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Terms and Conditions

1. Definitions

Terms used in the content of these Terms and Conditions of use of Fin.do app (the Terms and Conditions) have the meaning given below:

  1. Bank – the issuer of the Payment Card to the User,
  2. Card Network – Visa, MasterCard or other card networks (also known as card associations) that act as intermediaries between an acquirer and an issuer to process credit and debit card transactions,
  3. Company – UAB “Findo finansai”, legal entity code 304452187, having its registered office at J. Savickio str. 4, Vilnius, the Republic of Lithuania, with correspondence address at Vilniaus str. 31, Vilnius, the Republic of Lithuania, being the developer and the owner of the Fin.do app,
  4. Fin.do app – the software platform developed by the Company in order to facilitate “card to card payments” between the Payment Cards,
  5. mobile app – each mobile application where the Company makes available software enabling the Sender to make use of the Service,
  6. Payment Card – a payment instrument issued under the system of the Payment Organisation that is required for the performance of “card to card payments” via the Card Network (currently MasterCard),
  7. Payment Organisation – MasterCard Europe SPRL; an organisation granting a licence for issuing Payment Cards and handling transactions with such cards,
  8. PCI DSS Payment Card Industry Data Security Standard, which is an information security standard for organisations that handle branded credit cards from the major card schemes,
  9. PSP – licensed payment services provider engaged by the Company that provides the Transaction Authorisation and Transaction Settlement services, operates pursuant to the PCI DSS, meaning that it keeps the highest security standards in Payment Card data processing,
  10. Recipient – the User of the Fin.do app who receives a “card to card payment” from the Sender through the use of Fin.do app,
  11. Sender – the User of the Service that uses Fin.do app to make a “card to card payment” to the Recipient,
  12. Service – a ”card to card payment” service facilitated by the Fin.do app developed by the Company, consisting of debiting the Payment Card account of the Sender upon his/her order and crediting the Payment Card account of the Recipient,
  13. Transaction Authorisation verification of the Payment Card and its holder and obtaining a confirmation from the Payment Organisation that the Sender’s Payment Card may be debited and that the Recipient’s Payment Card may be credited;
  14. Transaction Settlement organising debiting Sender’s side and crediting Recipient’s side with the Payment Organisation,
  15. User – a natural person, a holder of the Payment Card, that can be a Sender or Recipient, that downloads Fin.do app and enters into a contract with the Company on the basis of these Terms and Conditions,
  16. 3DS (3D Secure) an authenticated payment system to improve online transaction security. The objective is to provide a safe and secure online payment experience using a password that is validated by the Payment Card issuer and further checked by all other parties involved in the transaction.

2. General Provisions

  1. These Terms and Conditions regulate the use of the Fin.do app by the Users.
  2. The Fin.do app is a software platform aimed at facilitating “card to card payment” services. The Company is an information technology company that has developed and owns the Fin.do app.
  3. For the avoidance of doubt, neither the Company nor the PSP is involved in either the debiting or the crediting of the Payment Cards and at no point in time during the provision of the Service the Company and / or the PSP get hold of the Users’ funds. In addition, neither the Company nor the PSP will gain access to the Payment Card accounts of the Users. The Transaction Settlement shall be effected directly between the Sender’s Bank and the Recipient’s Bank and arranged by the Payment Organisation.
  4. The Company itself is not a payment service provider, is not licenced and / or supervised by any financial regulatory authority in any jurisdiction and does not provide any payment services to the Sender or the Recipient. The services of the Company are limited to providing a solution facilitating the “card to card payment” transactions for the Fin.do app Users as detailed below in these Terms and Conditions.
  5. The PSP is a licenced payment service provider for the purposes of membership within the Payment Organisation. The PSP is not providing any payment services to the Users when they are using the Fin.do app.

3. Purpose of the Terms and Conditions

The purpose of these Terms and Conditions is to define the principles of using the Service by the Users via the mobile app.

4. Downloading of Fin.do app

  1. The User may only use the Service via the Fin.do app.
  2. The Fin.do app is designed to work with smartphones running [Android 5 and above] and [iOS 8.0 and above]. Fin.do app may as well run on other devices, such as tablets, however, the Users are hereby expressly notified that the Fin.do app and its functionalities are intended to be used only via smartphones, and that its use through any types of different platforms, including, but not limited to, personal computers, laptops, tablets, etc. may cause considerable errors and disabilities towards usage of the Fin.do app and its functionalities. The Company therefore does not assume any risks and/or liabilities which could arise from the use of Fin.do app and its functionalities via any types of platforms other than smartphones.
  3. The User may need to upgrade the operating system on his/her device if the Company changes the version(s) that the Fin.do app supports. The User may not be able to install or use the Fin.do app on a jail-broken or rooted device.
  4. Downloading of the Fin.do app requires internet access, as the Fin.do app is only distributed via proprietary app marketplaces, i.e. Apple App Store and Google Play Store. The User’s telecommunication service provider may charge the User for internet access on the User’s device.
  5. When the Fin.do app is downloaded and the User opens it for the first time, he/she first needs to indicate his/her country and phone number, then enter a confirmation code received by SMS, and create a four-digit passcode or, alternatively, to activate Touch ID / Face ID, either of which the User will then have to enter every time he/she opens the Fin.do app on his/her device (for security purposes, so that third parties getting a hold of the User’s device could not use the Fin.do app for using the Service). As a next step, the User has to provide his/her full name, date of birth and email address. When all of the mentioned steps are taken, the User will have his/her Fin.do app profile created and will be able to use the Service. If any of the mentioned steps are missed, the Fin.do app cannot be used and will not work for the User.
  6. One User can have only one Fin.do app profile.
  7. These Terms and Conditions must be actively accepted by the User before using the Service, by agreeing to use the Fin.do app after downloading it on the User’s device, performing all the steps discussed under item 5 above and being referred to these Terms and Conditions as well as the Company’s Privacy Policy. By using Fin.do app after the previously mentioned steps, the User agrees that he/she has become acquainted with their content and undertakes to comply with their provisions.
  8. The Company shall not disclose any private data of the User to third parties except for:
    1. the PSP for the purposes of Transaction Authorisation and Transaction Settlement;
    2. the Payment Organisation which requires it for transaction processing purposes; and
    3. the third party service provider for Full ID Verification purposes

(see § 12. Personal Data Processing for more details).

5. Adding of Payment Cards to Fin.do app

  1. For the execution of the Service the User will be required to add one or several (up to 5) Payment Card(s) to the Fin.do app for the sending and receiving of funds. Payment Cards that can be added to the Fin.do app are debit and credit cards, as well as prepaid cards with a name on them. Some of the cards may be unsupported by the Fin.do app for technical or other reasons. The Company has discretion to decide which Payment Cards are supported and which are not, without being obliged to provide any explanations to the Users. At this stage, business cards are not supported on the Fin.do app.
  2. The process of adding of Payment Card(s) involves indicating card number, expiration date and CVV number. This can be done manually or by scanning the card with the device. Colour of the card may prevent the User from successfully scanning the Payment Card’s data, in which case the Payment Card’s data will need to be entered into manually.
  3. The User will be required to indicate the base currency of the card in order to avoid double conversion exchange rates applied by the issuing Banks while charging or crediting Users’ card.
  4. The Company will pass all the information on the Payment Card(s) collected on the Fin.do app to the PSP, which will save such data using PCI DSS standards. The Company will retain and store only partial Payment Card number (only first 4 or 6 digits and last 4 digits) as well as the expiration date of the Payment Card.
  5. Once the Payment Card details are entered, the card will be verified by the PSP. Payment Card verification covers three aspects:
    1. that the connection between the Payment Card holder and the Payment Card is authentic and real. For this purpose the process of adding Payment Card(s) to the Fin.do app will in some cases require verification of the Payment Cards by the 3DS protocol in the manner normally applied by the User’s Bank;
    2. verification of the issuing country of the card;
    3. that the card added is supporting outgoing and/or incoming transactions (debiting and crediting). For this purpose 1 unit of the relevant card’s currency will be charged and immediately refunded by the Company (in some cases the refunding can take up to few days, depending on the issuing Bank). The cards not supporting incoming transactions may also be added on the Fin.do app for the purposes of sending funds only.
  6. Payment Card verification normally takes a few seconds, after which the Payment Card added by the User is marked as “verified”. The status of the added Payment Card(s) will be visible on the relevant dashboard. Where the Payment Card is still being verified, the Fin.do app will display its status as “pending” (verification might take longer with the Payment Cards issued by certain Banks). No operations may be performed with the Payment Card(s) the status of which is “pending” or “unverified”.
  7. All the Payment Cards added to the Fin.do app by the User and verified by the PSP will be divided into two categories – cards for sending funds and cards for receiving funds. Funds can only be sent from the Payment Card(s) classified as the “cards for sending” and can only be received to the Payment Card(s) classified as the “cards for receiving”. All verified Payment Cards may be used for sending funds, while not all the Payment Cards may be used for receiving funds due to technical restraints (some Banks are not able to support the technology for receiving funds to payment card via the Card Network). The same Payment Card can be classified under both categories and used for both sending and receiving of funds.
  8. The first verified Payment Card added by the User will be automatically determined by the Fin.do app’s system as a default card for sending and / or receiving of funds. Where more than one Payment Cards are added to the Fin.do app, the User can change the default card manually when managing cards on the screen “My Cards” on the Fin.do app. Default card for sending and default card for receiving may be different Payment Cards.
  9. For the avoidance of doubt, the provision of Service does not involve opening a separate payment account for the User as defined in the Law on Payments of the Republic of Lithuania.

6. Effecting “Card to Card Payments” on Fin.do app

  1. After the User has downloaded and installed the Fin.do app, has logged in and accepted these Terms and Conditions, and has added Payment Card(s) which have been duly verified, the User can act as the Sender and initiate payments from his/her Payment Cards (classified as the “card for sending”) to the Recipients.
  2. The Senders will only be allowed to make payments to the Recipients, i.e. other Users of the Fin.do app. If a person to whose benefit the payment is being initiated is not the Fin.do app User, the Sender will not be able to finalise the transaction before this person has downloaded the Fin.do app and added at least one Payment Card to the Fin.do app in order to receive payments from the Sender.
  3. The Sender can also use the Fin.do app to send funds to other cards of his/her own which were verified as valid for receiving funds.
  4. When the Sender wants to make a payment, the process is as follows:
    1. the Sender logs in to the Fin.do app;
    2. the Sender selects a payment function;
    3. the Sender selects a Payment Card from which he/she wants to make a payment;
    4. the Sender selects a contact (phone number only) from the contacts’ list on his/her device. All the User’s contacts that also are the Users of the Fin.do app will be listed above all the other contacts. Where the selected contact is also the User of the Fin.do app, the Company will within seconds identify him/her by his/her phone number and check if he/she has a valid Payment Card added to the Fin.do app for receiving payments, and the currency of that card. If the contact selected by the Sender can be a Recipient, the Recipient’s device will display a notification that there is an incoming payment (the process of incoming payments is described below). Where the selected contact is not the User, the Sender will only be able to send an invitation to use Fin.do app in order to receive payments. Such an invitation can be sent through any channel available on the User’s device;
    5. the Sender manually inserts an amount that he/she wishes to transfer;
    6. the Sender will have a possibility to manually enter the purpose of payment which will be visible to the Recipient;
    7. the Sender will have a possibility to select whether the transaction fees shall be compensated by himself/herself or by the Recipient;
    8. the Fin.do app will display the amount to be charged from the Sender’s Payment Card, including the fees to be paid, and the currency exchange rate when applicable; 
    9. the Sender needs to confirm the transaction by entering CVV of the card from which the transfer will be made and by tapping the relevant button. Where the Sender does not confirm the transaction within 15 minutes, the transaction will be aborted.
  1. The execution of payment might require additional verification of the transaction by 3DS protocol in the manner normally applied by the Bank. The execution of payment may also be blocked by the Bank due to any reasons at its discretion, in which case the User should contact his/her Bank for further information and action.
  2. Upon receipt of the Sender’s confirmation of the payment, the Company sends, via PSP, to the Payment Organisation a message concerning:
    1. the amount to be debited from the Sender’s Payment Card account. The amount to be debited shall correspond to the amount of the transaction initiated by the Sender, taking into account the currency exchange rate when applicable, and increased by the transaction fees if any of such fees are on the Sender’s part;
    2. the amount to be credited to the Recipient’s Payment Card account. The amount to be credited shall correspond to the amount of the transaction initiated by the Sender, taking into account the currency exchange rate when applicable, and reduced by the transaction fees if any of such fees are on the Recipient’s part. The amount actually credited to the Recipient’s Payment Card account may be slightly higher than displayed within the Fin.do app due to exchange rate display limitations (only 4 digits after the decimal separator are displayed on the Fin.do app).
  3. The Payment Organisation transfers the information indicated in item 15 above to the Card Network. Provided that the Card Network confirms the possibility of debiting the Sender’s Bank and crediting the Recipient’s Bank, the Service will be provided successfully.
  4. On the Recipient’s side, the Recipient, in case he/she also has the Fin.do app, is notified of the incoming payment. The notice will indicate the person sending the money, the amount, the currency exchange rate (if applicable) and the purpose of payment if such was indicated by the Sender, also the transaction fees if these shall be paid by the Recipient. The payment will be credited to a default Payment Card for incoming payments, after the currency exchange rate is applied, when applicable.
  5. Once the payment is credited to the Recipient’s Payment Card account, information about the transaction will appear on the history of the Sender’s outgoing transactions and on the history of the Recipient’s incoming transactions on the Fin.do app.
  6. The Service may only be executed within the limits of transaction amounts introduced by the Company in the table of limits appended to these Terms and Conditions. The limits are applied per Payment Card. Where the amount of the initiated transaction exceeds the set limit, the payment with the relevant Payment Card is not effected at all, i.e. the payment is not effected within the allowed limits as well.
  7. The payments on Fin.do app can be made 24/7.
  8. The term for the provision of Service shall normally not exceed 30 minutes and in most cases will take a few seconds. In any case, the funds shall reach the Recipient no later than until the end of the next working day following the day of the confirmation of the payment by the Sender and only in rare cases the process may take up to 2 or 3 days. The exact time on which a transaction will be credited to the Payment Card account of the Recipient depends on the Recipient’s Bank.
  9. In some cases, the Sender’s or the Recipient’s Bank may block transactions for security or other reasons. It is also possible that funds are blocked as a result of a cancelled or unsuccessful transaction. The Company is not responsible for the Banks’ policies and shall not be liable for any security blockings performed by the Banks.
  10. All the fees displayed by the Company to the User are the only fees charged by the Company for the Service. The Company is not liable for any other additional fees applied by the issuing Bank, and those will not be displayed on the Fin.do app. 

7. User’s Obligations

  1. The User is obliged to:
    1. comply with any restrictions on using the Fin.do app, downloading or otherwise exporting the Fin.do app;
    2. only download the Fin.do app from proprietary app marketplaces, i.e. Apple App Store and Google Play Store;
    3. comply with these Terms and Conditions;
    4. provide true, complete and up-to-date data when ordering the Service;
    5. ensure that the Payment Card number, mobile number and other details he/she provides are correct and up to date, and notify the Company as soon as these change;
    6. exercise due care for the purpose of protecting a device where the Fin.do app is downloaded or on which he/she enters the data to the Fin.do app against unauthorised access, and notify the Company immediately in case of any actual or suspected unauthorised access to the device with the installed Fin.do app for the Company to be able to block any operations from the User’s profile.
  2.   The Users shall in no case:
    1. use the Fin.do app in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these Terms and Conditions, or act fraudulently or maliciously for example by hacking into the Fin.do app or device where it is installed;
    2. use the Fin.do app for any illegal activities, including collecting of payments that are not owed to them;
    3. use the Fin.do app in a way that could damage, disable, overburden, impair or compromise the Service, Company’s systems or security or interfere with other Users.

8. Suspension of Service

  1. The Company may temporarily withhold the execution of the Service, reject execution of the Service or block the possibility of initiating the User’s transactions in the future in the following situations:
    1. the User’s non-compliance with the provisions of these Terms and Conditions;
    2. not receiving from the User correct or complete data necessary for the execution of the Service at the time allotted to introduce such data (including when the confirmation of the transaction is not provided within the specified time);
    3. invalidity or cancellation of the Payment Card of the Sender or the Recipient;
    4. refusal of execution of the transaction by the Bank;
    5. an attempt to make payments in breach of the relevant applicable law, including suspected unauthorised use of the Payment Card, fraud, illegality of payment itself, etc.;
    6. a command of public administration authority or law enforcement agencies.
  2.   The Company shall not be liable for any loss incurred by the User due to unavailability of the Service on the basis of any of the situations listed above.

9. Security

  1. As Fin.do app can be used to make payments from the User’s Payment Card account, the User must keep his/her device secure and not logged into the Fin.do app when it is not being used.
  2. If the User suspects that someone else knows his/her passcode and/or CVV numbers of Payment Cards added on the Fin.do app, or other security details enabling making payments through the Fin.do app, he/she must contact the Company immediately by the details provided in these Terms and Conditions, and the Company will block the User’s profile. At the same time, where the Payment Cards or any security details relating thereto become available to the third parties, the Users must immediately contact their Banks and block the Payment Cards. If the User fails to do so, or until the User does so, he/she will be liable for any unauthorised transactions on their account which are a result of their security details becoming known to someone else. The Company will not be liable for any unauthorised transactions on the User’s account which are a result of their security details becoming known to someone else, during the time where the User has already notified the Company about such security breach, but has not yet blocked his/her Payment Cards.
  3. After the User’s initial registration the Company will never contact the Users to request their security details and will not ask anyone else to do so on the Company’s behalf. If the User receives such a request then it is likely to be fraudulent and the User must not supply his/her security details in any circumstances. Any such activity should be reported to the Company immediately.
  4. Some devices allow the Users to use Touch ID (fingerprint) or Face ID (facial recognition) technology for logging into the Fin.do app. If the User enables this feature, then anyone whose fingerprint or face is registered on their device may be able to log into the Fin.do app and access the User’s accounts. Therefore, the User must not activate this feature if he/she allows other people to access his/her device using their fingerprint / face recognition. The User should delete any other fingerprints registered on the device first; otherwise, transactions made by anyone else who has their fingerprint registered on the device will be treated as being authorised by the User and the Company will not be liable for those transactions.

10. Liability

  1. When making a payment, the Sender must ensure that the Recipient’s information (including the mobile number, payment amount and any extra information required to make the payment) is current and correct, otherwise the payment may be aborted or made to the wrong Recipient. The Company will not be liable to the Users if the payment is sent to the wrong person as a result.
  2. Unless the Company is at fault, the Company will not be liable for any losses the Users might suffer or costs they incur because:
    1. the User is unable to access or use Fin.do app for any reason or there is a delay in its use;
    2. the Fin.do app is used on a device other than a smartphone;
    3. any device, hardware or software the Users use in connection with the Fin.do app is damaged or corrupted or fails to work;
    4. the Fin.do app does not meet the User’s requirements or expectations;
    5. there is a reduced level or failure to provide the Service caused by any third-party service providers including software providers and mobile operators.
  3.   Due to the fact that under provision of the Service the Company does not take possession of funds of the Sender or the Recipient, the Company’s liability is in any case limited to default by sending of incorrect message to the Payment Organisation about debiting the Sender’s Payment Card account and / or crediting the Recipient’s Payment Card account.

11. “Know Your Customer” Requirements

  1. The Company, as an information technology company and not a financial institution, is not obliged to perform “know your customer” (“KYC”) requirements as they are understood under the laws regulating money laundering and terrorist financing prevention. The Company does, however, assist the PSP in its own obligation to perform such KYC requirements and, accordingly, will collect certain information on the Users for this purpose on its Fin.do app, as instructed and directed by the PSP.
  2. In addition to the information collected on the User when downloading, installing and using the Fin.do app, additional data will be required when the Sender sends funds or the Recipient receives funds exceeding the limits indicated in the table of limits constituting an appendix to these Terms and Conditions (further referred to as the “Full ID Verification”). In particular, when the User tries to transfer an amount above the limits indicated in the table of limits constituting an appendix to these Terms and Conditions, the pop-up window will notify the User that the transaction cannot be executed unless the User passes the Full ID Verification. If the User agrees, he/she will be redirected to the relevant screens to proceed with the Full ID Verification.
  3. Additional data to be requested by the Company for the performance of the PSP’s KYC obligation in relation to the Full ID Verification will be the following:
    1. country having issued an ID document of the relevant User;
    2. type of the ID document;
    3. photo of the front and the end of the ID document, taken and transmitted real time to the Company through the Fin.do app;
    4. photo of the face of the User (“selfie”), taken and transmitted real time to the Company through the Fin.do app;
    5. first and last name, gender, date of birth and address.
  4. The information referred to in item 3 above, once collected, will be transferred to a third party service provider for verification and for making the relevant KYC checks. After such checks are performed, the Company will be notified by the third party service provider if they were successful, and if they were, the User will be able to see in the settings of his/her Fin.do app profile and will also receive a notification that his/her ID was verified, and will then be able to send and/or receive funds exceeding the limits indicated in the table of limits constituting an appendix to these Terms and Conditions. Where the KYC checks were not successful, the User will not be allowed to make transactions above the limits indicated in the table of limits constituting an appendix to These Terms and Conditions. The number of attempts to pass Full ID Verification is not limited, however, the Company might block the User’s account or contact the User for additional information in case of any suspicious behaviour on the User’s side.
  5. The Company will save all the information referred to in item 3 above, except for the photos of ID documents of the Users.

12. Personal Data Processing

  1. In order to use of Fin.do app, the User has to provide the following data that is processed by the Company:
    1. full name;
    2. date of birth;
    3. email address;
    4. photo of the face of the User;
    5. country and geolocation;
    6. phone number;
    7. card number (only first 4 or 6 digits and last 4 digits) and expiration date;
    8. additional information requested under item 3 of paragraph 11 of these Terms and Conditions in case of Full ID Verification.
  2. In order to facilitate the provision of the Service the Company acts as the controller of personal data and as such transfers to PSP for the purposes of Transaction Authorisation and Transaction Settlement the following personal data of the Users:
    1. data of the Payment Cards of the Sender and the Recipient: number, validity date, CVV number;
    2. full name of the User;
    3. phone number and email address of the User;
    4. data about the initiated transaction.
  3. For the purposes of Full ID Verification, the Company will transfer the data collected for KYC purposes as described under paragraph 11 above to a third party service provider that provides identity verification and background checks services. For this purpose the Company may transfer User’s data outside of the European Economic Area, including countries which have different data protection standards than those which apply in the European Economic Area. Any such transfer of the User’s personal data will be carried out in compliance with applicable laws. For transfers outside the European Economic Area, the Company will use Standard Contractual Clauses (and the User has a right to ask for a copy of these clauses) and Privacy Shield as safeguards for countries without adequacy decision from the European Commission.
  4. The User, by registering and logging in to Fin.do app and by introducing the above data on the Fin.do app, expresses his/her consent for the controlling and processing of such data by the Company and the PSP for the purpose of execution of the Service. Such consent is additionally evidenced by the User actively accepting the Fin.do app’s Privacy Policy.
  5. Personal data is processed according to the provisions of the European Union General Data Protection Regulation, the Law on Personal Data Protection of the Republic of Lithuania, the Law on Electronic Communication of the Republic of Lithuania and other applicable laws.
  6. Any person providing his/her personal data to the Company has the right to request access to and rectification or erasure of personal data (“right to be forgotten”) or restriction of processing concerning the User or to object to processing as well as the right to data portability, also the right to lodge a complaint with the User’s national data protection authority (the list of all such authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 ) . The User shall exercise the rights granted by this item by contacting the Company via Help Centre of the Fin.do app or website of the Company www.fin.do. The Company may not be able to implement certain rights of the User, such as the “right to be forgotten”, if it is necessary to apply safeguards, in particular to prevent the destruction of data or evidence based on and in accordance with the requirements of the applicable laws and regulations.
  7. Data from item 1 above may be used to notify the User about discounts and new services offered by the Company. The legal basis of such data processing is the legitimate interest of the Company – to inform clients about services and updates. The User has a right to object to the processing for marketing purposes at any time.
  8. The Company processes and stores User’s personal data no longer than necessary for the purposes stated in this paragraph. User’s personal data provided for the purpose of providing the Service and using Fin.do app is stored during the provision of Service and usage of Fin.do app and for a maximum of 10 years after the end of the provision of Service and usage of Fin.do app. User’s data processed for marketing purposes is stored during the provision of Service and usage of Fin.do app and for a maximum of 3 years after the end of the provision of Service and usage of Fin.do app, unless the User objects to the processing for marketing purposes sooner.
  9. Sending by the Company to the User electronic messages about the execution status of the Service may prove necessary for its provision and does not constitute commercial (marketing) information.
  10. For additional information regarding personal data processing the User shall contact the Company via Help Centre of the Fin.do app or website of the Company www.fin.do.

13. Fees

  1. The use of the Service is subject to the transaction fee. The amount of the fee will in each case depend on the amount of the transaction, currency and countries between which the payments will be made, and are not set as fixed amount in advance. The fee for each relevant transaction will be displayed to the User before approving the transaction.
  2. Transactions can be made in the currency of the card indicated by the User while adding the Payment Card to the Fin.do app, however, where the currency of the transaction differs from the base currency of the Payment Card, the currency exchange of the issuing Bank will apply. The Company is not liable for the Banks’ currency rates, therefore the User is required to insert correct base currency of the card to avoid double conversion. While making transaction the currency exchange rate with respect to each relevant transaction will be displayed to the User before approving the transaction.
  3. The fee for the facilitation of the Service on the Fin.do app shall be withdrawn from the Sender’s Payment Card account (where it is on the Sender’s part) or the amount to be credited to the Recipient shall be reduced by the amount thereof (where it is on the Recipient’s part).

14. Complaints, Communication and Language

  1. Complaints concerning non-execution of the Service or its execution not in line with the principles defined in these Terms and Conditions may be submitted via Help Centre of the Find.do app or website of the Company www.fin.do.
  2. The complaint should contain:
    1. indication of the Users’ full name, phone number, email, transaction number (available in the User’s transaction history);
    2. indication of the faulty Service, as well as a description of the subject of the complaint;
    3. transaction details such as date, time, amount and last 4 digits of the card involved if the faulty Service related to a transaction;
    4. a return address, to which a response is to be sent, if the User wishes to receive a response otherwise than through the channel through which the complaint was submitted.
  3. The Company will accept complaints in English or any other native languages of the Users but the responses to the Users will in all cases be provided in English.
  4. Complaints are examined and responded by the Company immediately, no later than within 20 days from the date of receipt of complaint. The deadline is deemed observed after sending, prior to its expiry, a response to the User via Help Centre of the Find.do app and via other channels according to the User’s Notification Settings of the Fin.do app. 
  5. Notices concerning leakage of passcode, CVV numbers or other security details etc., which require action by the Company with respect to blocking the User’s profile, shall be submitted via Help Centre of the Find.do app or website of the Company www.fin.do. These will be managed immediately, no later than within 2 hours from the time of receipt of the blocking request.
  6. The Company may as well always be contacted by its correspondence address indicated in these Terms and Conditions or by email at support at fin.do.

15. Marketing

  1. The Company may contact the Users from time to time about the Fin.do app, including marketing messages relating to the Fin.do app. The Company will do this electronically, for example by email, SMS, in-app notifications or other messages on the Fin.do app or device or by telephone. All such communications will come from the Company. The Company will never pass Users’ information to a third party for them to use in their own direct marketing without the Users’ consent.
  2. The User may notify the Company at any time if he/she does not wish to receive marketing messages from the Company by contacting the Company as set out in these Terms and Conditions or by following any instructions the Company may include in the message it sends to the User. Also marketing notifications may be de-activated in the settings of the Fin.do app, and all in-app marketing notifications may be de-activated by the User in the settings of his/her mobile device.

16. Changes to the Terms and Conditions

  1. The Company can change these Terms and Conditions at any time by notifying the Users of a change when the User next opens the Fin.do app and/or by email. The new Terms and Conditions will be displayed on–screen and the User may be required to read and accept them to continue the use of the Fin.do app.
  2. From time to time, updates to the Fin.do app may be issued via the Apple App Store or Google Play Store. Depending on the update, the User may not be able to use the Fin.do app until he/she has downloaded the latest version and accepted any new Terms and Conditions.

17. Language

  1. Due to worldwide availability of the Fin.do app, these Terms and Conditions are prepared in the English language, and the Fin.do app also operates in English. By accepting these Terms and Conditions and using the Fin.do app, the User confirms that he/she understands the English language and agrees to communicate with the Company in the English language as far as the Fin.do app and legal relations arising under these Terms and Conditions are concerned.

18. Final Provisions

  1. These Terms and Conditions are governed by the Lithuanian law.
  2. These Terms and Conditions are available at all times for each User on Fin.do app and the Company’s website.

Appendix to the Terms and Conditions of use of Fin.do mobile application table of limits

Limits of amounts of transactions are dependent on whether the User has passed Full Verification process or not. The detailed description of these limits is set forth in the table below.

Table of the main transaction limits* (applicable per Payment Card)

Domestic daily Domestic monthly Cross-border daily Cross-border monthly

Before full verification

1 000 EUR 1 000 EUR 1 000 EUR 1 000 EUR

After full verification

1 000 EUR 5 000 EUR 1 000 EUR 5 000 EUR

* The company has a right to apply other limits, which will vary across currencies, amounts and types of card (prepaid, debit or credit cards). If you’re under or over any of our limits, we’ll let you know with an error message displayed on the screen.