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Security report for trustly.one

Trustly, Inc. · Finance · United States

Medium risk. 2 critical or high findings in GDPR outside view.

Security score

66/100

Risk levelMedium

0–100, higher is better. How it is calculated

Trustly, Inc. is a leading Pay by Bank payment service provider leveraging a proprietary Open Banking technology stack to deliver guaranteed payments, risk management, and consumer insights. The company targets businesses across financial services, gaming, retail, and subscription sectors, offering a global network with over 110 million consumers in 30+ countries. Their business model focuses on enabling faster, more secure, and cost-effective bank payments compared to traditional card payments. The website reflects a mature digital presence with excellent content quality and professional branding, supported by modern marketing and analytics tools such as HubSpot, Google Tag Manager, and Weglot for multilingual support. Technically, the site is built on Webflow CMS and hosted on Amazon AWS, utilizing various JavaScript libraries and integrations. However, the site suffers from slow load times and lacks a valid SSL certificate, resulting in a critical security deficiency. Accessibility and mobile optimization are good, and SEO practices are well implemented. The absence of HTTPS and security headers significantly impacts the site's security posture, exposing users to potential risks. From a security perspective, the lack of HTTPS and essential security headers, combined with no evidence of incident response or vulnerability disclosure policies, indicates a need for urgent improvements. Privacy and cookie policies are present and comprehensive, supporting GDPR compliance. The WHOIS data shows the domain is privacy-protected but consistent with the company's US presence and age, supporting legitimacy. Overall, while Trustly's business and website demonstrate strong market positioning and professional quality, the critical absence of SSL/TLS encryption and security best practices poses a significant risk. Immediate remediation of these issues is recommended to enhance user trust and secure sensitive transactions.

Scanned

NIS2 and GDPR posture

GDPR outside view
43/ 100 · High
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

2 findings rated critical or high. Fix these first.

  1. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • High

      No Cookie Policy found

      GDPR requires clear information about cookie usage

      What to do: Add a dedicated cookie policy explaining cookie usage and purposes

    • High

      No Cookie Consent Banner found

      GDPR requires explicit consent for non-essential cookies

      What to do: Implement a cookie consent banner that appears on first visit

Need hands-on remediation? Email guard@offseq.com

Keep watching trustly.one

This scan found 14 issues across 6 checks. Monitoring re-runs those checks daily, emails you when something material changes and records each fix, so you can show progress.

Daily monitoring

Recommended

€25per month

  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
50
Security headers
65
Email security
50
DNS health
85
Network security
100
GDPR outside view
43
Average
66

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

Trustly holds a strong market position as a global Pay by Bank provider with a proprietary Open Banking stack, serving major industries such as financial services, gaming, retail, and subscription billing. Their competitive advantage lies in their extensive network of 12,000 banks worldwide and deep consumer insights derived from years of transaction data. The business model is B2B focused, providing payment initiation, payouts, identity verification, and data analytics services. Revenue streams likely include transaction fees and data services. The company targets medium to large enterprises seeking to optimize payment processes and reduce costs. Partnerships with major brands like Coinbase, T-Mobile, and Western Union enhance their ecosystem. Growth indicators include a large consumer base and significant payment volume ($500B+). The website content and structure support a clear, professional brand image aligned with their strategic goals.

Security posture

The current security maturity level of the website is low due to the absence of a valid SSL certificate and HTTPS support, which is a critical vulnerability for any financial service provider. No security headers such as HSTS, Content-Security-Policy, or X-Frame-Options are implemented, increasing exposure to common web attacks. There is no visible incident response or vulnerability disclosure information, which limits transparency and preparedness. Privacy policies are comprehensive and indicate GDPR compliance, but the lack of secure transport undermines data protection efforts. No exposed sensitive data or vulnerable libraries were detected in the analysis, but the missing HTTPS significantly impacts the overall security posture. The site uses secure forms but without HTTPS, data in transit is at risk. Overall, the security culture appears underdeveloped on the public-facing site, requiring urgent attention to meet industry standards.

Recommendations

  1. Obtain and deploy a valid SSL/TLS certificate to enable HTTPS across the entire site.
  2. Implement essential security headers including HSTS with preload, Content-Security-Policy, X-Frame-Options, and X-Content-Type-Options.
  3. Enable modern TLS protocols (TLS 1.2 and TLS 1.3) and disable outdated protocols.
  4. Establish and publish a vulnerability disclosure policy and incident response contact information.
  5. Optimize site performance to reduce load times and improve user experience.
  6. Enhance transparency by providing explicit security and data protection policies.
  7. Maintain consistent branding and trust signals across all site sections.
  8. Regularly audit third-party scripts and dependencies for vulnerabilities.
  9. Implement comprehensive accessibility features to improve inclusivity.
  10. Develop a long-term security strategy including continuous monitoring and compliance updates.

Contact details published on the site

Legal name
Trustly, Inc.
Registration number
NMLS #2463855
Technical notes

Notes

The website is built using Webflow CMS and hosted on Amazon AWS infrastructure, leveraging JavaScript libraries such as jQuery and integrations with HubSpot for marketing and analytics. The site includes multilingual support via Weglot and uses Google Tag Manager and Qualified for user tracking and analytics. Despite a modern tech stack, the site suffers from slow load times (18.2 seconds) and a large page size (~1.19 MB), indicating potential optimization opportunities. The absence of a valid SSL certificate and disabled TLS protocols are critical technical risks. The site is mobile-optimized and accessible, with good SEO practices including meta tags and Open Graph data. The technical debt is moderate, with clear paths for modernization by addressing security and performance issues. Overall, the infrastructure supports a scalable and global payment platform but requires immediate security enhancements.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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