Fingopay Terms and Conditions

About us

Sthaler Limited (Sthaler) is a UK registered company, no 08161567, with its registered office at 4 Riverview, Walnut Tree Close, Guildford, GU1 4UX, United Kingdom.

Fingopay is a product of Sthaler.

Questions about the Fingopay service, GDPR and your data privacy rights can be resolved by emailing our Data Protection Officer at

Contract and scope of application

You agree to these Terms and Conditions by applying for a Fingopay account. The Terms and Conditions will continue to apply whether or not the verification of your account is successful.

Excluding any other terms and conditions, the present Terms and Conditions will apply to all aspects of the relationship and the contract between you and Sthaler, unless otherwise expressly agreed to in writing from Sthaler. By applying for an account with us you confirm that you accept these terms and conditions and that you agree to comply with them. We recommend you print out a copy of these terms for future reference.

Sthaler reserves the right to modify the terms and conditions of Fingopay Services at any time. The modified Terms and Conditions will apply immediately after being published on the Fingopay website. You will be informed of any changes by email, via notifications on the website and/or by notifications through your Fingopay account.

In the event that you are not in agreement with any modified or revised Terms and Conditions, then you are able to withdraw from using the service via your Fingopay account. In your account you have the right to delete your account.

Fingopay Service

The identification service provided by Sthaler in order to help consumers register finger vein biometric information to process payments (via card or Variable Recurring Payments) at approved retailers and points of sale.

On successfully creating a Fingopay account, the login details (email address and self-created password) are strictly personal and confidential. Sharing this information with any other person or entity is not permitted, you must take all reasonable measures to prevent the abuse, misuse, theft, or loss thereof.

Information provided by you for the registration will be stored by Sthaler in accordance with appropriate data protection laws as set out in the Data Privacy Policy.


You may delete your Fingopay account at any time by using the ‘delete’ button in your Fingopay account. Relevant records will be kept for the purposes of auditing, in accordance with appropriate laws.

Sthaler reserves the right to delete Fingopay accounts with immediate effect if there is any reason to believe or to suspect that the verification and/or validation provided has been faulty or is no longer correct. In order to gain access to a Fingopay account again, you will be required to reapply.

Sthaler reserves the right to delete accounts with immediate effect if communications from you to Sthaler employees or partners are considered harassing, threatening, abusive and beyond the provision of reasonable services offered to support applications for the service. Any continuation of abusive, threatening or harassing behaviour will be reported to the appropriate authorities.

Sthaler reserves the right to delete accounts with immediate effect if it is suspected or known that the information provided during registration and enrolment is false/fraudulent as set out in the Data Privacy Policy. Any fraudulent activity will be referred to the relevant authorities.

Our obligations

Sthaler will provide the Fingopay Service as described on the website in accordance with the Terms and Conditions, the associated Data Privacy Policy and Good Industry Practice.

Sthaler aims to provide a continuously functioning and accessible service but makes no guarantees about the availability of any services provided. You accept the fact that service interruptions may occur which would render Fingopay inaccessible on some occasions.

Sthaler reserves the right to limit access to, or render the Fingopay Service entirely inaccessible for limited periods of time in order to carry out maintenance and/or implementation of required modifications. Sthaler aims to carry out these scheduled ‘down times’ in periods which could be reasonably determined to affect the minimum number of users as far as possible e.g. outside of operating hours.

Sthaler will provide the Fingopay Service in accordance with the published Data Privacy Policy. This Data Privacy Policy will be updated from time to time to reflect changes in the processing of data in relation to the service. You will be informed of any changes by email, via notifications on the Fingopay website and/or by notifications in your Fingopay account.

Your obligations

You agree to supply the necessary and required information in order to register and enrol in the Fingopay Service.

You agree to ensure and guarantee that all data and information provided is correct, complete, accurate and up‐to‐date and conforms to the requirements as set out during the process of registration and enrolment. You agree to notify Sthaler of any changes to your Fingopay registration information.

You accept and agree to inform Sthaler immediately if there are any security concerns, security issues or data leaks. Any report of this information to Sthaler will be treated as strictly confidential and handled in accordance with appropriate laws and regulations in order to minimise damage to the affected users, Sthaler, or 3rd parties. Sthaler aims to resolve any security alerts or hazards as fast as reasonably possible and will take steps to inform any 3rd parties affected.

You agree to attend the biometric enrolment station and follow the instructions outlined as the enrolment process. The credentials and information collected from you on the registration process will be kept and remain for the sole use of the biometrically enrolled individual and you agree not to allow any other individual to enrol on your behalf.

Use of website and associated materials

You are prohibited from copying, passing on, selling, publishing or making profit from any content of the website, products, services or associated materials of Sthaler or the Fingopay Service.

You are prohibited from using the website, products or associated materials of Sthaler or the Fingopay Service in any way that causes, or may cause, damage to the website or impairment of the performance, availability or accessibility of the website, products or associated materials.

You are prohibited from accessing the website and associated materials of Sthaler or the Fingopay Service using any robot, spider or other automated means.

Personal data

By entering into the contract, you agree that personal data will be processed according to  the UK Data Protection Act 2018. The data protection act refers to the law regarding the protection and processing of personal data.

Sthaler and any partners process information according to the laws specified in EU General Data Protection Regulations (GDPR), Fingopay remains the data controller for the processing of personal data at all times, whether using partners or not. The Data Privacy Policy contains information on how Sthaler treats personal data it processes.

You have the right to complain to the Lead Supervisory Authority, or any other Supervisory Authority, about issues regarding the storage and processing of your personal data.


Sthaler and you are obliged to take all reasonable measures to protect confidential information or the Fingopay account from unauthorised access, loss, damage, modification or unauthorised processing. In the event that this occurs Sthaler must be informed immediately of any such unauthorised access, loss, damage, modification or unauthorised processing.

Sthaler will inform you of any unauthorised processing identified within your account.

Rights of ownership and intellectual property

Any intellectual property rights associated with the Fingopay Service or associated materials remain at all times the property of Sthaler, the licensee or our supplier.

The right to use the service or associated materials related to the Fingopay Service does not imply any transfer of any intellectual property rights of the service or associated materials to you. Sthaler only provides a non‐exclusive right to use the Fingopay Service and/or associated materials for the purpose of creating an account. The rights of your use are strictly personal and cannot be transferred to any other person.

You are prohibited from using the service, data or associated materials in any way, or by use of any part, that would result in the violation of intellectual property rights of Sthaler, any of its brands and products/services, the licensee or suppliers.

Sthaler reserves the right to take all measures necessary in order to protect intellectual property rights owned by them, the licensee or suppliers. These measures include the termination of the use of the Fingopay Service or associated materials upon the termination of the contract. You are prohibited from removing or circumventing any such measures in any way.


Nothing in these Terms and Conditions excludes or limits our liability in respect of a) any breach of law by Sthaler or its sub-contractors, b) any loss, unauthorised access to or corruption of Personal Data held by Sthaler or its sub-contractors (including any credentials issued to you), c) any wilful default on the part of Sthaler or its sub-contractors. Any other limitations on liability included in these Terms and Conditions must be reasonable in all the circumstances of the services provided by Sthaler to the user.

We are not responsible to you for any loss or damage suffered by you which was not an obvious consequence of us breaching these Terms and Conditions. We are not responsible to you for losses which you suffer due to any events beyond our reasonable control. We are not responsible to you for losses which you suffer which are not directly caused by our actions.

Sthaler cannot be held liable for damages resulting from events beyond reasonable control or not caused directly by actions by Sthaler.

Sthaler cannot be held liable for any indirect damages or damages caused because you did not/or do not take appropriate measures to i) limit such damages immediately after a damaging event has occurred, ii) prevent further damage or subsequent damages resulting from the initial event, iii) immediately took action to inform Sthaler about events which would cause damages and/or took action to provide relevant information to Sthaler.

In all cases the liability of Sthaler shall be limited to the usual and foreseeable damages. Sthaler cannot be held liable for any business damages after using the Fingopay Service in the capacity of a consumer. The use of the Fingopay Service contemplated by these Terms and Conditions is as a customer for private use only.

Sthaler can never be held liable in respect of any damages resulting from:

  • Your unauthorised or improper use of the data, the Fingopay Service and/or related materials;
  • That the data you have provided is incorrect and/or incomplete, or not provided to Sthaler in a timely manner;
  • Loss, theft or unauthorised sharing of your own data or login details provided to you;
  • Your failure to abide by any obligations as provided in these Terms and Conditions, including not cooperating with the Terms and Conditions;
  • Temporary inaccessibility of the Fingopay Service;
  • The downtime or unavailable online tools of 3rd parties.
  • Regardless of the provisions in Liabilities, Sthaler does not exclude or limit in any way any liability where it would be unlawful to do so. Including in particular, liability for death or personal injury caused by Sthaler negligence or the negligence of employees, agents or subcontractors and any liability for fraud or fraudulent misrepresentation.

Limitation of action

Any claim for damages against Sthaler must be brought within one year after the damage has occurred.

Force majeure

Sthaler are not obliged to perform any of the obligations under the contract or the Terms and Conditions in case of force majeure. Force majeure is understood to include but is not limited to improperly functioning materials provided by users, requirements under the law, power cuts, improper functioning of the internet, or of computer‐ and telecommunication facilities, extreme weather conditions, fire, flooding, war, strike, general problems of transportation and unavailability of one or more of Sthaler employees or subcontractors.

Applicable law and disputes

The contract and the Terms and Conditions are governed by English law in adherence and conformity with applicable European Directives, specifically Article 8 of the European Convention of Human Rights regarding laws on privacy.

Any dispute that cannot be settled amicably will be brought before the competent judge of the place where Sthaler have a statutory seat (England and Wales). If applicable, European law provisions determine that another judge is also competent, then the case may also be brought before the relevant jurisdiction.

The Fingopay Service is provided from system based in the UK, whilst the processing is available locally. From a data privacy perspective (GDPR) the Lead Supervisory Authority is the UK ICO who can be contacted here:


Sthaler does not provide for any other guarantees, undertakings, and/or commitments than those explicitly provided for in the Terms and Conditions.

Variable Recurring Payments

Payment transactions completed using the Variable Recurring Payments service are processed by Reflow in accordance with the VRP Rulebook for the purpose of the Sandbox live trial. The trial complies with all reasonable rules and / or directions given in the VRP Rulebook. 

Consumer Protection

Your ability to use Variable Recurring Payments via Fingopay Platform is subject to

  • Agreeing to the Terms;
  • Providing correct and accurate credentials to initiate a payment order with respect to the relevant Payment Account; and 
  • Payments cannot be made outside the caps you have agreed.
  • You will be notified for each payment unless you opt-out of notifications.
  • In the event of a dispute, if you cannot get a resolution from Fingopay you are entitled for a full and immediate refund from your Bank, pending investigation.
  • You can view or cancel the VRP Mandate through your Starling Bank mobile app (via Marketplace & Reflow as Connected Services) at any time.
  • All VRP mandates created using this service will be cancelled by 1st March 2020, the date when the Sandbox live trial ends.

For any VRP Dispute

  • We will provide information relating to a VRP Dispute that is requested by you and / or Reflow or Regulatory Authority without delay; and
  • To the extent any VRP Dispute is caused or otherwise attributable to you or a Merchant with whom you have entered into an agreement, you will compensate us for any Loss incurred or sums paid as a result of the VRP Dispute without dealy and in any event within 14 days of our written notice to you of the same. 
  • You agree that any VRP Dispute will be handled in accordance with the VRP Rulebook’s dispute and arbitration process. In relation to any VRP Dispute that has been referred to to arbitration, both you and we agree that Open Banking will make the final decision and will be bound by its decision.

Concluding provision

Should any provision of the Terms and Conditions be declared invalid or void, this shall not affect the validity of any of the other provisions included in the Terms and Conditions. In such case, Sthaler will amend the Terms and Conditions with the aim to achieve the same object and purpose served by the provision declared invalid.


The following words have the following meaning:


“User”, “you” or “your” in these Terms and Conditions refer to you as a registered user of the Fingopay Service.

Identity service

The service provided by us to you entailing the verification of your identity and/or the validity of any documents or data. If this verification and/or validation process results in a confirmation and/or validation of the information provided by you, an identity account will be created for your personal use.


The relationship between you and us, governed by the Terms and Conditions according to the first article of the Contact and scope of application section. 

Terms and Conditions

These Terms and Conditions as set out here.

Data / Information

Any data you have provided to us or in connection with the Fingopay Service.


The holder of a licence for intellectual property rights connected to the Fingopay Service.


Materials shall refer to any software, hardware, websites, database, designs, models, programs, reports, and other identity services and materials put to use by us in relation to the Fingopay service.

Good industry practice

At any time, the exercise of that degree of care, skill, diligence, prudence, efficiency, foresight and timeliness which would be reasonably expected at such time from a leading and expert provider of services which are similar to the Fingopay Service, such provider seeking to comply with its obligations in full and complying with applicable laws and with ISO27001 and Scheme accreditations.

Fingopay Service

Service provided by Sthaler in order to help consumers register finger vein biometric information to process payments (via card or Variable Recurring Payment) at approved retailers and points of sale.

Variable Recurring Payment (VRP)

An instruction from a payer to a PSP providing Payment ‎Initiation Services to initiate ongoing payments from the payment ‎service user’s online payment account held with an account ‎servicing PSP.‎

VRP Dispute

A dispute raised by a Customer when using VRP for one of the following reasons; (i) goods or services not provided, (ii) goods or services not as described; (iii) advance notification not sent as promised (e.g. being overdrawn, amount higher than expected); or (iv) merchant refund and cancellation problems.

VRP Rulebook

The Open Banking Rulebook for Open Banking Variable Recurring Payments.


Reflow, is the trademark of Reflow Zone Limited, a company registered in England and Wales (No. 11235853), register office is at 86-90 Paul Street, London EC2A 4NE. Reflow Zone Limited is authorized and regulated by the Financial Conduct Authority (reference number 811078).

Lead supervisory authority

Is the UK Information Commissioners Office (ICO).

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