You are reading this because a business has asked us to connect to your bank account, or to start a payment from it, on your instruction. These terms explain what we do, what we do not do, and what you can expect from us.
If you are a business looking for the terms on which you can use our services in your own product, please read our Client Terms of Service instead.
1. Who we are
1.1 We are Finexer LTD, a company registered in England and Wales with number 12191948, whose registered office is at 124 City Road, London, EC1V 2NX, England.
1.2 We are authorised by the Financial Conduct Authority under the Payment Services Regulations 2017, firm reference number 925695, as an Authorised Payment Institution. That authorisation allows us to provide account information services and payment initiation services. You can check this on the Financial Services Register at register.fca.org.uk. You can contact the FCA itself on 0800 111 6768 (or +44 20 7066 1000 from outside the UK), through fca.org.uk, or by writing to 12 Endeavour Square, London E20 1JN.
1.3 We never hold your money. We are not a bank and we do not have an account that your money passes through. When you ask us to start a payment, the money goes directly from your account to the account of the person you are paying.
1.4 Your statutory rights. Nothing in these terms excludes or restricts a right or protection under Part 6 or Part 7 of the Payment Services Regulations 2017 to the extent that it cannot lawfully be excluded or restricted. If a provision of these terms is inconsistent with such a right or protection that applies to you, the Regulations apply instead.
2. Words we use
Platform — the business whose website, app or service you are using, and which has asked us to access your account information or to start a payment for you. A Platform may be our direct customer, may be our registered agent, or may be a customer of our registered agent.
Your bank — the bank, building society or other provider that holds the account you are connecting or paying from.
Payee — the person or business receiving a payment you ask us to start.
Account information service — a service that retrieves information about your account from your bank and shares it as you have instructed.
Payment initiation service — a service through which we initiate a payment at your request by transmitting your instruction to your bank. Our responsibilities are described in clauses 8 and 12; we do not hold your money or execute the transfer of funds ourselves.
we, us, our — Finexer LTD.
3. How the different relationships fit together
3.1 There are several separate relationships here, and it helps to keep them apart.
3.2 You and us. These terms are the agreement between you and us. They cover only the account information service or payment initiation service that we provide.
3.3 You and the Platform. You have a separate agreement with the Platform for whatever it is providing to you. We are not part of that agreement and we are not responsible for the Platform's product or service. If you have a problem with what the Platform provides, you need to take it up with the Platform.
3.4 You and your bank. Your account, and your rights in relation to it, are governed by your agreement with your bank. We are not part of that agreement either.
3.5 Us and the Platform. We have a commercial agreement with the Platform, or with the business that supplies the Platform. The Platform pays us. You do not pay us anything for our service.
3.6 The Platform may not have permission from the FCA to provide account information services or payment initiation services itself, or it may have chosen to have us provide them instead. Either way, we are the provider of the regulated service, and these terms govern it rather than the Platform's terms.
4. Where the Platform is our agent
4.1 Some Platforms are registered with the FCA as our agent. That means they provide the account information service or payment initiation service under our authorisation, and we remain responsible to you for it.
4.2 You can check this yourself. Look up Finexer LTD on the Financial Services Register at register.fca.org.uk and open the section showing which firms are connected to us. Our registered agents are listed there.
4.3 We are responsible only for the regulated service. We are not responsible for anything else the agent provides to you, and these terms, rather than the agent's terms, govern the regulated service.
4.4 If a Platform stops being our agent, it can no longer provide the regulated service as our Agent. Where you have a live ongoing consent, and a lawful and technically viable wind-down or continuation directly with us is available, we will not end your connection abruptly merely because of a dispute between us and the Platform. We will use reasonable endeavours to allow an operational wind-down period of at least 30 days and may communicate with you directly. That operational objective does not shorten or replace any longer statutory notice that applies under clause 17.2A, which prevails. We may act sooner only where clause 17.2A, the law, a regulator, a court, a bank, security, suspected fraud or operational necessity permits or requires it.
5. Your consent
5.1 We only act when you tell us to. Before anything happens you will see a consent screen setting out what you are agreeing to, which accounts are involved, what information will be shared or what payment will be started, who it will be shared with, and, where relevant, for how long or that it will continue until you withdraw it.
5.2 Depending on what you are doing, your journey may involve an account information service, a payment initiation service, or both.
5.3 You can ask us for a copy of these terms at any time.
6. Signing in at your bank, and your security details
6.1 We will never come into possession of your bank login information or security credentials. We will never ask you for your online banking username, password, PIN, memorable information or one-time passcode, and we have no way of seeing them.
6.2 You always authenticate directly with your bank. We send you to your bank's own website or app, you sign in there and approve what you are being asked to approve, and your bank then tells us that you have done so. The way you are asked to authenticate is decided by your bank, not by us.
6.3 If any website, app or person ever asks you to enter your online banking credentials on a screen that is not your bank's, do not do it. If it happens in connection with our service, please tell us straight away at privacy@finexer.com.
6.4 You should keep your security details safe and not share them with anyone, including with a Platform.
7. Account information services
7.1 If you consent to an account information service, we retrieve information about the accounts you have chosen from your bank, and share it as your consent describes.
7.2 What is available depends on your bank, and may include your account details such as sort code and account number, the name on the account, your balance and your transaction history.
7.2A Information that may be sensitive. A transaction description written by your bank can sometimes mention something sensitive, such as a payment to a clinic, a place of worship or a political party. We do not look for this, we do not read or analyse your transactions to work anything out about you, and we pass the description on exactly as your bank recorded it. You can withdraw your consent at any time through the Platform or by contacting us. Withdrawal stops us retrieving anything further, but does not automatically delete information already shared with the Platform, which is governed by the Platform's own privacy policy. Our Privacy Policy explains this in full.
7.2B Depending on your bank. Whether, and how quickly, we can retrieve your information depends on the interface your bank makes available. Clause 11.2A explains what happens if it is unavailable or slow.
7.3 We can only read information. We cannot move money out of your account, change anything about your account, or change your banking credentials.
7.4 Your consent may be for a single access or for ongoing access. Ongoing access may run for a fixed period, in which case you are shown the end date before you agree and access stops on that date, or it may continue on an ongoing basis with no fixed end date until you withdraw it. Either way, you are told before you agree which applies.
7.4.1 If your consent lasts, or may last, longer than 90 days, your continued agreement must be reconfirmed at least every 90 days to keep access active. Depending on how you connected, we or the Platform may provide the way for you to reconfirm. Where the Platform operates that process, it is responsible for presenting it to you and sending us an accurate record of your reconfirmation. We may remind the Platform when reconfirmation is due, but we cannot guarantee that the Platform will present its prompt or successfully send us your response. Reconfirming does not ordinarily require you to sign in at your bank again.
7.4.2 If we do not receive a valid record of your reconfirmation within the 90-day period, we automatically pause the collection of new information from your bank, whatever the reason for the missing record. This protects your account information and does not, by itself, end your consent or your agreement with us. Collection may resume after we receive a valid reconfirmation, unless you have withdrawn your consent, a fixed end date has passed, or access is unavailable for another reason. Where a fixed end date applies under clause 7.4, reconfirming does not extend it.
7.4.3 Separately from this, your bank may sometimes ask you to sign in and authenticate, either because of how it has set things up or for its own security reasons, and access is unavailable until you have done that.
7.5 You can withdraw your consent at any time, and you do not need a reason. You can do it through the Platform, by contacting us, or through your bank. Once you withdraw it we stop accessing your account.
7.6 Withdrawing your consent stops us collecting new information. It does not automatically delete information already shared with the Platform or information we store for it as its processor. The Platform's retention instructions, its own privacy policy and our Data Processing Agreement govern that existing information, and you should contact the Platform about its continued retention or use.
8. Payment initiation services
8.1 If you consent to a payment initiation service, we pass your payment instruction to your bank. Your bank authenticates you and decides whether to make the payment. We do not make the payment ourselves.
8.1A How long it takes. We submit your instruction to your bank promptly. The maximum execution time required by law is made available to you before initiation. Your bank then authenticates you, decides whether to accept the payment, and carries it out, including on any future date you have chosen. We are responsible for receiving, recording and transmitting your instruction correctly, and for keeping evidence of it.
8.1B What it costs. We do not charge you for using our payment initiation service, and we do not convert currency or apply an exchange rate to your payment. Your payment is transmitted in the currency and amount specified in the instruction. Your own bank may separately charge you under your agreement with it.
8.1C After you approve. As soon as your payment has been initiated with your bank, we give you confirmation, a reference identifying the payment, the amount, and any charge payable to us, which is currently zero. We also pass the reference to your bank. Any status we show you is the status your bank has reported to us.
8.2 To make a payment, we need the Payee's account details as given to us by the Platform, being the sort code and account number of the account to be paid, or, where the payment is identified that way, the IBAN and BIC. Check the amount, the Payee and the reference carefully on your bank's screen before you approve a payment. Those details usually come from the Platform, and we cannot check that they are right.
8.3 Your money never passes through us. It goes directly from your account to the Payee's account.
8.4 Once you have approved a payment at your bank, we cannot cancel, change, recall or reverse it. If you need to stop a payment, contact your bank straight away.
8.5 A payment may be refused, may fail, or may take some time to arrive. That is generally decided by your bank or by the Payee's bank rather than by us. We will tell you what status your bank has reported to us and will distinguish successful initiation from execution.
8.5A Depending on your bank. Whether, and how quickly, your payment is processed depends on your bank, as clause 8.5 explains. Clause 11.2A explains what happens if your bank's interface is unavailable or slow.
8.6 If a payment does not reach the Payee, or reaches the wrong account, tell your bank. You may ask your bank to investigate it, and we will provide your bank with the information and cooperation reasonably required for that investigation.
8.7 If you want a refund of something you have bought, that is generally a matter between you and the Payee. This clause does not apply where you were deceived into authorising a payment to a fraudster, which is addressed in clause 12.2, or affect any statutory reimbursement right.
9. Verification
9.1 Some Platforms use our verification service. There are two kinds of check, and which one you experience depends on what the Platform has chosen.
9.2 An account check. Here we compare information the Platform gives us about you, such as your name, with the account holder information your bank holds for the account you connect, and we tell the Platform the result. This kind of check uses the account information service, so everything in clause 7 applies to it, including your right to withdraw your consent.
9.3 A document check. Here the Platform asks you for an identity document, such as a passport or driving licence, and sends it to us together with information about you. We read the required fields from the document, compare them with the information the Platform gave us, produce the result and, during the 30-day retention period in clause 9.6, use the document where reasonably necessary to resolve a query concerning that result. This kind of check does not involve your bank and does not access your account, and there is no consent screen from us, because we carry it out on the Platform's instructions rather than under an agreement with you. A document-reading service provided by Microsoft Azure carries out the reading for us, in the United Kingdom.
9.4 How we use your document. We use it only to read the required fields, perform the comparison, produce the result and resolve a query concerning that result during the 30-day retention period. We do not use it to train or improve any technology. Our result speaks to the details we compared and to those alone; whether the document itself is genuine is a matter for the Platform that asked you for it.
9.5 The Platform decides whether to ask you for a document. It chooses the check, asks you for the document, and is responsible for explaining why it needs it and for having your agreement before sending it to us. If you were not expecting to be asked for an identity document, ask the Platform about it before you provide it. Because we carry out a document check on the Platform's instructions, questions about why it was done, and requests about the information involved, are for the Platform in the first instance, and we will help it answer them.
9.6 How long we keep it. We remove the image of your document from active systems no later than 30 days after the check. We keep the detail we read from it and the result for as long as the Platform's instructions require. For an account check, we keep the result and the consent and audit evidence for five years, to evidence the regulated service we provided and to respond to complaints and regulatory enquiries. Our Privacy Policy sets out our retention periods in full. The Platform may keep its own copy of your document on its own terms, so a request to delete that copy should go to the Platform.
9.7 The result we return is information for the Platform to act on. Any decision about you is taken by the Platform. If you want to know why a Platform made a decision about you, or want it looked at again, you should ask the Platform.
10. Your responsibilities
10.1 You must be entitled to use the account you are connecting or paying from, and must have the authority to give the consent you are giving.
10.2 You must give accurate information, and must not use our service for anything unlawful or fraudulent.
10.3 You must tell us, and your bank, as soon as you can if you think someone has used our service without your authority.
11. Our responsibility to you
11.1 Nothing in these terms makes us responsible for any loss unless, and only to the extent that, the loss was caused by our breach of a duty owed to you, was reasonably foreseeable when the agreement was made and is recoverable under applicable law. You must take reasonable steps to avoid or reduce loss and may not recover twice for the same loss.
11.2 Subject to any right or liability that cannot lawfully be excluded or restricted, we are not responsible for the Platform's or Payee's goods, services, decisions or conduct; information or payment details supplied by you or the Platform; your bank's authentication, refusal, execution or account information, or the availability, maintenance or interruption of your bank's interface; or an event outside our reasonable control. We are not responsible for loss of profit, business or opportunity where you use the service for business purposes.
11.2A Depending on your bank. Our service depends on the interface your bank makes available to us. Your bank decides when that interface is available, when it is taken down for maintenance, and how quickly a fault with it is put right, and we cannot require it to restore or repair it. Where access or a payment is delayed or unavailable for that reason, we will tell you what we know and, where it helps, raise it with your bank, but we do not commit to a time by which it will be resolved. Doing so is not an acceptance that we caused the problem or that any sum is due from us.
11.3 Nothing in these terms excludes or restricts liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any right, remedy or liability to the extent it cannot lawfully be excluded or restricted.
12. If a payment was not authorised by you, or went wrong
12.1 If you believe a payment was unauthorised, not executed, incorrectly executed or late, contact your bank without undue delay after becoming aware of the problem and normally no later than 13 months after the debit date. That 13-month limit does not apply where the transaction information required by the Payment Services Regulations 2017 was not provided. Those Regulations generally make your bank responsible for the payer-facing investigation and any refund or restoration due. This does not remove a duty the Regulations place on us or your bank's right of recourse against us.
12.2 If you were deceived into authorising a payment to a fraudster, contact your bank immediately and also tell us or the Platform. A qualifying customer may have a statutory reimbursement right under the applicable authorised push-payment scam rules. Your bank or other account provider assesses and pays the claim. Current information about eligibility, exclusions and limits is available from the Payment Systems Regulator at psr.org.uk.
12.3 We will maintain fraud warnings and controls appropriate to our payment initiation service, preserve the evidence we hold, provide required information and cooperate promptly with you, your bank and any other payment service provider involved. Nothing in clauses 8.7 or 12 removes or limits a mandatory duty or reimbursement right.
13. Your personal information
13.1 Our Privacy Policy explains what personal information we handle, why, how long we keep it and what rights you have.
13.2 In short, our role depends on the purposes and essential means of the particular processing actually performed, not merely on a contractual label or on the fact that the service is regulated. The following describes the intended allocation for the usual flows:
- To the extent that, when we retrieve your account information, transmit a payment instruction or carry out an account check under Verification, we determine the purposes and essential means of the consent journey, the security and fraud checks we apply, and the content and retention of our canonical consent, authorisation, status and audit record, we act as a controller in our own right for that processing.
- Once we have provided that information to the Platform, to the extent we then store it for the Platform on its documented instructions, including as a client-facing copy or extract of consent or audit data, categorise it at the Platform's request, or carry out a document check on the Platform's instructions, we act as the Platform's processor and the Platform is the controller. That client-facing copy is distinct from our canonical controller record.
- The canonical record of the consent and regulated-service journey, our fraud and financial crime checks, our security monitoring and our complaint handling are things whose purposes and retention we decide, so we are a controller in our own right for them.
- Once your information is with the Platform, the Platform decides what to do with it as a controller and is responsible for that, under its own privacy policy.
13.2.1 Our Privacy Policy sets out the full breakdown, purpose by purpose, and the lawful basis for each.
13.3 The businesses that help us provide the service are listed at Sub-processors.
13.4 You can exercise your data protection rights with us directly, whichever Platform you came through. Contact details are in our Privacy Policy.
13.5 Where your connection is. When you use the service we record the internet address (IP address) your connection is using, and work out the approximate area it covers, being the country, the town and the network provider. We use this to help spot fraud and unauthorised access, and we pass the approximate area to the Platform so it can do the same. It gives a rough area based on the connection and the network it runs on, so it can be some distance out. The lookup is carried out for us by a specialist company in the European Union, described at Sub-processors.
14. Complaints
14.1 Who to go to depends on what the problem is.
- The Platform's product or service, or a decision the Platform made about you — contact the Platform.
- A payment that was not authorised, did not arrive or went to the wrong place — contact your bank, as clause 12 explains.
- Our account information service or payment initiation service — contact us.
14.2 To complain to us about our account information service or payment initiation service, email complaints@finexer.com or write to us at the address in clause 17.9. There is no form to fill in, and we will not ask you for any business or company details. You can also complain through the Platform, and if you complain to the Platform about our service it is required to pass your complaint on to us. For complaints about how we handle your personal information, see clause 14.5.
14.3 We will send you a final response within 15 business days of receiving your complaint. If exceptional circumstances outside our control mean we cannot, we will send you a holding response within those 15 business days that clearly explains the reasons for the delay and states the date by which you will receive our final response. That date will be no later than 35 business days after we received your complaint.
14.4 If you are not satisfied with our final response, or we do not respond in time, you can refer your complaint free of charge to the Financial Ombudsman Service, Exchange Tower, London E14 9SR, telephone 0800 023 4567, financial-ombudsman.org.uk. You normally need to do this within six months of our final response.
14.5 Complaints about your personal information. You have a separate right to complain to us about how we handle your personal information. Email us at privacy@finexer.com, or write to us at the address in clause 17.9. There is no fee, and you do not need to give us any business details. We will acknowledge your complaint promptly, normally within five business days and in any event within 30 days, look into it, keep you posted, and tell you the outcome as soon as we can. Our Privacy Policy sets out the full procedure.
14.6 If you are not happy with the outcome, you can complain to the Information Commissioner's Office at ico.org.uk. Coming to us first does not affect that right.
15. How we communicate with you
15.1 We communicate with you electronically, through the Platform's app or website, through the consent screens we present to you, and by email or text message where you have given us those details. You agree to us communicating with you in those ways.
15.2 To use the service you need a device with an up-to-date web browser and an internet connection, and you need to be able to complete your bank's own security steps, which may require a mobile device or an app your bank provides. Your bank sets those requirements, not us.
15.3 You can ask us at any time for a copy of these terms and of the information in them, free of charge, by emailing privacy@finexer.com. We will provide it electronically, or on paper if you ask.
15.4 Where we have to give you notice of something, including a change to these terms under clause 16, we will provide it in a form you can keep and look at again, such as an email or a document you can download. A prompt that appears once and cannot be reopened is not enough on its own. We may ask the Platform to deliver it for us, but we remain responsible for making sure you receive it.
15.5 We always publish the current text of these terms on this page, with its effective date. Posting a notice on this page, or in a dashboard, is in addition to sending it to you, and never instead of it, so you do not need to check this page to find out about a change.
16. Changes to these terms
16.1 We may change these terms, for example to reflect a change in the law or in regulatory requirements, a change to the service, or a change in the way banks operate. How a change reaches you depends on which of our services you are using.
16.2 Single payments. If you ask us to initiate a single payment, the terms that apply are the ones published on this page when you give us that instruction. A later change does not affect a payment you have already instructed.
16.3 Ongoing access to account information. If you have given us consent for ongoing access, your agreement with us continues over time, so a change is handled as follows.
- We will ensure that the complete notice is provided to you on a durable medium in accordance with clause 15.4 at least two months before the change takes effect. We may use the Platform as a delivery channel, but remain responsible for meeting that requirement and will not treat a failed or unproved delivery as satisfying it.
- You will be treated as having accepted the change unless you tell us, or tell the Platform to tell us, before that date, that you do not accept it.
- If you do not accept it, you have the right to end your agreement with us at any time before the change takes effect, without any charge, by withdrawing your consent as clause 7 explains.
16.4 Withdrawing your consent is free of charge at any time, whether or not we have proposed a change, and it takes effect straight away.
16.5 The effective date at the top of this page shows when these terms took effect. If you want a copy of the terms that applied at a particular time, ask us and we will send it to you.
17. Ending and other terms
17.1 Your agreement with us for a single payment ends when the payment has been dealt with. Your agreement with us for an ongoing account information service continues until you withdraw your consent or, where a fixed end date applies under clause 7.4, until it expires. If we do not receive a valid reconfirmation within the required period, we pause collecting new information as clause 7.4.2 explains, but your agreement does not end for that reason alone. You can bring it to an end at any time, immediately and free of charge, by withdrawing your consent as clause 7 explains.
17.2 We may stop providing the service to you if we are required to by law or by a regulator, if we reasonably suspect fraud or unlawful use, or if the Platform's arrangement with us ends. Where we can, we will tell you first, and clauses 4.4 and 17.2A apply.
17.2A Where your agreement is an indefinite framework contract, this clause prevails over every other termination and termination-notice provision to the extent of an inconsistency. If the contract was entered into before 28 April 2026, we may terminate it only where the contract permits termination and by giving at least two months' notice on a durable medium in accordance with regulation 51A of the Payment Services Regulations 2017. If it was entered into on or after that date, we will comply with regulations 51B to 51D. Except where those Regulations or another legal requirement permit otherwise, we will give at least 90 days' notice on a durable medium, explain the reasons in sufficient detail and with sufficient specificity for you to understand them, explain how you may complain to us, and state any right you have to complain to the Financial Ombudsman Service. The Regulations permit exceptions or modified notice in specified circumstances, including certain customer-due-diligence failures, suspected serious crime, regulatory directions and public-order offences.
17.2B A justified technical or security suspension may temporarily prevent access to the service without terminating your framework contract or consent. We will keep its scope and duration under review and restore access when the ground for suspension no longer applies, so far as lawful and technically practicable. Where a suspension is intended to be permanent or has the purpose or practical effect of permanently ending your indefinite framework contract, it is a termination and regulations 51A to 51D and clause 17.2A apply.
17.3 We may suspend or refuse to act on an instruction where we reasonably suspect fraud or unauthorised use, or where we are required to. Where we are allowed to, we will tell you why and what you can do about it.
17.4 These terms are written and available in English only, and we will communicate with you in English.
17.5 We may transfer our rights and obligations to another business that holds the regulatory permissions needed to provide the service. Your rights will not be affected. You may not transfer yours.
17.6 Contractual recourse and personnel. Your contractual recourse is against Finexer only. No director, officer, employee or contractor of Finexer assumes personal contractual liability solely by acting for Finexer. Each such person may enforce this protection and any applicable exclusion or limitation under the Contracts (Rights of Third Parties) Act 1999. This does not exclude or restrict that person's own liability for fraud or any liability that cannot lawfully be excluded or restricted.
17.7 If part of these terms cannot be enforced, the rest still applies.
17.8 These terms are governed by the law of England and Wales. If you live in Scotland or Northern Ireland you may bring proceedings in your local courts; otherwise the courts of England and Wales have jurisdiction.
17.9 If you want to contact us in writing, our address is Finexer LTD, 124 City Road, London, EC1V 2NX, England. You can also email us at privacy@finexer.com. You never need to use our business contact form, which is for enquiries from companies.