Legal information

Account onboarding

Information pack for COMMITLY customers

Version 1.0 / status: October 2025

Overview

When opening a COMMITLY account and using the COMMITLY card, two documents are accepted in a legally binding way by the end customer:

  1. Swan’s general account terms of use
  2. COMMITLY – Swan partnership terms

These documents govern the contractual relationships as well as the data processing and the allocation of roles between the customer, COMMITLY and Swan.

1. Swan’s general account terms of use (“account terms and conditions”)

Overview

  • Contracting party: the customer concludes the contract directly with Swan.
  • Subject matter: use of the payment account, of the card and of all of Swan’s payment services.
  • Regulation: Swan is an electronic money institution supervised by the Banque de France / ACPR, registration number 86245.
  • Binding effect: these terms and conditions are accepted digitally when the account is opened.

Key content of the account terms of use

  • Account opening and KYC procedure
  • Use of the debit card
  • Payment orders (SEPA, SWIFT, card)
  • Fees and price list
  • Liability, blocking, termination
  • Data protection and complaints management

You will receive all the necessary information about this in Swan’s general account terms of use, accessible during onboarding or in your COMMITLY online banking.

2. COMMITLY – Swan partnership terms (“BP”)

Overview

  • COMMITLY’s contractual role: COMMITLY acts as a technical partner and intermediary.
  • No contractual relationship for the account/card: the contract for the account exists exclusively between the customer and Swan.

Content of the partnership terms

  • COMMITLY supports Swan with:
    • preparing account openings
    • transmitting user information
    • initiating transactions (e.g. credit transfers, direct debits)
    • issuing and administering cards
    • providing interfaces for using the account
  • COMMITLY may submit requests to Swan on the customer’s behalf (e.g. blocking, refunds).
  • The customer agrees that COMMITLY maps certain functions technically and synchronises them with Swan.

Document:Swan-Commitly partnership

3. The onboarding process

  • The customer is invited via COMMITLY to open an account with Swan
  • The customer accepts digitally:
    1. Swan’s terms and conditions (legally binding for the account & card)
    2. Partnership terms COMMITLY – Swan
  • After successful KYC and activation: use of the account and card via the COMMITLY interface

4. Notes for the customer

  • COMMITLY is not the provider of the account or the card, but provides the technical interface for using them.
  • Swan remains the sole contracting party and, under data protection law, the controller for the account and the card.
  • Complaints about the operation of the account or about payments are to be addressed to Swan. COMMITLY assists with forwarding them.
  • Data protection information: see the data protection information for the account & card

If you have any questions, the COMMITLY support team is at your disposal at support@commitly.com.