Open Banking Module Terms
Terms appendix for the Open Banking module.
Updated / published: 09.02.2026
Appendix No. 2 to the Terms of Service - Open Banking Module Terms
Module name in the Service: Swift Settle
Partner: EasyCheck (for OpenBanking/AIS)
1. Scope
1.1. These Module Terms apply only to Clients who have activated or use the “Swift Settle” Module.
1.2. Depending on the Package and configuration, the Module enables:
a) retrieval of transaction and account data from the Client’s bank accounts in read-only mode through the AIS (Account Information Service) provided by the Partner;
b) automatic and manual matching (reconciliation) of bank transactions with invoices registered in the Service;
c) automatic updating of invoice payment statuses based on matching results;
d) generation of bank statements in MT940 format based on the retrieved transaction data.
1.3. The Module is not used to initiate payments (PIS). Access to banking data is informational only (read-only), unless a separate Service functionality is expressly described in an update to the Module Terms.
2. Role of the Partner and External Systems
2.1. The Client acknowledges that the Service Provider only provides the Module integration layer in the Service, while the AIS (Account Information Service) is performed by the Partner as an AIS provider (AISP). The Service Provider does not provide AIS as a regulated entity within the meaning of PSD2.
2.2. Module activation requires redirecting the Client to the Partner or to a bank/financial institution (External System) to authenticate and grant consent to access account data.
2.3. The Client acknowledges that the availability, scope and format of transaction data may depend on the bank/financial institution and the Partner. The Service Provider has no influence on the format, completeness or timeliness of data made available by the bank.
2.4. To perform transaction-to-invoice matching, the Module may use services of external data processing technology providers, including providers of semantic search services and language models (AI/LLM), if this functionality is available and enabled for the relevant Client. Data transferred to these services is limited to what is necessary to perform the matching (for example date, amount, currency, transaction description and selected contractor identification data) and does not include bank authentication data. The data is subject to appropriate data processing agreements.
3. Consents and Authorizations
3.1. The Client is responsible for ensuring that the person authorizing access to the bank account is authorized to access that account and grant consents on behalf of the Client.
3.2. Consents to access account data have a limited validity period specified by the bank/Partner, including where periodic re-authentication may be required. The Module sends notifications about upcoming consent expiry 14, 7 and 1 day before expiry. The Client is responsible for renewing consents on time.
3.3. Expiry or withdrawal of consent immediately stops the retrieval of new transaction data for the relevant account. Data retrieved before consent expiry remains in the Service until deleted by the Client or until termination of the Agreement, in accordance with the retention and deletion rules set out in the Terms of Service.
3.4. The Client may connect more than one bank account in more than one bank to the Module. Each connection requires separate authorization and consent.
4. Transaction Data Synchronization
4.1. After Module activation and consent grant, transaction data is retrieved automatically according to the synchronization schedule configured by the Client (frequency: hourly, daily or weekly; time window: any time, business hours, night hours, weekends or custom).
4.2. The Client acknowledges that:
a) transaction data is retrieved with a delay depending on the bank and the Partner - the Module does not provide real-time access to transactions;
b) in the event of temporary unavailability of the Partner or bank, synchronization is retried automatically (up to 3 attempts);
c) the scope of retrieved data includes transactions from a period configurable by the Client, with a default one-day overlap of time windows to ensure data continuity.
4.3. Retrieved transaction data is stored in the Service Provider’s infrastructure for the duration of the Agreement. After termination of the Agreement, the data is deleted in accordance with section XI of the Terms of Service, subject to obligations arising from applicable law.
5. Matching Transactions to Invoices (Reconciliation)
5.1. The Module offers the following methods for matching bank transactions to invoices:
a) Heuristic matching - based on comparing amounts, dates, reference numbers and contractor data. Used as the first matching method;
b) AI-assisted matching - based on semantic search (vector embeddings) and verification by a language model (LLM). Used when heuristic matching does not produce sufficiently confident results;
c) Manual matching - the Client independently indicates the relationship between a transaction and an invoice through the Service interface.
5.2. Automatic confirmation of matches: if automatic match confirmation is enabled, matches with a high confidence level (>= 90%) may be confirmed automatically without Client intervention. Matches with a medium confidence level (>= 70%) are routed to a manual verification queue for the Client.
5.3. A confirmed match (automatic or manual) automatically updates the invoice payment status in the Service, including marking the invoice as fully or partially paid. The Client is responsible for verifying payment status correctness and correcting any irregularities. Payment status in the Service is auxiliary and does not constitute proof of payment or confirmation of account balance.
5.4. The Client acknowledges that:
a) algorithmic matching (heuristic and AI-assisted) is probabilistic - the Service Provider does not guarantee 100% correctness of matches;
b) AI-assisted matching may in rare cases result in a false match (false positive). The Client should regularly review automatically matched transactions;
c) multi-currency matching uses exchange rates and amount tolerances; exchange rate differences may affect matching accuracy;
d) configuration of automatic matching thresholds and amount tolerances affects matching accuracy and frequency.
5.5. The Service Provider is not liable for the consequences of automatic or manual matches approved by the Client, or automatically on the Client’s behalf in accordance with section 5.2, including incorrect marking of invoices as paid.
5.6. AI-based features are used only for preliminary data sorting and do not replace accounting verification. The Service Provider provides a technological tool (data bridge), not accounting advisory services. The Client is solely responsible for verifying match correctness before posting it or sending it to external systems.
6. Generating MT940 Statements
6.1. The Module enables generation of bank statements in MT940 format based on retrieved transaction data.
6.2. Generated MT940 statements are auxiliary and are created based on data received from the Partner/bank. They do not constitute official bank statements and should not be treated as a document confirming bank account balance.
6.3. The Client is responsible for verifying the consistency of generated statements with official bank statements before using them for accounting or tax purposes.
7. Liability
7.1. The Service Provider is responsible for due technical diligence in integrating the Module in the Service, subject to the liability limitations set out in the Terms of Service.
7.2. The Service Provider is not liable for:
a) unavailability, limitations or errors on the side of banks, the Partner or AI service providers;
b) consequences of expiry, withdrawal or non-renewal of consent to access the account;
c) consequences of the Client approving, manually or through enabled automation, incorrect matches of transactions to invoices suggested by AI/heuristic algorithms. The Client acknowledges that these suggestions are auxiliary only;
d) consequences of automatic updates of invoice payment statuses based on matches;
e) incompleteness, delays or errors in transaction data made available by the bank/Partner;
f) irregularities in generated MT940 statements resulting from incomplete or incorrect source data;
g) consequences of synchronization and matching parameter configuration made by the Client;
h) exchange rate differences affecting multi-currency matching.
8. Data Security
8.1. Data and secrets used to communicate with the Partner (EasyCheck) are stored in a secure key store. Access tokens may be stored temporarily, for example in memory, and renewed according to the Partner’s requirements. If connection identifiers or equivalent authorization mechanisms requiring storage are used, they are stored in encrypted form.
8.2. Transaction data retrieved from the Client’s bank accounts is stored in the Service Provider’s cloud infrastructure and is subject to the security standards described in the Privacy Policy.
8.3. To perform semantic matching, selected invoice and transaction data, to the extent necessary for matching, may be processed by external AI service providers. The data does not include bank authentication data. The list of processors and data transfer rules is available in accordance with section XVI.2 of the Terms of Service and in the Privacy Policy.
9. Disabling the Module
9.1. The Client may disable the Module or disconnect individual bank accounts in the Service.
9.2. Disabling the Module stops retrieval of new transaction data and stops automatic matching.
9.3. Transaction data retrieved before disabling and previous matching results remain in the Service until termination of the Agreement or deletion by the Client. Disabling the Module does not automatically delete historical data unless the Client initiates deletion.
9.4. Disabling the Module does not affect other services provided under the Terms of Service, unless the Module is an essential element of the Package.
10. Module Changes
10.1. Changes to the Module Terms are subject to the rules in section XV of the Terms of Service concerning changes to Module Terms.