End-user terms of service

Last updated: 1 September 2023

Welcome to TrueLayer!

Thank you for using TrueLayer's services ("Services")!

The Services are delivered by TrueLayer Limited ("TrueLayer", "we", "us"), a company registered in England and Wales (company number 10278251) with our registered office at Part Ground Floor (East), Floors 6 and 7, The Gilbert, 40 Finsbury Square, London, EC2A 1PX.

These End-User terms of service ("Terms") apply to you ("End-User", "you") each time you use our Services through the app or websites of our merchant customers (Merchants).  Each time you use the Services, you must agree to the Terms in force at that time, so please be sure to read them carefully each time you use the Services. If you do not agree to these Terms, you cannot use any of our Services.

We may provide other products or services that have additional terms, which will apply and will become part of the agreement you have with us when you use those services.

If you would like to know how we use your personal data, please read our Privacy Notice, which also contains our Cookie Policy.
These Terms are available for you to download or you may request a copy of these Terms by creating a support ticket

Who we are

TrueLayer is authorised and regulated by the Financial Conduct Authority (“FCA”) under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 (Firm Reference Number: 901096). 

Our VAT registration number is: 251953204. 

The FCA's contact details are as follows: 

Financial Conduct Authority 

12 Endeavour Square 

London, E20 1JN 

Contact Centre: 0300 500 0597 

Consumer Helpline: 0800 111 6768 

We are not authorised to give you any financial or investment advice. Our Services do not amount to financial or investment advice.

Restrictions on our Services

We are providing the Services to you only and you should not share your access to the Services with anyone else.

By using the Services, you represent and confirm that:

  • you will not use our Services for any fraudulent, unlawful or abusive purpose;

  • the bank login credentials you use are your own and you are duly authorised to use the credentials to connect your Payment Account(s) to our Services;

  • you are at least 18 years of age and resident in the EEA. 

If we consider that the conditions set out in these Terms are not satisfied, or if it would be unlawful to provide you with a Service, we may refuse to do so. If this is the case, you will be notified through the app or website, unless the law prevents this.


Authentication

In order to use any of our regulated Services, you will be required to authenticate yourself. through a ‘Redirect Flow’.

Redirect Flow

After your bank and Payment Account have been selected, we will redirect you to your bank (either on a web browser, or your banking mobile app) who will ask you for your login credentials, which may include two factor authentication (e.g. a password and biometric credential such as a fingerprint).

In this flow, neither TrueLayer nor the Merchant will be able to see or access your login credentials at any time. Once your bank has confirmed authentication, we will instruct them to (i) share your data (AIS); and/or (ii) make a payment (PIS) in accordance with your instructions (a “Payment Order”). 

Data Services

Account Information Services (AIS)

What this is

Our AIS enables you to: 

  • access and view information relating to your Payment Accounts (Account Information), including through our Merchants’ apps or websites, in a consolidated form; and 

  • where relevant, and with your explicit consent, to share that Account Information with those Merchants and other third parties.

We do this, on your instruction, by either:

  • Consolidating your account information from multiple banks (and presenting this back to you via our Merchant's app or website); 

  • Sharing your account information with a Merchant (who will use it to provide a service that you have agreed to use (such as a credit reference service, or an affordability check); and/or

  • Sharing the Account Information with TrueLayer to allow you to choose a bank to pay from when we provide you with PIS. 

How this works

You will be directed to a page on our Merchant’s app or website where you will be able to:

  • provide explicit consent to TrueLayer by clicking continue; 

  • select the bank and Payment Account you want to connect to; and

  • select the Account Information you want to access via TrueLayer and, if relevant, share with Merchants or other third parties.

You will then be required to authenticate with your bank (see Authentication)

Once your bank has confirmed authentication, we will:

  • provide you with the Account Information retrieved in this way through our Merchants’ apps or websites; and/or

  • provide that Account Information to Merchants or other third parties in accordance with the provisions above.

The Account Information retrieved and shared may include your personal account details (such as name), transaction history, transaction amounts and descriptions, account name and number, currency, account balance, any overdraft balance, payment due dates and other information about your transactions. This will depend on the services being provided by the Merchant through which you access our AIS Service. We will not request sensitive payment data (such as bank login credentials) linked to your payment accounts. The transaction details will be a snapshot as at the date and time that you provided us with access to your Payment Accounts. 

You will need to renew your consent to our access to your Payment Account(s) by authenticating with the relevant bank at least every 90 days, and every time you wish to access and/or share Account Information other than your account balance or transaction data relating to transactions occurring in the last 90 days.

We will provide this Service immediately following your confirmation that you wish us to proceed with AIS and you will not have the right to cancel your contract after providing that consent.

We will not charge a fee for providing this AIS.  However, fees may be charged by your bank in connection with your use of this AIS in accordance with your bank's terms and conditions.

We will not use, access or store any data for purposes other than the performance of AIS as explicitly requested by you.

Verification Services

Verification Services are a type of AIS and the provisions of the AIS section apply in addition to those in this “Verification Services” section.

What this is

Our Verification Service enables you to:

  • with your explicit consent, share your Account Information obtained through AIS with TrueLayer and your Merchant; and

  • permit us to use that data for the one off purpose of verifying your identity against a separate set of data provided to us by the Merchant.

How this works

Once we have cross-checked the AIS retrieved data against the data provided by the Merchant, we will return a Verification Outcome to the Merchant which will state whether the two data sets match, do not match or that insufficient information has been provided.

Signup+

What this is

Our Signup+ Service enables you to register on one of our Merchant’s websites without manually inputting your details. 

How this works

Where this Service is offered by our Merchant, you will first be presented with the choice to use Signup+ or to enter your details manually. Should you explicitly consent to use the Signup+ Service by clicking on the relevant option, you will then be directed to either:

  • Share your account information with TrueLayer (who will use it to provide the Signup+ Service that you have agreed to use; or

    • In which case the terms governing AIS apply

  • Make a Pay In using PIS to a payment account that the Merchant has been issued by us. 

    • In which case the terms governing PIS apply

The Merchant will determine the method by which you will share your account information with us.

Once received, we will pass your account information to our third party data provider, Equifax Limited, who will in turn provide us with the information required to register you on that Merchant website. We will then share that information with the Merchant. 

Equifax is a credit reference agency and will return information required to enable this Service. This search will have no impact on your credit rating. For more information about Equifax, please read their Credit Reference Agency Information Notice.

You can share your account information either through our AIS Service or alternatively by making a payment to the Merchant’s wallet using our PIS Service. 


Payment Services

Payment Initiation Services 

What this is

Our PIS enables you to initiate a Payment from your Payment Account to a Merchant that you wish to pay.

We do this, on your instruction, by:

  • instructing your bank to make a payment or payments from your selected Payment Account to your chosen recipient. 

How this works

You will be directed to a page on our Merchant’s app or website where you will be able to:

  • provide explicit consent* to TrueLayer by clicking continue 

  • select the bank and Payment Account you want to make a payment from

  • instruct TrueLayer to initiate a payment of your chosen amount to your chosen recipient, details of which will be clearly displayed on the account selection page.

*Please note that the consent you provide in accordance with these Terms is a "single use" consent for the initiation of a single payment transaction.  If you want us to provide you with additional PIS, you will need to provide us with a new consent and instructions to provide your bank with a new payment instruction.

You will then be required to authenticate with your bank (see Authentication)

Once your bank has confirmed authentication, it will act on your instruction to make the payment.

Once you have authorised the payment with your bank, funds will usually leave your Payment Account immediately and, at the latest, within two hours.  We or the Merchant will confirm the successful initiation of a Payment Order together with a transaction identifier for you to identify the payment transaction together with the amount of the payment transaction.  
Please note that your bank (and not TrueLayer) is responsible for executing the payment transaction. We will not charge a fee for providing this Payment Initiation Service.  However, fees may be charged by your bank in connection with your use of this Payment Initiation Service in accordance with your bank's terms and conditions. 

Variable Recurring Payments

What this is

A Variable Recurring Payment (“VRP”) is a type of PIS where you can consent to multiple payments being made from your Payment Account to a Merchant that you wish to pay without the need to authenticate yourself with your bank each time a payment is taken. 

How this works

For you, this works in exactly the same way as any other PIS payment except that instead of providing explicit consent for a single payment you are consenting to multiple payments provided that they fall within the limits agreed as part of the consent process.  This means that you will only need to authenticate with your bank once. This will happen at the time you provide your explicit consent for the VRPs. The terms governing PIS will apply to your VRP.

Pay Ins

What this is

We may provide a Merchant with a merchant checkout service that lets you pay the Merchant for online products and services from your Payment Account. In order to make the payment, you will use our regulated PIS to make a Pay In directly from your Payment Account to the Merchant.

How this works

For you, this works in exactly the same way as any other PIS payment. As such, the terms governing PIS will apply to your Pay In.


The differences for us are that the PIS payment is directed to a Payment Account that the Merchant holds with us. As such, once we receive the funds that form part of the payment we will issue E-money of an amount equal to the amount transferred to us. The E-money we issue will be provided to the Merchant immediately to settle the payment with that Merchant. No further payments will be initiated by us to the Merchant (or executed by your bank to the Merchant), unless you repeat the steps to make a further purchase. 

Our safeguarding obligations 

Where we issue E-money, we will safeguard the relevant funds in line with our regulatory obligations with our safeguarding bank. These funds do not have protection under the UK Financial Services Compensation Scheme, however, safeguarding requirements mean the funds are placed in a separate account from TrueLayer's working capital and other funds. If TrueLayer becomes insolvent, claims of E-money holders will be paid from these funds in priority to all other creditors.

Save My Details / Remember Me

What this is

We can provide you with a Service where we store your information to enable a faster payment experience next time you use our Services. 

How this works

When you use one of our Services, you may be given the option ‘opt in’ to this Service. With your agreement, we will store certain personal data that we have collected about you, such as your name, email address, date of birth and account details (sort code/account number or IBAN). 

We may also store your billing address and shipping address where made available. 

Next time you use our Services, we can pre populate the data we hold about you, removing the need to input it yourself. The data we pre populate will be determined by the Service you are using at that time. 

You will always be given the option to amend the data prior to giving us explicit consent to provide you with our Service. 

If, at any time, you want to ‘opt out’ of this Service, you can do so as part of a future payment process or via the following link. More information on our processing of the personal data we store to provide this Service is available in our Privacy Notice.

Merchants and banks

We are not responsible for any problems that you might have with the functionality or suitability of your bank. We are responsible for retrieving and transmitting your Account Information safe and securely but not for the content of your Account Information itself, which is the responsibility of your bank. If you have any questions in relation to these, you should speak to the relevant Merchant that provides the app or website that you are using, or to your bank. 

Your use of the Merchant’s services and your Payment Account will also be subject to other terms and conditions - these Terms will not affect any of those terms. In particular, the Merchant and your banks will have separate rules on data protection that will apply to your use of their services. Once your Account Information is transmitted via our software to a Merchant, that Merchant becomes responsible for it.

We do not charge you as an End-User to use our Services, however, the Merchant may charge you for use of their app or services. In turn, Merchants may pay us fees for the services we provide to them. The Merchant’s terms will govern any products or services they provide to you and we are not responsible for any loss, harm or damage arising from them.


Any Account Information that you choose to share as a result of using our Services will be encrypted with a multi-key encryption mechanism. The Merchant delivering the app or website will only be able to access this information if you have explicitly given them your permission to do so.

Intellectual Property

TrueLayer owns all rights, title and interest (including 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 Services, website or technology we may use them without any limitation.

Disclaimers

We want you to get the most out of our Services and we will provide our Services with reasonable care and skill. All Services (including any additional services or products) are provided to you on an "as is" and "as available" basis.

Other than as expressly set out in these Terms, any additional terms we introduce from time to time, or implied by consumer law, we do not make any particular commitments or promises to you about our Services. For example, we do not promise that any content within the Services, the functions of the Services, or their reliability or availability will be suitable for your needs. This does not affect your statutory rights.

To the extent permitted by applicable law, we exclude all warranties.

You agree that you will be liable for any losses that are proved to be sustained by TrueLayer as a direct result of your breach of these Terms.

Who is responsible if things go wrong?

We are only responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of us breaching these Terms or failing to use reasonable care and skill in our provision of the Services. We are not responsible for any loss or damage that is not foreseeable or, to the extent permitted by law, for any indirect or consequential losses (including lost profits, lost revenue or financial losses) arising in the course of a business carried on by you.


We will not be responsible for any loss you may suffer as a result of your material failure to comply with these Terms or caused by matters beyond our reasonable control, for example, an interruption or failure of a utility service, pandemic, industrial action, natural disaster, explosion or accident. We do not exclude or limit in any way our liability to you insofar as it would be unlawful to do so.

If, following use of our Services, you notice unauthorised, or suspicious transactions on your Payment Account, you should immediately contact your bank, who is responsible for investigation, and, where necessary, reimbursing you. Please refer to the complaints policy of your bank.

We are not responsible for any harm, damage or loss to you arising from, or relating to hacking, tampering or unauthorised access to your Account Information that is not within our reasonable control. If you suspect that somebody else has access to your banking credentials and is fraudulently using them to access the Services, you must contact us immediately by email at [email protected].

About these Terms 

Each time you use our Services, you will be bound by the Terms in force at that time. Some or all of the Services may be provided by TrueLayer or another entity in its group (an "Affiliate") on its behalf. If some or all of the Services are provided by an Affiliate, you will be subject to these Terms unless and until you become subject to a separate agreement with that Affiliate, at which point these Terms will cease to apply. 

These Terms will apply for the duration of the period during which you use one of our Services.

We may terminate our agreement with you or suspend your access to any part of our Services at any time if you have breached any of these Terms or if we believe we are required to do so by law. You may terminate your agreement with us at any time by contacting our Client Care team.

We may update these Terms at any time and changes will be published on this page.  In the event that you reject the changes concerned, you have the right to terminate these Terms free of charge at any time. If either we or you terminate this agreement, or you do not agree to the Terms in force at the point at which you want to use our Services, you cannot use our Services.

These Terms (or any previous version of these Terms) are available for you to download or you may request a copy of these Terms by contacting our Client Care team.

Complaints

Providing you with great service is important to us. We consider any expression of dissatisfaction from our customers about our service as a complaint.  If you are unhappy with any part of our Services, the easiest way for us to help resolve your issue is for you to contact our Client Care team.

Alternatively, you can reach us by email at [email protected] or you can write to us at at TrueLayer, Client Care, Part Ground Floor (East), Floors 6 and 7, The Gilbert, 40 Finsbury Square, London, EC2A 1PX.  

We will acknowledge your complaint within 3 working days and will aim to investigate and resolve your problem or give you a clear response within 15 days. We may need to contact the Merchant or your bank and we may need your assistance to investigate and progress any complaint. You agree to provide any necessary assistance in this regard. You agree that responses to your complaint may be in electronic form and sent by email.

Governing Law and Jurisdiction

These Terms are governed by English law and you can bring legal proceedings in respect of the Services in the English courts. If you live in Scotland you can bring legal proceedings in respect of the products in either the Scottish or the English courts. If you live in Northern Ireland you can bring legal proceedings in respect of the products in either the Northern Irish or the English courts. Any matter, claim or dispute arising out of or in connection with these Terms, whether contractual or non-contractual, is to be governed by and determined in accordance with English law. 

If you are a consumer, you will benefit from any mandatory provisions of the law of the country in which you are resident. Nothing in these Terms affects your rights as a consumer to rely on such mandatory provisions of the laws of your country of residence. 

The European Commission has also established an online dispute resolution platform to facilitate communication between the parties involved in a dispute arising from an online transaction (including disputes arising in respect of the Services).

Entire Agreement

These Terms are the entire agreement between you and us in relation to the Services. 

Transfer of Your Rights

You may not transfer your rights under these Terms to any third party without our written consent. 

Conflict

If there is any conflict between these Terms and terms that apply to additional Services, the terms applying to any additional Services will prevail in the conflict.

Modification and Severance

If any part of these Terms is invalid, that part of the Terms shall be modified to make it valid or deemed deleted if it is not possible to modify the term. This will not affect the rest of the Terms. 

Waiver of Rights

A failure or delay by either of us in exercising any right or remedy under these Terms or by law shall not be a waiver of that or any other right or remedy. A waiver of any right or remedy under these Terms or by law is only effective if it is in writing. 

Applicability of Terms

These Terms control the relationship between TrueLayer and you.

Translation and Language

While a translation of the Terms into another language may be provided, only the English language version of the Terms will be legally binding and while some communications may be made in other languages for convenience, Truelayer reserves the right to communicate in English only. The provision of communications in other languages does not constitute an obligation on Truelayer to continue to communicate in that language.

Contact Us 

If you have any questions about the security we use at TrueLayer, please contact us by email at [email protected] 

Do you have other questions? If so, contact us here [email protected]