Complaints Procedure
Last updated 26 October 2026
Version 4.1 | Last updated 26 October 2026
1. About this procedure
1.1 This procedure explains how to complain to Earnly Limited (company number 16183799), registered office 41 New Cross Street, Swinton, Manchester, England, M27 4TU ("Earnly", "we", "us", "our"), what we will do and by when, and where you can go if you are not happy with our answer.
1.2 This procedure forms part of your Agreement with us, as set out in the "Documents forming part of the Agreement and order of precedence" clause of our Terms and Conditions. The timescales in it are commitments we make to you. Where a law or regulation gives you a better right or a shorter timescale, that right or timescale applies.
1.3 If this procedure conflicts with another part of the Agreement, the order of precedence in the "Documents forming part of the Agreement and order of precedence" clause of the Terms and Conditions applies. In summary, the Privacy Policy prevails on how we handle personal data, the Open Banking Consent Notice prevails on consent to the account information service and the use of Open Banking Data, and on how we handle complaints this procedure prevails over the Terms and Conditions and the other documents forming part of the Agreement.
1.4 Complaining is free. We will never charge you for making or pursuing a complaint, and we will not treat you less favourably because you have complained.
2. Who this applies to
2.1 This procedure applies to everyone who uses the Earnly website and web application (the "Platform"), and to anyone who has applied for an Account or whose Account has been suspended or closed. If we release mobile apps, this procedure applies to them too. In particular it applies to you if you are:
2.1.1 a Consumer: an individual using the Platform wholly or mainly outside your trade, business, craft or profession;
2.1.2 a Business User: anyone using the Platform for a trade, business or profession, including a sole trader, contractor, freelancer, partnership, LLP, limited company or other organisation, and any individual (for example a director) acting on its behalf;
2.1.3 an Organisation: a company, LLP, partnership or other entity that is a Business User; or
2.1.4 an Individual acting for an Organisation. An "Individual" is any natural person who uses the Platform, whether as a Consumer, a sole trader or for an Organisation. Every Individual can complain about how we use their own personal data, even when acting for an Organisation.
2.2 We handle every complaint to the same standard. Whether you are a Consumer, a sole trader or an Organisation affects only where you can go next if you are not satisfied, which section 9 explains. Where something applies to only one group, we say so.
2.3 If someone's personal data appears in your bank transactions (for example as a payee) and they want to complain about how we use it, they can use this procedure too. They do not need an Account.
2.4 In this procedure, a "Business Day" is Monday to Friday, excluding bank holidays in England and Wales.
3. Who we are
3.1 Earnly Limited (FRN 1058277) is registered on the Financial Services Register as an agent of Finexer Ltd, which is authorised and regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Reference Number 925695) for the provision of account information services. You can check this on the Financial Services Register at register.fca.org.uk. Earnly is not itself authorised by the Financial Conduct Authority. Earnly does not provide payment initiation services, cannot initiate payments or move money, and never receives, sees or stores your online banking credentials.
3.2 Finexer Ltd (company number 12191948, registered office 124 City Road, London, EC1V 2NX) is the "Provider" of the account information service that lets the Platform read your Connected Accounts. This matters when you complain, because it affects who is responsible for your complaint, how quickly you must receive an answer, and where you can go next. Section 5 explains this.
4. How to complain
4.1 You can complain in any of these ways:
4.1.1 by email to complaints@earnly.co.uk;
4.1.2 using our online complaint form at https://earnly.co.uk/complaints, which you can use without signing in;
4.1.3 in the app, by going to Settings → Help and choosing to make a complaint, which opens the same form with your Account details filled in; or
4.1.4 by post to Earnly Limited, 41 New Cross Street, Swinton, Manchester, England, M27 4TU.
4.2 If your complaint is about how we use your personal data, you can also email privacy@earnly.co.uk. If you send a complaint to support@earnly.co.uk, or raise it with us in any other way, we will pass it to our complaints team and treat it as received on the day it first reached us.
4.3 We do not have a telephone line. If you cannot use any of the channels above, or you need to complain in another way because of a disability or your circumstances, email us or write to us (or ask someone to do so for you) and we will arrange a telephone call or another way for you to complain. Section 10 explains the support we can offer.
4.4 You do not need to use the form, a particular channel or the word "complaint". If you tell us you are unhappy, we will treat it as a complaint, even if you are not sure it is one.
4.5 Never send us your online banking username, password, PIN or any other banking credentials. We will never ask for them and we do not need them.
4.6 We treat a complaint as received on the day it reaches us through any of the channels above. Our hours are Monday to Friday, 9:00 to 17:30 UK time, excluding bank holidays in England and Wales. If your complaint reaches us after 17:30 on a Business Day, or on a day that is not a Business Day, we treat it as received on the next Business Day.
What the online complaint form asks for
4.7 The online complaint form asks for:
4.7.1 your name and the email address on your Account (or, if you do not have an Account, the email address we should reply to);
4.7.2 whether you are complaining for yourself or for someone else, and if for someone else, their name and your relationship to them;
4.7.3 whether you are a Consumer, a sole trader, complaining for an Organisation (with the Organisation's name), or not an Earnly user;
4.7.4 what your complaint is about: Open Banking and your bank connections, the Platform and our service, how we use your personal data, or "not sure";
4.7.5 what happened and when;
4.7.6 how it has affected you;
4.7.7 what you would like us to do to put things right;
4.7.8 any supporting files, such as screenshots or copies of emails (optional);
4.7.9 any support or adjustments you need, and the format you would like our replies in (optional); and
4.7.10 whether you are happy for us to reply by email, or would prefer post.
4.8 Only your name, a contact email or postal address and a description of your complaint are required. When you submit the form you will see your complaint reference on screen, and we will email you a copy of what you sent. The form is also our electronic complaint form for data protection complaints under section 164A of the Data Protection Act 2018.
4.9 If you complain by email, by post or in another way, it helps us if you include the same information, but we will still deal with your complaint if you do not.
Complaining for someone else
4.10 Someone else can complain for you, such as a family member, carer, friend, accountant, adviser, lawyer or someone holding a power of attorney. Before we discuss your Account with them we will ask for reasonable evidence that they have your authority, such as an email from you sent from your registered email address. While we check, we will still log and investigate the complaint and keep you informed directly.
4.11 If you are an Organisation, any director, partner, member or other person authorised to act for the Organisation can complain on its behalf. If we are not sure someone has authority, we will deal with the person who holds the Account until the position is clear.
5. The three types of complaint
5.1 We sort every complaint into one or more of three types, because each has its own deadlines and its own route if you are not satisfied:
| Type | What it covers | Who is responsible | Final answer within |
|---|---|---|---|
| Open Banking | Connecting or disconnecting a bank account, your consent and reconfirming it, the bank data we receive, and the conduct of Finexer or your bank in providing that data | Finexer Ltd, as the Provider, with Earnly as its agent | 15 Business Days (up to 35 Business Days in exceptional circumstances) |
| Product and service | The Platform, our categorisations, tax estimates, forecasts and other Outputs, any fees or plans, account decisions and our customer service | Earnly | 8 weeks (we aim for 20 Business Days) |
| Data protection | How we collect, use, share, keep or protect your personal data, including how we handled a request to access, correct or delete it | Earnly | Without undue delay, normally 1 month and no later than 3 months |
5.2 If your complaint covers more than one type, we will deal with each part on its own timescale and make clear which part each answer covers. If we are not sure whether something is an Open Banking complaint, we will treat it as one, because that gives you the shortest deadline.
6. What happens and when
For every complaint
6.1 We will acknowledge your complaint in writing within 2 Business Days of receiving it. We will give you a reference number, tell you which type of complaint it is, who is handling it, and the date by which you will get the final response.
6.2 Every complaint is handled by a person. We do not use automated systems or AI to decide complaints.
6.3 We will investigate fairly. Your complaint will be investigated by someone who was not involved in the matter you are complaining about. Because Earnly is a small company with a sole director, if your complaint is about a decision our director made, it will be reviewed by an external adviser we appoint for that purpose.
6.4 If we need more information we will ask you. Please reply as soon as you can, because we may not be able to reach a fair answer without it.
6.5 If your complaint is still open after 10 Business Days, we will update you at least every 10 Business Days, and you can ask for an update at any time by quoting your reference.
6.6 If we resolve your complaint to your satisfaction by the close of the third Business Day after we receive it, we will confirm this in writing and tell you how to reopen it. For an Open Banking complaint, this written confirmation will also tell you about the Financial Ombudsman Service, and the six months you have to refer the complaint to it start from the date of that confirmation.
Open Banking complaints
6.7 Finexer Ltd is responsible for the account information service, so we will pass the Open Banking part of your complaint to Finexer within 1 Business Day of receiving it, or of realising it is an Open Banking complaint. We will tell you in writing that we have done this and what happens next. Passing it on does not close your complaint: we stay involved until you have a final response.
6.8 Complaints relating to Open Banking services will be referred to Finexer Ltd, which is responsible for handling these complaints and issuing the final response. We will give Finexer any information and help it needs, and we will keep you updated until you receive Finexer's final response.
6.9 You will receive a final response by the end of 15 Business Days after the day we received your complaint. In exceptional circumstances outside our and Finexer's control, you will instead receive a holding reply by then, explaining the reasons for the delay and the date by which you will receive the final response, which will be no later than the end of 35 Business Days after the day we received it. These timescales run from the day Earnly received your complaint, not the day it was passed to Finexer.
6.10 You can also complain to Finexer directly at complaints@finexer.com. If your complaint is about how Finexer itself uses your personal data, you can contact Finexer at privacy@finexer.com. Finexer's End User Terms (https://finexer.com/legal/end-user-terms) and Privacy Notice (https://finexer.com/legal/privacy) explain how it handles complaints and data.
Product and service complaints
6.11 We will send you a final response as soon as we reasonably can, and in any event within 8 weeks of receiving your complaint. We aim to do so within 20 Business Days.
6.12 If, exceptionally, we cannot send our final response within 8 weeks, we will write to you before the 8 weeks end to explain why and to give the date of our final response. This does not extend the 8-week commitment in clause 6.11, and you may take the steps in section 9.2 without waiting for our final response.
Data protection complaints
6.13 We will acknowledge your complaint within 2 Business Days (the law requires us to do so within 30 days at the latest). We will look into it without undue delay, make the enquiries needed, keep you informed, and send you an outcome letter. We aim to send it within 1 month and, if the complaint is complex, no later than 3 months. If it will take longer than 1 month we will tell you why and when to expect it.
6.14 A request to access, correct or delete your data is handled under our Privacy Policy, normally within 1 month. You can make a request by emailing privacy@earnly.co.uk or using the form at https://earnly.co.uk/privacy-request. If you are unhappy with how we handled that request, that is a data protection complaint.
7. The final response
7.1 The final response, or outcome letter for a data protection complaint, will be in writing (by email to your registered email address unless you ask for post or another format) and will tell you:
7.1.1 your reference number;
7.1.2 how we understood your complaint and what we looked at;
7.1.3 whether we uphold it in full, in part, or not at all, and why, in plain English;
7.1.4 what we will do to put things right, and when;
7.1.5 that it is the final response; and
7.1.6 where you can go next if you are not satisfied.
7.2 The final response is Earnly's final position. We do not have a further internal review or appeal stage. If you think we have misunderstood your complaint or missed something important, tell us and we will check whether the final response needs correcting, but this does not delay or replace the routes in section 9, which you can use straight away.
8. Putting things right
8.1 If we got something wrong, we will aim to put you back in the position you would have been in if it had not happened. Depending on what went wrong, that may include an apology, correcting your data or an estimate, changing how something works, a refund or credit of any fees, payment for financial loss we caused, and a payment for distress and inconvenience. We will pay any agreed amount within 14 days of you accepting it.
8.2 Accepting an offer is your choice. We will never make an offer conditional on you not going to the Financial Ombudsman Service, the Information Commission (ICO) or a court, or ask you to keep quiet about your complaint to any of them. If accepting an offer would affect your right to go to the Financial Ombudsman Service, we will tell you clearly before you decide, and give you at least 14 days to decide.
9. If you are still not satisfied
9.1 Open Banking complaints: the Financial Ombudsman Service
9.1.1 If you are not satisfied with the final response to an Open Banking complaint, or you have not received it within 15 Business Days (or 35 Business Days where you received a holding reply), you may be able to refer your complaint to the Financial Ombudsman Service. It is free and independent, and it will decide whether it can look at your complaint.
9.1.2 Time limits. You must normally refer your complaint to the Financial Ombudsman Service within six months of the date of the final response. It also normally cannot consider a complaint made more than six years after the event you are complaining about or, if later, more than three years after you became aware (or ought reasonably to have become aware) that you had cause to complain. If you miss these limits, the Financial Ombudsman Service may not be able to consider your complaint. The final response will tell you whether Finexer consents to the Financial Ombudsman Service considering a complaint referred outside the six-month limit.
9.1.3 Who can use the Financial Ombudsman Service. You can use it if you are:
(a) a Consumer;
(b) a micro-enterprise: a business with fewer than 10 employees and an annual turnover or annual balance sheet total of €2 million or less. Most sole traders, freelancers and contractors fall into this group;
(c) a small business: a business with fewer than 50 employees and either an annual turnover below £6.5 million or an annual balance sheet total below £5 million;
(d) a charity with annual income below £6.5 million; or
(e) a trustee of a trust with net assets below £5 million.
The Financial Ombudsman Service decides whether you are eligible.
9.1.4 Financial Ombudsman Service contact details:
Website: financial-ombudsman.org.uk
Email: complaint.info@financial-ombudsman.org.uk
Telephone: 0800 023 4567
Post: Financial Ombudsman Service, Exchange Tower, London E14 9SR
9.1.5 The final response will include, or link to, the Financial Ombudsman Service's explanatory leaflet. Using the Financial Ombudsman Service does not affect your right to go to court.
9.2 Product and service complaints
9.2.1 There is no ombudsman for complaints about Earnly's own Platform and service, because those services are not regulated financial services.
9.2.2 Earnly does not use an alternative dispute resolution (ADR) scheme. If you are not satisfied with our final response to a product and service complaint, you can take the matter to court.
9.2.3 If you are a Consumer, you keep all your statutory rights, including your rights under the Consumer Rights Act 2015, and you can bring a claim in the courts of England and Wales or of the part of the UK where you live, as set out in the "Governing law and jurisdiction" clause of the Terms and Conditions. Citizens Advice (citizensadvice.org.uk) can give you free, independent advice.
9.2.4 If you are a Business User, you can bring a claim in the courts of England and Wales, as set out in the "Governing law and jurisdiction" clause of the Terms and Conditions.
9.2.5 If a product and service complaint turns out to be caused by your bank data as supplied through Finexer, that part becomes an Open Banking complaint and section 9.1 applies to it.
9.3 Data protection complaints: the Information Commission (ICO)
9.3.1 If you are not satisfied with our outcome letter, or we have not dealt with your complaint, you can complain to the Information Commission (ICO), the UK data protection regulator:
Website: ico.org.uk
Telephone: 0303 123 1113
9.3.2 The Information Commission (ICO) normally expects you to complain to us first. You also have the right to go to court about how your personal data is used.
10. If you need extra support
10.1 Complaining can be hard, and some people need more support than others, for example because of health, a disability, a bereavement, money worries or other difficult circumstances. Tell us what would help and we will make reasonable adjustments, such as:
10.1.1 giving you longer to reply;
10.1.2 sending our letters and this procedure in large print, as an accessible PDF or as a plain-text email;
10.1.3 arranging a telephone call with you at a time that suits you;
10.1.4 dealing with someone you have authorised; and
10.1.5 dealing with your complaint as a priority if delay would make things worse.
10.2 You do not have to tell us anything you would rather not share. We will record only what we need to help you, with your agreement, and we will never use it for marketing.
11. Your complaint records
11.1 We keep a record of every complaint, including what you told us, what we did and what we decided, for 6 years from the date the complaint is closed, or longer if a legal claim or an ombudsman's or regulator's enquiry is still ongoing. Our Privacy Policy and Data Retention Policy explain how we use and protect this information and your rights over it.
11.2 For Open Banking complaints, we share your complaint and the relevant Account and consent records with Finexer Ltd, because it is responsible for the service.
12. Changes to this procedure
12.1 We may change this procedure to reflect changes in law, regulation, guidance or our processes. We will give you at least 30 days' notice of any change that reduces your rights or lengthens our timescales, in line with the "Changes to the Agreement" clause of the Terms and Conditions. Any complaint already made will be handled under the version in force when we received it, unless a later version is better for you.
13. Contact
13.1 Complaints: complaints@earnly.co.uk, the online complaint form at https://earnly.co.uk/complaints, or in the app at Settings → Help.
13.2 Data protection complaints: privacy@earnly.co.uk, or any of the channels in clause 13.1.
13.3 Post: Earnly Limited, 41 New Cross Street, Swinton, Manchester, England, M27 4TU.