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Audience:

Operators

Brand and communication rules

Must → Partner obligations

As a Swan Partner, you are allowed to sell and present Swan's commercial offer as your own, without any obligation to mention Swan.

You must, however, comply with data protection regulations. Communicate the following information to your users:

  1. Provide a company privacy policy.
  2. Tell your users that their data will be shared with Swan.
  3. Share your company's legal status. Provide the following information in your footer and legal notices:
    • Your company's legal status
    • If in France, your Orias registration number
    • Legal name as provided on your official paperwork
    • Postal address

Can't → Partner restrictions

As a Swan Partner, you can't do the following:

  1. You can't manage sensitive operations yourself (for example, Strong Customer Authentication), although you may participate in collecting required documentation.
  2. Regulations stipulate that companies with your legal status can't call yourselves banks or neobanks.
  3. You can't sell payment services. Only Swan is allowed to sell payment services.
  4. You can't call your offer a “bank account”. You may, however, use the wording "payment account". Please make sure not to choose wording that suggests you are the entity providing payment accounts because that's Swan's responsibility. Consider the following naming suggestions:
    • MyBrand Account
    • MyBrand Premium
    • MyBrand Wallet

Can → Partner capabilities

As a Swan Partner, you can:

  1. Present payment services directly on your platform. You don't have to route your users to Swan.
  2. Provide access to your own platform, app, or SaaS, where users can manage their Swan accounts, prepare payment orders, and more.
  3. White-label the branding. You can brand Swan's payment services as your own. Make sure to mention Swan as a partner in your Terms and Conditions.
  4. Present Swan's Terms and Conditions and commercial offer within your own Terms and Conditions, or directly on your website.
  5. Collect client information and identification documents yourself (for example, proof of address, company registration), then forward them to Swan. Make sure to share this intention in your GDPR notice to your clients.

How to present your offer

Image of Dashboard consent notification

  1. You can brand banking services entirely as your own, without having to mention Swan as a partner. (Note that if the product seems unclear about which entity is regulated, you might be asked to mention Swan.)
  2. You can provide details of banking services on your own website.
  3. The example provides a correct mention of data protection policies.
  4. You can offer banking services directly on your platform.
  5. The example provides a correct way to declare that you are a Registered Swan Intermediary.
Presenting your billing offer

To learn about how Swan handles fees and your options to charge your users, refer to the guide to build a compliant billing offer.

Referring to Swan

If you are preparing another project or license application and wish to cite Swan in communications to partners, regulators, investors, and more, you must first submit materials that mention Swan to receive Swan's validation.

Send an email to compliance@swan.io with all extracts of your presentation that mention Swan (and only these extracts).