Terms of Use & Privacy Policy

1.1

In order to use the Account Service you will need to link one or more of your existing payment accounts and/or card solutions, such as debit card, credit card and/or checking account (the "Transaction Link"), which you would like to apply the Account Service to. We will not be able to provide you with the Account Service without a functioning Transaction Link or for any account or card not linked. By using the Account Service you confirm that you accept these Terms of Use.

1.2

Based on your request to create and uphold the Transaction Link, the financial institution(s) where you have the account(s) and/or the card issuer(s) of your card(s) (jointly the "Transaction Issuers") will provide to Finton information about the purchases and payments that you make using your linked payment methods, such as purchase amount, merchant information and point of sale, and date (jointly the "Transaction Data"), and your card or payment account details linked to the linked card(s) or payment method. You accept and agree that the Transaction Issuer may disclose your Transaction Data, card or payment account details linked to the respective payment method or card(s) to Finton.

1.3

The Account Service integrates with the open banking connectivity provider Enable Banking Oy, and when you use the Account Service you have separately accepted Enable Banking's connectivity terms and conditions and privacy rules. Gokind AB is a Swedish open banking categorization engine that helps to provide labeling of your consumption and spending in relation to the Account Service. Neither Gokind AB nor Enable Banking Oy store or log any of your transaction and account data; they process information and provide the minimum data to Finton to allow us to provide the Account Service.

1.4

Based on your Transaction Data and the information that you provide in connection with registration for and use of the Account Service we will provide you with the Account Service, which includes Finton providing you with insights into your economy, loan situation and the use of other consumer related products, services and utilities, which could be relevant for you based on your spending and preferences.

1.5

In order to use the Account Service you need to connect it to a Transaction Issuer that is supported. The Account Service gives you a convenient way to provide information about some of your preferences and spending, but you have to apply your own knowledge about your financial life and preferences when assessing the information and suggestions provided by the Account Service.

1.6

Finton and the Account Service do not offer financial advice, lending, or brokerage services. All information and insights provided by Finton are general and automatically generated. They do not constitute personal financial advice, recommendations, or credit assessments.

1.7

You must be at least 18 years old and reside in the EEA to use the Account Service.

1.8

Your data is processed in accordance with our Privacy Policy. By using the Account Service, you agree to this processing.

1.9

Finton and Haveton AB are not liable for any direct or indirect losses resulting from the use of the Account Service or from any financial decisions based on the information provided, as well as any downtime or non-accessability to the Account Service.

1.10

To the extent permissible by local law or regulations, these Terms of Use shall be governed by and construed in accordance with Swedish law. Both parties submit, to the extent permitted by local law or regulations, to the non-exclusive jurisdiction of the District Court of Stockholm to resolve any dispute that may arise from these Terms of Use. The Terms of Use and Privacy Notice may be altered by giving at least 60 days notice to you before being put into effect, where you have the right to forthwith terminate the use of the Account Service.

1.11

Any provision of these Terms of Use declared void or unenforceable by any competent authority or court shall, to the extent of such invalidity or unenforceability, be deemed severable and shall not affect the other provisions remaining, which shall continue unaffected.

1.12

These Terms of Use were last updated on 8 November 2025 and replace all previous versions thereof.

What is the purpose of the processing?

Based on your Transaction Link and the information that you provide in connection with your use of the Account Service, Finton helps you get informed of your current economy, loans, financing solutions and other contracts and utilities that you have entered into or use.

Your Transaction Data (as defined below) and other personal data related to the Account Service will not be used in any manner that is incompatible with the purpose for which it was collected. We process your personal data for the sole purposes set out below:

To provide the Account Service; based on your Transaction Data and the information that you provide in connection with the use of the Account Service, Finton provides you with insights into your current economy, loans, financing solutions and other contracts and utilities that you have entered into or use.

The Account Service cannot be provided without this processing.

1. Data we collect

When you link your accounts and/or card solutions, such as debit card, credit card, and/or checking account to the Account Service (the "Transaction Link") we ask you to provide your bank/card provider, account, card or payment account details and the other information as necessary for such Transaction Link. In order to provide a safe Transaction Link, connectivity related personal data may be processed, such as timestamps and IP number.

When using the Account Service, we automatically collect from the Transaction Link relevant transaction data needed for us to perform and provide you with the Account Service.

On the basis of your request to create and uphold the Transaction Link and your acceptance of the Terms of Use for the Card Service, the financial institution(s) where you have the account(s) and/or the card issuer(s) of your card(s) (jointly the "Transaction Issuers") will provide to Finton information about the purchases and payments that you make using your linked payment methods, such as purchase amount, transaction text, merchant/labelled information and date (jointly "Transaction Data"). We will not process Transaction Data older than two years.

We may collect and process the following types of information:

• Personal information: name, personal identification number, email address, and user ID.
• Financial data: transaction data, account balances, and counterparties of transactions retrieved via secure Open Banking APIs and labelled (e.g. via subprocessors Gokind and AISP provider Enable Banking Oy).
• App usage data: events, crash reports, and device information via Firebase and Google Cloud.
• Communication data: messages and email activity via SendGrid.

2. What is the legal basis for processing?

The legal basis for this processing of your personal data is our obligation to comply with the Terms of Use and deliver the Account Service as requested by you, see GDPR art. 6 no 1 b.

3. Who has access to the personal data?

The number of persons that have access to your personal data is limited to what is necessary in order to fulfil the purposes of the processing.

Your data will be stored and processed in Finton's internal systems and will not be transferred at rest outside Finton. Third party suppliers processing personal data on our behalf might have access to your personal data for processing, when necessary, in order for Finton to manage the Account Service. As described in the Terms of Use and below, Gokind AB operates as a data processor to Finton, with Enable Banking Oy as sub-processor.

3. How we use the data

We process your data to:

• Provide personalized financial insights and cost-saving suggestions.
• Improve app functionality and user experience.
• Send notifications and relevant offers (via consent).
• Maintain security, detect fraud, and comply with legal requirements.

We never provide individual financial advice. All insights are generated automatically and should be considered general information only. As mentioned in the Terms of Use, we can only identify financial events based on a Transaction Link and actual transaction events. We can therefore not identify loan relationships etc. where you do not have any transactions captured by the Transaction Link.

3. Data storage and sharing

• All data is stored securely in Google Cloud (EU region).
• Certain data may be shared with trusted processors such as Firebase, Gokind, Enable Banking and SendGrid, only for service functionality.
• No data is sold to third parties. Aggregated and anonymized insights may be used for analytics or research purposes.

4. Your rights under GDPR

You have the right to:

• Access, correct, or delete your data.
• Withdraw consent at any time.
• Request data portability.
• File a complaint with the Swedish Authority for Privacy Protection (IMY).

In more detail: You have the right to know which personal data we are processing about you and may request a copy of that personal data. You have the right to request that we rectify or erase inaccurate or incomplete personal data. You are also entitled to object to specific processing of personal data and request that processing of personal data be restricted. Further, you have the right to receive, in machine-readable format, personal data you have provided, and have the data transferred to another party responsible for data processing.

Requests can be sent to: [email protected]

5. Data retention

Data is retained only as long as necessary to provide the service or comply with legal obligations. When you delete your account, all personal data is removed or anonymized within 30 days.

6. Security

We use encryption, secure access controls, and regular audits to protect your information.

7. Updates

This Privacy Policy may be updated periodically – see Terms of Use. Significant changes will be notified within the app and/or via contact information you have provided via the Account Service.

1. What cookies we use

• Analytics cookies: Used by Firebase and Google Analytics to understand usage and improve performance.
• Functional cookies: Enable login sessions and security features.
• Communication cookies: Used by SendGrid for email delivery and engagement tracking.

2. How we use cookies

Cookies help us remember preferences, measure performance, and detect bugs.

We do not use third-party advertising cookies.

3. Managing cookies

You can disable or clear cookies in your device settings at any time.

By continuing to use the app, you consent to the use of cookies as described in this policy.