About Swaps and this policy pack
Last updated: 2026-10-03 Version: 1.5 Status: Publication notice Effective: On publication of this edition
This information is current as of the update date and applies when published. The availability of a product depends on its launch, your eligibility and the selected route.
Supa Labs OÜ, Estonian registry code 17399414, operates Swaps from Oru tn 2, Tallinn 10127, Estonia. Legal and privacy contact: legal@swaps.app.
What the Service provides
Swaps combines software interfaces, provider integrations and blockchain tools. Access can be through the website, Dashboard v2, supported apps, API or MCP. A product described here is available only where enabled for the user, region and route; a preview or test environment does not establish live availability.
| Product | Function and relevant boundary | Terms |
|---|---|---|
| Buy, sell and swap | Compares offers and prepares or routes instructions to the selected provider or user-authorised blockchain route; provider and protocol risks vary | Terms of Service |
| Wallet | Passkey-controlled wallet access, supported transfers and conversions, with optional provider and cross-network routes that have separate controls and transit risks | Wallet |
| Payment Links | Requests payment from a payer using the bank or crypto routes available for the merchant or individual | Payment Links |
| Crypto Processing | Crypto invoices and recurring invoice scheduling; contracts pay a fixed merchant amount and send the remainder to a fee address; accidental excess follows the exception process; scheduling does not authorise wallet debits | Crypto Processing |
| Pay an Invoice | Prepares and routes eligible payer funding toward a third-party beneficiary through a provider | Pay an Invoice |
| Payroll | Prepares and routes worker or recipient payments; does not determine employment, wages, tax or withholding | Payroll |
| Accounts / bank details | Displays eligible users' provider-issued deposit instructions and related information; Supa Labs does not issue a bank deposit account | Accounts |
| Address Check | Address and transaction reports, tracing and screening with incomplete, fallible risk signals; available through supported interfaces, including Ask Swaps | Address Check |
| API, MCP and webhooks | Scoped access to resources and instructions; some public variants are read-only while authenticated tools can perform consequential operations | API |
| Referral programme | Qualifying referrals and Service credits | Referral |
Responsibilities and control
Swaps is responsible for its software and the commitments it makes. Merchants, employers, payers and recipients remain responsible for their underlying obligations. Providers are responsible for the services they undertake under their own contracts.
Our technology can create payment requests, prepare transaction data, submit authorised provider instructions and reconcile payment status. On the direct Tempo Crypto Processing route, Swaps also triggers the contract's predetermined distribution after funding. The payer's funding authorisation and this separate release transaction are different steps; release does not give Swaps the payer's wallet signing authority or the ability to change the recipients bound to that payment address.
For Bridge-powered features, Swaps is the integrating developer and user interface. The applicable Bridge entity provides the financial service under a separate user agreement. Relay supplies cross-network infrastructure through a different legal and technical arrangement; it is not Bridge and does not inherit Bridge's authorisations. Our own contract-release automation is described separately in the Crypto Processing Terms.
Control differs across user-signed wallets, provider accounts, funds held in transit and settlement contracts. Swaps receives disclosed fees, including fees distributed on-chain. Overpayments and unmatched deposits require the relevant product's exception process; receipt at a fee address does not alone determine ownership or regulatory status. The product terms describe the fund-control and execution arrangements for each route.
Regulatory and provider statements
Supa Labs OÜ does not claim authorisation as a bank, CASP, payment institution or electronic-money institution. Software design and contractual labels do not by themselves establish an exemption from regulation. Provider authorisation belongs to the named legal entity and service, not automatically to Swaps or every use of an integration.
The applicable provider terms identify the contracting entity and service; check the terms and eligibility for your route before confirming. A provider logo, integration registry or coverage list is not evidence of authorisation, solvency or transaction availability. A banking route can combine financial providers and blockchain infrastructure; that infrastructure is not itself a bank merely because it supports the route.
Where used, Preview or Beta describes a feature's development stage, not a regulatory permission or a statement that payments are simulated. The environment and route determine whether an operation is a test or a real transaction. The Terms explain the distinction.
Swaps does not provide investment, tax or legal advice. It is not an employer of record by providing Payroll, nor the seller of goods described in a merchant's invoice.
Fees and data
Revenue can include provider commissions, platform and transaction fees, conversion or cross-network fees, paid reports, credits and developer services. Applicable charges are disclosed before your instruction. Offer ranking depends on the selected sort and operational criteria; the Service is not an exhaustive or independent market comparison.
We process account, transaction, wallet, payment, recipient, compliance, communication and technical data depending on use. Providers and customers can be separate controllers; Swaps acts as processor where its actual activities are carried out on a business customer's instructions and for that customer's purposes. An applicable DPA records those duties and scope. See Privacy and Cookies.
Policy index
The Terms and product terms above are supplemented by Acceptable Use, AML Statement, Sanctions, Risk Disclosure, AI Disclosure, Limits and Enforcement and Imprint. The DPA template is for execution with business customers where the processing relationship requires it.