. You agree and acknowledge that Trustly may (i) suspend access to the Service, and (ii) claim damages for any damage caused to Trustly or any third party, due to your failure to comply with these Terms. 

6.4 If you know or suspect unauthorized use of the Service, including your Credentials, you must immediately notify us via the contact form on Trustly’s Support page, and report the unauthorized use of the Service to the bank in which you hold the bank account selected for the performance of the Service. The bank, and not Trustly, will decide whether you shall be reimbursed for any loss in accordance with your agreement with your bank. It is very important that you as soon as possible report any unauthorised use to your bank as you otherwise might not be able to claim a refund from your bank.

7. PERSONAL DATA

7.1 By using the Service, you acknowledge that personal information about you is collected from your online bank and Supplier in order to be processed by Trustly in accordance with, and for the purposes, set out in our Privacy Policy. It is important for Trustly to protect your personal data. Trustly processes your personal data in accordance with applicable data protection legislation. For more information, including information on who we may share your personal data with, see our Privacy Policy.

8. PROCESSING TIMES

8.1 A Transaction is transferred via general clearing systems, meaning it might in exceptional cases take up to three (3) Bank Days before funds from the Users are settled with the Supplier.

9. CHARGES

9.1 Trustly does not charge you for any fees for the provision of the Service via the Supplier.

9.2 However, a foreign transaction (FX) fee charged by Trustly may apply when you make a Transaction in a currency other than what is available on your relevant bank account. The FX fee is based on a reference currency exchange rate provided by Oanda Corporation (185 Berry Street, Suite 4700, San Francisco, CA 94107) to which Trustly then adds an FX fee. The FX fee will be displayed to you in Trustly’s interface prior to authenticating the Transaction. In addition, an FX fee can be incurred in cases where your Supplier is sending you funds, for instance due to a refund, and is refunding you in a currency different than the currency of your bank account.

9.3 For the avoidance of doubt, you are responsible for any costs when using the Service that you may incur from parties other than Trustly, such as bank charges and data traffic costs. 

10. SERVICE AVAILABILITY

10.1 Trustly strives to provide an excellent Service, but does not guarantee the availability of the Service. Trustly is not responsible for any losses, damages or similar if the Service is down, not functioning as intended or expected, if the Account Information Data is incorrect in any way, or similar, to the extent permitted under applicable law. 

11. UPDATES AND CHANGES

11.1 Trustly is entitled to implement updates and new versions of the Service to the extent Trustly considers appropriate. Trustly is also entitled to implement changes to the Service or the way the Service is provided without prior information.

12. SUSPENSION 

12.1 Trustly may have to suspend the Service to (i) deal with technical changes or (ii) update the Service to reflect changes in relevant laws and regulatory requirements.

12.2 Trustly unilaterally reserves the right to suspend a Transaction or you as a User in the event of suspected criminal or illicit activity, imminent civil actions by third parties due to the provision of the Service, or any other act or omission such as severe malfunction or misuse of the Service. If Trustly deems the conditions set out in these Terms not to be satisfied, or if it would be unlawful for Trustly to perform the Service, we may refuse to do so. If so, Trustly or the Supplier will notify you, unless the law prevents us from doing so.

13. COMMUNICATION

13.1 General information about our Service and these Terms is provided on an ongoing basis via our website www.trustly.net or via our interface used when you are using the Service. Security related information will be communicated via our dedicated page for security, https://www.trustsly.net/security.

14. ACCESSIBILITY STATEMENT (EFFECTIVE DATE, JUNE 28TH 2025)

14.1 At Trustly, we are committed to providing banking services that are accessible to all our customers, including those with disabilities. We strive to ensure that everyone can access and use our services independently and with dignity. This commitment is in line with our values and our legal obligations under the Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services (the "EAA") and its transposition into Swedish law, Lag (2023:254) om vissa produkters och tjänsters tillgänglighet (the "Swedish Accessibility Act").

14.2 Our full Accessibility Statement, linked here, outlines how we meet the relevant accessibility requirements set out in Annex I of the EAA and the applicable requirements of the Swedish Accessibility Act. We also describe any known accessibility issues and how you can report issues to us so that we can fix them.

15. QUESTIONS AND COMPLAINTS

15.1 Providing you with excellent Service is important to Trustly. If you notice any indication of malfunction of the Service, please notify us promptly.

15.2 If you have any questions relating to the Service you can contact our Support team via the contact form on Trustly’s Support page. Trustly will communicate with you electronically and in English. You have a right to request a translation into the official language where the Service is offered, and that any information shall be delivered to you in a physical form by ordinary mail.

15.3 If you are not happy with our Service and wish to submit a complaint, we encourage you to contact us directly. Our dedicated Complaints Manager is the point of contact for complaints and can be reached via this Complaints form or by sending a letter to the address below:

Trustly Group AB

To: Complaints Manager

Box 45020
104 30 Stockholm
Sweden

‍

15.4 Trustly follows the Swedish Financial Supervisory Authority’s general guidelines on complaints management (FFFS 2002:23) and handles complaints in accordance with existing regulations. 

15.5 In case you are not satisfied with Trustly’s handling of your complaint or if you need additional assistance or advice, you can also turn to independent consumer guidance. You can find more information from the following bodies: 

• The Swedish Consumers’ Banking & Finance Bureau (Sw: Konsumenternas Bank- och finansbyrå), which provides independent guidance on banking and financial services. More information is available at: https://www.konsumenternas.se/om-oss/in-english/
• The Swedish Consumers’ Insurance Bureau (Sw: Konsumenternas Försäkringsbyrå), which offers independent advice on insurance matters. More information available at: https://www.konsumenternas.se/om-oss/in-english/
• For Swedish residents: Municipal consumers’ advice officials (Sw: Kommunala konsumentvägledare), who provide general consumer advice in your municipality. More information available at: https://www.konsumentverket.se/konsumentratt/kommunal-konsumentvagledning/
• The European Consumer Centre (Sw: Konsument Europa), for cross-border disputes involving companies in EU countries, Norway, or Iceland. More information available at: https://www.eccnet.eu/contact-your-local-ecc.
  
  

15.6 If you are not satisfied with Trustly’s handling of your complaint, you have the right to have your case tried by the Swedish National Board for Consumer Disputes (Sw: Allmänna reklamationsnämnden, ARN). ARN is a public body that provides impartial, non-binding recommendations. More information is available at: https://www.arn.se/om-arn/Languages/english-what-is-arn/

15.7 For further information on how Trustly handles questions and complaints, please visit https://www.trustly.com/support.

16. CUSTOMER DUE DILIGENCE

16.1 The Transactions executed by you are subject to monitoring for the purposes of complying with applicable regulations on anti-money laundering and countering the financing of terrorism. To comply with relevant regulations, information may be requested from you in order to establish for instance your identity, purpose of the payment transaction and origin of funds. By executing a payment transaction through the Service, the User commits to provide any and all such information as may be deemed necessary for these purposes and recognize that non-compliance with such request may result in refusal to complete the payment transaction of the User or other consequences as called for. For the purposes of complying with applicable regulations, records with information on you will be kept by Trustly.

17. INTELLECTUAL PROPERTY

17.1 Trustly owns all intellectual property rights in and to the Services, our website and technology. If you choose to give us feedback or suggestions about any part of our Service, website or technology Trustly may use such feedback or suggestions without any limitations and without payment to you.

18. LIABILITY AND COMPENSATION

18.1 It is your account servicing payment service provider, i.e. your bank, that is responsible for executing the transaction you initiate using the Service. Trustly is not responsible for the accurate execution of a Transaction once you have completed the necessary actions using the Service and Trustly has submitted the correct and relevant instructions to your bank to execute the Transaction.

18.2 If a payment order is not executed or has been executed in an inadequate way, and these inadequacies were caused by Trustly, Trustly is responsible in relation to you. In such cases we will try to trace the payment order as soon as possible and notify you or your account servicing payment service provider (i.e.your bank) of the result.

18.3 To the extent Trustly is liable, this liability is limited to foreseeable loss or damage caused by Trustly to the extent set out in these Terms or by mandatory law. Trustly is not liable for indirect loss or damages incurred due to the use of the Service unless caused by Trustly’s gross negligence.

18.4 Your purchase of goods, services, digital content or otherwise from a Supplier by using the Services will at all times be subject to the Supplier's own terms and conditions, and Trustly shall in no way be liable for the actions or inactions of the Supplier. Please ensure that you have reviewed and accepted the Supplier's terms and conditions (including their privacy policy)  before using the Service. 

18.5 Trustly is not responsible for any harm, damage or loss arising from, or relating to, hacking, tampering or in any other way unauthorized access to your Credentials or use of the Service that is not within our reasonable control.

19. FORCE MAJEURE

19.1 Trustly is not liable for any economic loss, damage, delay or failure of performance to the extent such loss, damage, delay or failure is caused by fire, flood, explosion, war, strike, blockade, boycott, lockout, embargo, governmental requirements and/or actions, new legislation, civil and military authority, data trespass, denial-of-service (DoS) attack, unlawful action of the User or any other cause or similar circumstances beyond Trustly’s reasonable control. The reservation as regards strike, blockade, boycott, lockout and similar also applies if Trustly is itself the subject of or implements such industrial action. 

20. ASSIGNMENT

20.1 You may not assign or transfer any rights or obligations you have according to the Terms. Trustly is entitled to assign all or parts of its rights and obligations according to the Terms, provided that such assignment or transfer is not to your disadvantage and does not change the rights and obligations you have according to the Terms.

21. SEVERANCE

21.1 If any provision of these Terms is found by any court or administrative body of competent jurisdiction to be invalid or unenforceable, such invalidity or unenforceability shall not affect the other provisions of these Terms which shall remain in full force and effect. If any provision of these Terms is found to be invalid or unenforceable, but would cease to be invalid or unenforceable if some part of the provision were deleted, the provision in question shall apply with such modification as may be necessary to make it valid and enforceable.

22. CONTRACT TERM

22.1 These Terms apply for the performance of the Service that you have requested Trustly to perform. Each time you use the Service, you will need to approve the current version of the Terms. For the avoidance of doubt, these Terms do not constitute a framework agreement between you and Trustly.

23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1 These Terms shall be governed by the laws of Sweden. Disputes shall primarily be resolved by negotiations in good spirit between the parties. Should the parties not be able to reach an amicable agreement, the dispute shall be resolved by a Swedish general court.

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Trustly Group AB (556754-8655)
Rådmansgatan 40, floor 5
113 57 Stockholm/Sweden
website: https://www.trustly.com
email: contactus@trustly.com

Supervised by the Swedish Financial Supervisory Authority
Box 7821
103 97 Stockholm
Email: finansinspektionen@fi.se
Phone: +46 8 408 980 00