Swaps — What it is, what it is not

SSOT: Canonical positioning statement for marketplaces, agent-discovery surfaces (ChatGPT mini app about, MCP legal://swaps/about, agent.swaps.app /, ClawHub listing), and integrators evaluating Swaps for partnership.

Last updated: 2026-06-27 Version: 1.2 Maintainer: legal@swaps.app

What Swaps IS

• A comparison and routing layer for cryptocurrency on-ramps, off-ramps, and swaps.
• A discovery interface that surfaces rates, payment methods, and country coverage from third-party licensed providers.
• A redirector: when a user chooses an offer, Swaps hands the user off to the chosen provider's regulated checkout, with optional encrypted prefill of non-sensitive context (selected pair, amount, destination address — encrypted in transit via redirect_init).
• An information service that publishes help articles, address-report tools (Search), and educational content about crypto, providers, payment methods, and risk.
• A developer surface: agent.swaps.app and the @agent.swaps/mcp-server npm package expose read-only quote, taxonomy, and routing-explainer endpoints for AI agents and integrators.
• A Payment Links product (live): a non-custodial interface that lets a Provider-verified business Merchant create a public request for payment; the Payer pushes payment on a public page and the Provider (Bridge) creates and settles the transfer directly to the Merchant. Swaps never holds the funds. See the Payment Link Terms.
• A Wallet Service (live, Beta; non-custodial): wallet software on the Tempo network for holding, receiving, and sending supported USD stablecoins, whose signing material is held only on the user's own device, browser, or password manager. Swaps stores only public credential metadata, the wallet address, status, and audit logs, never private keys, seed phrases, passkey secrets, session keys, or other means of access. No Swaps KYC is required for wallet-only on-Tempo use. Provider verification may apply where a non-Wallet provider service is used. Direct Tempo transfers use the Tempo wallet address; supported cross-network receive/send routes may use third-party infrastructure in transit and are available only when shown in-product. There is no fiat buy/sell inside the wallet. See the Wallet Service Terms.
• A Payroll product (private beta; execution-only): an interface that routes a verified individual or business Payer's payout instructions to the Provider (Bridge), which executes the payouts. Swaps is not an employer of record and does not calculate wages, tax, or withholding. See the Payroll Terms.
• A Swaps Accounts product (staged): a holder-aware interface for reusable provider-issued Bridge Virtual Account deposit details. It may be used by an eligible individual or business; Swaps does not issue a bank account or custody funds. See the product and policy documentation under docs/accounts/.

What Swaps is NOT

• Not a counterparty. Swaps is not the seller, buyer, or exchanger in any user transaction. The chosen provider is.
• Not a custodian. Swaps never holds, receives, or transmits user funds — fiat or cryptocurrency — at any point.
• Not a custodial wallet provider. The Swaps Wallet Service is non-custodial wallet software: Swaps provides a software interface to a passkey wallet the user controls, but does not safeguard crypto-assets, hold funds, manage private keys, or control any means of access.
• Not an exchange. Swaps does not match orders, does not operate an order book, does not set the prices users pay — those are set by the providers.
• Not a payment institution, e-money institution, or VASP/CASP under the current model. Based on the non-custodial software, comparison, routing, and provider-executed model described in the Terms, Supa Labs OÜ does not itself provide regulated crypto-asset, payment, custody, settlement, or exchange services in its own name. See the Legal Notice.
• Not an investment adviser. Swaps does not give investment advice and does not recommend buying or selling any specific cryptocurrency.
• Not a tax adviser. Swaps does not calculate or report users' tax obligations.
• Not a regulator-of-providers. Swaps lists providers based on integration availability and operational signals, not on independent regulatory audit. Each provider is regulated by its own supervisory authority.

Provider relationship

Provider availability follows the generated provider taxonomy at public/agent/taxonomy.json / https://agent.swaps.app/taxonomy.json. Current public/legal wording must treat that taxonomy as the source of truth for active availability, while provider licensing remains the provider's own claim.

The presence of a provider on Swaps does not constitute endorsement of that provider's regulatory standing, security practices, or business conduct. Users are encouraged to read the provider's own terms before transacting. Sandbox/pending or historical names must not be represented as live checkout availability.

Revenue model

Swaps earns revenue from:

1. Provider referral commissions disclosed by each provider's affiliate programme. Commission economics do not influence the order in which offers are sorted — sort order is governed by an internal Smart Routing Engine score combining price (60%), coverage (15%), reliability (15%), and speed (10%).
2. Search Address Report — paid informational reports about blockchain addresses (see the Search Address Report Terms).
3. Future: B2B integrations, developer API tiers — not in scope at this version.

Swaps does not earn from spreads, hidden fees, or markups on provider quotes. The quote shown is the provider's quote.

Data we hold

• Account data (email, optional profile): held in EU (Supabase, Frankfurt).
• Transaction metadata (which provider was chosen, when, for which pair — not amounts of user funds, which we don't touch): held in EU.
• Search queries and reports (blockchain addresses scanned): held in EU, encrypted at rest.
• PII for provider handoff (destination address, amount, selected pair): encrypted in transit via AES-GCM (redirect_init), never logged in URLs.

Full data-handling details in the Privacy Policy.

Geographic scope

Swaps is accessible globally except in sanctioned or restricted jurisdictions (see the Sanctions policy). Provider coverage varies by country and is disclosed at quote time. Some providers do not serve some countries; Swaps surfaces this, it does not override it.

Age requirement

Swaps is intended for users 18 years of age or older. The providers Swaps integrates with verify user identity (KYC) including age. Swaps itself does not collect government-issued ID.

How to verify Swaps

• Estonian Business Registry — search "Supa Labs OÜ" or registry code 17399414 at https://ariregister.rik.ee/ — independent verification of company existence and management board.
• GitHub — engineering activity is visible at github.com/swapsapp (public repositories, releases, issue tracker).
• npm — @agent.swaps/mcp-server is published and verifiable on npm.
• OpenSanctions — Swaps performs sanctions screening using OpenSanctions data; the dataset and methodology are themselves auditable at opensanctions.org.
• Persona — providers (not Swaps) use Persona for identity verification; Persona's coverage is public.

How to talk to Swaps

We do not maintain a public phone line. All inquiries are handled by email or in-product support, with a 30-day SLA for legal and privacy matters.