Payment initiation service provider / NEO Finance - "NEO Finance", AB (legal entity code 303225546, registered address: Ukmerges 126, LT-08100, Vilnius, Vilnius, Republic of Lithuania, tel. 8 700 70075, e-mail: [email protected] website:; Electronic money institution license No. 7, issued January 5, 2017, licensed and supervised by the Bank of Lithuania; data on NEO Finance are collected and stored by the State Enterprise Center of Registers), its branches and representative offices and other legal entities, which NEO Finance uses to provide its services and which are authorized to act on behalf of NEO Finance. All payment services will be provided exclusively by NEO Finance, AB.

Payer - a natural (private)or legal person, who initiates a payment order in the NEO Finance system using the Payment initiation service provided by NEO Finance, AB.

Payment initiation service (PIS) - means the service of initiating a payment order related to a payment account held at another payment service provider at the request of the Payer through the Payment initiation service provider.

Payment service provider (PSP) - for the purposes of these Rules, is understood to mean the Payment service provider at which institution, the Payer has its own payment account from which the Payer intends to execute the payment transfer (i.e. banks, other credit institutions, etc.).

Basic features of a payment initiation service

1. These Rules, which are made available to the Payer prior to the use of the PIS, determine the operation of the Payment initiation service in NEO Finance system, provide the main features of the Payment initiation service, regulate the provision of Payer's data for the purpose of the Payment initiation service, as well as the safety and confidentiality of such data.

2. The Payment initiation service provided by NEO Finance enables the Payer to connect to his / her personal electronic banking system via NEO Finance, submit an automatically generated payment order to his PSP and approve (authorize) it. The Payer initiates and submits the Payment order, not connecting directly to his electronic banking system, but through a software solution developed by the Payment initiation service provider.

3. The Payer shall be informed in NEO Finance system about the commission fee applicable to the Payer and the amount thereof prior to initiation of the payment order. By means of the present Terms and Conditions, the Payer is informed that payment orders are subject to a standard PSP commission fee applicable to Payers charged for the payment order of a corresponding type, which shall be debited by the Payer’s PSP. If the Payer’s PSP informs about the price of such payment order, Neo Finance shall also notify the Payer prior to authorisation of the payment order.

Detailed operation of the payment initiation service

4. When initiating a payment order from a payment account held by the Payer, he shall submit his electronic banking data in a secure PIS medium (website) created by NEO Finance, which shall be entered into the specific information fields provided in the NEO Finance system. Whenever the Payer's Bank:

  • 4.1. "Swedbank", AB 1) M. Signature - User ID and telephone number; 2) Smart-ID - User ID and phone number; 3) Code card - User ID and password; 4) PIN Generator - Used ID and password;
  • 4.2. "SEB Bankas", AB 1) M. Signature - Identification code; 2) Smart-ID - Identification code; 3) Generator / card - identification code;
  • 4.3. "Luminor bank", AB (DNB) - 1) M. Signature - Access code; 2) Smart-ID - Access code; 3) PIN card / Generator - identification code;
  • 4.4. "Luminor bank", AB (Nordea) - 1) M-signature - Customer number; 2) Nordea Codes - Customer number; 3) Generator - Customer number;
  • 4.5. Lithuanian branch of AS "Citadele banka" - 1) M-signature - Username; 2) Code Card - Username and Password; 3) Generator - Username and Password;
  • 4.6. "Šiaulių bankas", AB - 1) M. Signature - Username (ID) and user password; 2) Username (ID) and user password; 3) Code Card - Username (ID) and user password; 4) Generator - Username (ID) and user password.

5. Using the electronic banking data provided by the Payer, the NEO Finance system automatically connects to the Payer's electronic banking and initiates a payment order. In performing this function, NEO Finance does not collect, store or protect electronic banking data (personalized security features) provided by the Payer and the final data recipient is the beneficiary, specified by the Payer. The information used to connect to the Payer's e-banking (customer identification code, password, generator codes, password card codes, etc.) is encrypted and used only for one-off payment order initiation and one session, until the signed payment confirmation is received from PSP.

6. The payer is expressing consent to initiate the PIS shall enter his electronic banking data electronically. The payer, through the use of PIS provided by NEO Finance, personally and unilaterally initiates the submission of a payment order in his own name to the PSP of his choice. The payment order may be revoked until the Payer has given his consent to initiate the PIS.

7. If the Payer has more than one payment account in a particular PSP institution, the Payer shall choose, during the payment process, the one from which he intends to make the payment.

8. If the account specified by the Payer does not contain the currency indicated in the payment order or the amount thereof is insufficient, the Payer shall not be given the possibility of currency exchange.

9. By providing PIS to the Payer, NEO Finance automatically generates a payment order based on the Payer's data, provided to NEO Finance, which automatically specifies:

  • 9.1. the payment amount approved by the Payer at the time of initiating the payment order, where the payment amount was specified by either the Payer himself or the Seller (NEO Finance business customer) from which the Payer intends to purchase the services or goods;
  • 9.2. the name and the account number of the beneficiary;
  • 9.3. the purpose of payment:
  • 9.3.1. if the beneficiary is the Seller (business customer of NEO Finance) from whom the Payer intends to purchase the services or goods - the purpose of payment is indicated according to the data of the Seller (customer of NEO Finance) in the system, according to which the Seller (beneficiary) could easily recognize the payment order and for what goods or services, or for what purpose it was executed;
  • 9.3.2. if the beneficiary is the Payer himself who seeks to top-up his NEO Finance payment account, the purpose of payment shall be indicated taking into account the purpose of account replenishment, chosen by the Payer.

10. Once a transfer order has been formed, it is impossible to change the amount, beneficiary or other details of the transaction.

11. The Payer shall approve (authorize) the automatically generated payment order of NEO Finance.

12. After successfully initiating the execution of a Payment order, NEO Finance shall submit to the Payer and the beneficiary - a confirmation of the proper initiation of the Payment order and the successful execution of the Payment order. Together with this information, NEO Finance shall provide data, enabling the payer and the beneficiary to identify the payment transaction, the amount of the payment transaction and, where appropriate (i.e. while using personal identification number transfer service) to identify the payer to the beneficiary, together with the data transmitted with the payment operation.

13. Upon initiation of a payment order by the payer, the payment shall be made:

  • 13.1. if the Payer's and beneficiary's accounts are in the same bank - on the same banking day;
  • 13.2. if the beneficiary's account is in another bank - no later than the end of the next banking day.

14. NEO Finance informs the beneficiary of the successful execution of the payment.

15. When initiating the submission and execution of a payment order, NEO Finance shall provide the Payer and the Beneficiary with data enabling to identify the Payment and the Payer.

16. NEO Finance shall not, at any time, keep the Payer's funds when providing the Payment initiation service, but shall immediately credit them to the Beneficiary's NEO Finance account after issuing electronic money for them or to the Beneficiary's account with another financial institution.

17. If, at the initiation of a payment order, the Payer's PSP requests a change of password, filling in a questionnaire or answering any questions, these PSP questions shall not be submitted to the Payer. NEO Finance will inform the Payer that further provision of the PIS is not possible in this particular case because the Payer's MPT requests a password, a questionnaire or answers to any questions.


18. NEO Finance assumes full responsibility for the correct submission of the Payer's payment order to the MPT, chosen by the Payer and for the security and confidentiality of the submitted electronic banking credentials.

19. If NEO Finance has provided PIS and credited Payer's specified funds to the Beneficiary pursuant to a transfer initiated by the Payer but, for any reason, the funds have not been debited from the Payer's account and have been transferred or returned to the Payer, the Payer must transfer such funds to the account specified by NEO Finance.

Data protection

20. NEO Finance does not store any Payer’s data related to personalized security features (i.e. unique identifiers, passwords or payment order confirmation (authorization) codes) in information technology systems and used servers, ensuring the security of payment transfers and Payer data. All data received is provided by the personal data subject himself.

21. All of the Payer's personalized login information (personalized security features) for electronic banking is used only for one-time session, it is encrypted during transmission and cannot be seen, reproduced and used in NEO Finance system. Each time a payment is initiated, the payer must reconfirm his identity at the PSP managing his account.

22. All data provided by the Payer in the NEO Finance system at the time of the payment shall be transmitted to the PSP institution via a secure channel which is protected by an SSL certificate.  Therefore, the Payer's e-banking login data and payment order confirmation (authorization) codes remain secure and cannot be intercepted by third parties.

23. The following data on the payment transfer are collected and stored in the NEO Finance system for the purpose of providing payment services (in particular the provision of PIS): name and surname of the payer (or the name of the legal person); personal identification number (if personal identification number transfer service is provided to the clients of the Seller (NEO Finance business customer)), payment date; the amount of the payment; the purpose of payment; payer's account number.

24. NEO Finance informs the Payer that his personal data will be processed by NEO Finance and the Payer, by initiating a payment order in the NEO Finance system with the help of PIS, agrees that NEO Finance will process and store his personal data. If the Payer does not agree that his personal data will be processed by NEO Finance, the service cannot be provided to the Payer.

25. NEO Finance processes personal data in accordance with the following provisions:

  • 25.1. ensures that the Payer's personalized security features are not accessible to parties other than the Payer itself and the issuer of the personalized security features (the relevant PSP);
  • 25.2. ensures that information on the Payer, received in connection with the Payment initiation service is provided only to the beneficiary and with the explicit consent of the service user;
  • 25.3. implements measures to prevent the use of Payment initiation services by persons seeking to obtain or control funds in a fraudulent way.
  • 25.4. does not store sensitive payment service user payment data, i.e. data, the use of which would allow fraudulent behavior and which contains personalized security features;
  • 25.5. does not request any data other than that required for the provision of the Payment initiation service;
  • 25.6. does not use the data for any purpose other than to provide the Payment initiation service, has no access to and does not store the data for purposes other than those mentioned above;
  • 25.7. implements appropriate organizational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, as well as any other unlawful processing as provided for by the legislation governing the processing of personal data;
  • 25.8. does not change the amount, beneficiary or other features of the payment transaction;
  • 25.9. The personal data subject has the right to request access to his personal data held by NEO Finance and how it is processed and to request such data to be provided to him. Data may be provided free of charge once per calendar year, but in other cases data may be subject to a charge up to the cost of providing the data.

26. The personal data subject shall have the right to demand from NEO Finance to correct all of the incorrect personal data, delete them, limit access to them or transfer them. In addition, the personal data subject has the right to object to the processing of his or her personal data and to the disclosure of it to third parties, except where necessary for the provision of the services referred to on the website. It should be noted, that the right to request immediate deletion of personal data may or may not be limited due to the statutory obligation of NEO Finance as a payment service provider to retain customer identification, payment transactions, contract concluded, etc. during a statutory period.

27. Personal data collected for the purpose of the Payment initiation service are retained for 3 years after receipt.

28. You may send a request for access, correction or disagreement with the processing of personal data to the Personal data officer of NEO Finance at the following email address: [email protected]. The application must clearly state your full name.

Final provisions

29. The law of the Republic of Lithuania shall apply to the interpretation of these Rules.

30. Payers shall have the right to lodge complaints or claims regarding payment services provided, by a general e-mail address at: [email protected]. The Payer's written complaint shall be investigated no later than within 15 working days from the day of receipt of the complaint. In exceptional cases, where for reasons beyond NEO Finance's control, it is not possible to respond within 15 business days, NEO Finance will provide an interim response. In any event, the deadline for submitting the final reply will not exceed 35 working days.

31. If the Payer considers that NEO Finance has violated its rights or lawful interests, he shall have the right to apply to the court of the Republic of Lithuania or, if the Payer is a consumer, to the institution responsible for settling consumer disputes outside of court - Bank of Lithuania (Gedimino ave. 6, LT- 01103 Vilnius; phone +370 5 268 0029; e-mail [email protected]; website, as the State Consumer rights protection authority (address Vilniaus str. 25, 01402 Vilnius; phone +370 5 262 6751; e-mail: [email protected]); e-mail [email protected]; website, the State Data Protection Inspectorate, (address A. Juozapavičiaus str. 6, 09310 Vilnius; phone +370 5 271 2804; e. email [email protected]; website

32. These Rules shall enter into force upon initiation of a payment order by the Payer using the PIS provided in the NEO Finance system. By using PIS in the NEO Finance system, the person using it acknowledges that he / she is familiar with, complies with and agrees to abide by these Rules.

33. NEO Finance reserves the right to change these Rules unilaterally at any time and such changes will become effective upon their publication. Persons are recommended to always check the latest version of these Rules.