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Finom Payments law enforcement guidelines

  1. Introduction

    This document provides guidelines for law enforcement authorities and (non-client) third parties (each a “Requesting Authority”) seeking access to or demanding specific actions in relation to any client or any client account data (each a “Request”) from Finom Payments B.V., including its branches in Germany, Italy, Spain, and France (“Finom Payments”)(the “Guidelines”). Finom Payments is committed to protecting the privacy of its clients and ensures that any requests for data disclosure are handled in compliance with its privacy policy, user agreements, and applicable laws and regulations. At the same time, Finom Payments cooperates with Requesting Authorities. Finom Payments recognizes the importance of complying with legally valid requests from Requesting Authorities, while also maintaining the trust of its clients and compliance with applicable laws. As part of this commitment, Finom Payments will only disclose client information where there is a valid legal basis and in accordance with established legal processes. These Guidelines further specify the type of requests that Finom Payments processes and how to submit requests to Finom Payments.

    Note: These Guidelines are not applicable to regular client queries. Clients can reach us via chat or email to hello@finom.co for regular client questions not related to any of the topics addressed in paragraph 2.2 below.

  2. Submission of Requests

    2.1 General Requirements

    Finom Payments accepts Requests when submitted according to the following requirements:

    • Legally valid: Under these Guidelines, Finom Payments only accepts Requests that are legally valid and explicitly state the legal basis on which such Request is based.
    • Authentic: All Requests must be submitted via an official email address or other official electronic means by the Requesting Authority, and should be identifiable as authentic through means chosen by the Requesting Authority. All Requests should be sent to Finom’s designated mailbox as further specified below.

    2.2 Types of Data Requests and submission

    Under these Guidelines, Finom Payments distinguishes the following types of Requests. As each type of Request requires different internal actions from Finom Payments, it is important that the right address is used for a specific Request, to ensure effective processing of the Request.

    1. Requests related to bankruptcies, seizures, attachments, and guardianships

      These are Requests that involve direct actions to the availability of client funds required by Finom Payments. The Requests may be related to a client being declared bankrupt, or a client’s e-money balance held by Finom Payments being seized due to criminal investigations and/or court orders, etc. Please submit all Requests via email to: claims@finom.money. Please note that all Requests must meet be legally valid and authentic as set forth in paragraph 2.1 above.

    2. Fraud-related Requests

      These are Requests related to (suspected or actual) fraudulent behavior by a client of Finom Payments or against a client of Finom Payments. The requests may or may not be related to payment recalls. Please submit all Requests via email to: fraud@finom.money. Please note that all Requests must meet be legally valid and authentic as set forth in paragraph 2.1 above.

    3. Intelligence Requests

      These are Requests solely related to clients’ data or clients’ account data held by Finom Payments. Please submit all Requests via email to: claims@finom.money. Please note that all Requests must meet be legally valid and authentic as set forth in paragraph 2.1 above.

  3. General legal information

    Please note that clients of Finom Payments, irrespective of the IBAN country codes clients may have in connection with one or more of their payment accounts, have a user agreement with Finom Payments which is governed exclusively by the laws of The Netherlands. This means that Dutch criminal procedural laws, Dutch civil procedural laws, and Dutch AML and sanction laws apply. Requests must meet the standards as set out therein, as applicable. Finom Payments may demand that foreign Requesting Authorities seek assistance from relevant Dutch authorities through Mutual Legal Assistance Treaties (each a “MLAT”) or similar international agreements. The MLAT process allows foreign governments to request assistance from the Dutch government to obtain information from Finom Payments.

  4. Other

    For general inquiries or questions not related to requests covered by these Guidelines, Requesting Authorities may contact Finom sending an email to: hello@finom.co. General note: Finom Payments provides these Guidelines to ensure that valid Requests are processed with the fastest response time by Finom Payments. Not following these Guidelines does not necessarily mean Finom Payments will not comply with valid Requests. The initial response time of Requests which do not follow these Guidelines may be longer.

Office address of Finom Payments:

Finom Payments B.V. Jachthavenweg 109h 1081 KM Amsterdam The Netherlands