Account onboarding

Information package for COMMITLY customers

Version 1.0 / Status: October 2025

Overview

As part of the opening of a COMMITLY account and the use of the COMMITLY card two documents are legally accepted by the end customer:

1. Swan's General Terms and Conditions of Account Use
2. Partnership conditions COMMITLY - Swan

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

1. general terms and conditions of account use of Swan ("GTC Account")

Overview

• Contractual partner: The customer concludes the contract directly with Swan.
• Subject matter: Use of the payment account, the card and all Swan payment services.
• Regulation: Swan is an electronic money institution regulated by the Banque de France / ACPR, registration number 86245.
• Binding nature: These GTC are accepted digitally when opening an account.

Key contents of 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 complaint management

You will find all the necessary information in the Swan General Terms and Conditions of Account Use, accessible during onboarding or in your COMMITLY Online Banking.

2. partnership terms and conditions COMMITLY - Swan ("BP")

Overview

• Contractual role of COMMITLY: COMMITLY acts as technical partner and intermediary and mediator.
• No contractual relationship account/card: The contract for the account exists exclusively between the customer and Swan.

Contents of the partnership conditions

• COMMITLY supports Swan with:
  • Preparation of account openings
  • Transmission of user information
  • Initiation of transactions (e.g. transfers, direct debits)
  • Card issuing and administration
  • Provision of interfaces for account use
• COMMITLY may make requests to Swan on behalf of the customer (e.g. blocking, refunds).
• The customer agrees that COMMITLY may technically map certain functions and synchronize them with Swan.

Document: Swan-Commitly-Partnership

3. onboarding process

• Customer is invited to open an account with Swan via COMMITLY
• Customer accepts digital:
  1. Swan AGB (legally binding for account & card)
  2. Partnership conditions COMMITLY - Swan
• After successful KYC and activation: use of account and card via COMMITLY interface

4. information for the customer

• COMMITLY is not the provider of the account or the card, but provides the technical interface for use.
• Swan remains the sole contractual partner and controller under data protection law for account and card.
• Complaints about account management or payments should be addressed to Swan should be addressed to Swan. COMMITLY will assist with forwarding.
• Data protection information: see Account & card data protection information

If you have any questions, please contact the COMMITLY support team at support@commitly.com.