Frequently asked questions
Overview and key concepts
Open banking is the use of open APIs that enable third-party developers to build applications and services around financial institutions. Tink provides services in the open banking industry and therefore offer services that rely on interactions with financial institutions. Our services are provided on a software-as-a-service basis and all use is governed by the terms of our Master Service Agreement.
Some open banking activities require a license or authorization under open banking legislation. Tink's platform can be configured to support both licensed and non-licensed customers and consequently, understanding the licensing configuration is important as it has legal implications. Here are some key differences that depend on licensing:
Licensed customers - Tink operates as a technical service provider when provisioning services to licensed customers and contracts with its customers like in a normal customer-vendor relationship
Non-licensed customers - Our customers redirect end-users to Tink, who then offers services that are subject to licensing requirements directly to the end-users, after which the end-users are redirected back to the customer. Our services to our customers are governed by the Master Service Agreement and our services to end-users are governed by our EULA
Want to know more about open banking or deep dive into the different terms and industry parties? You'll find more information in these resources:
What is an agent?
Under PSD2 an 'account information service' is an online service which provides consolidated information on payment accounts held by a payment service user with payment service providers. In plain language, this essentially means that non-licensed entities may not display financial information to the end-users as that activity likely qualifies as an account information service under the PSD2.
Tink can, in some limited cases and for a limited time, appoint its customer as an agent of Tink which means that the customer can display the financial information back to the end-users on behalf of Tink. Contact us if you would like to explore options.
Is Tink subject to AML-requirements?
Tink is an authorised payment institution licensed by the Swedish Financial Supervisory Authority (Finansinspektionen) to provide PIS and AIS. Therefore, Tink is subject to requirements in a number of anti money laundering and counter terrorist financing legislative acts.
We have received an onboarding form from Tink, why do we need to fill this out?
When Tink is providing services on our license, we enter into a business agreement with you as set out in the AML /TF framework. This means that Tink needs to perform a customer due diligence on you (as a part of Know Your Customer rules), which we do via this onboarding form. We also perform sanction- and PEP-screenings.
I don't want to fill out the form, can I use the services anyway?
No, you can't. If you don't complete the onboarding form and provide the requested information, Tink will not be able to provide services for you.
Why do Tink have different PIS-limits for different customers?
The AML-framework is risk based. Tink's mitigating measures in place, to handle the AML/TF-risk that we are exposed to, should be adequate to the level of risk. When assessing the AML/TF-risk, Tink is obliged to take into consideration certain factors such as for example certain geographical aspects and what operational areas the customer is active in. If a customer relationship impose higher risks, Tink will as a standard impose a lower PIS-limit to meet the increased risk.
Is Tink a data controller or a data processor?
Tink process personal data in either of two capacities depending on the relationship in which we process that personal data in.
Tink acts as a data controller when we process personal data pursuant to our agreements with consumers (i.e. all of Tink's payment service users).
Tink acts as a data processor when we process personal data on behalf of our corporate customers.
Licenses and authorisations
Can customers white label Tink Link?
While the look and feel of Tink Link can be somewhat customized within our services, we only permit licensed customers to fully white label Tink Link as we use Tink Link to ensure that we meet our regulatory requirements when provisioning services to payment service users (or end-users).