Terms of Service

Last updated: 2026-06-27 Version: 2.3 Effective: Upon publication on www.swaps.app.

These Terms of Service ("Terms") govern your use of Swaps.app, the Swaps mobile applications, the Swaps Telegram mini app, the Swaps ChatGPT mini app, agent.swaps.app, the @agent.swaps/mcp-server package, and any other surface where Swaps is offered (collectively, the "Service"), provided by Supa Labs OÜ, an Estonian private limited company with registry code 17399414 and registered office at Oru tn 2, Tallinn 10127, Estonia ("Swaps", "we", "us", "our").

By using the Service, you agree to these Terms. If you do not agree, do not use the Service.

1. What the Service is — and is not

1.1 — Service description. The Service is a comparison and routing layer for cryptocurrency on-ramp, off-ramp, and swap offerings provided by independent third-party providers ("Providers"). The Service compares Provider quotes, coverage, and payment methods, and, when you choose an offer, redirects you to the chosen Provider's regulated checkout.

1.2 — No counterparty status. We are not the seller, the buyer, the exchanger, or any other counterparty to any transaction you initiate through the Service. The Provider you choose is your counterparty. The Provider's own terms — not ours — govern your transaction with that Provider. We are not a party to that contract.

1.3 — No custody; non-custodial Wallet Service. We never receive, hold, transmit, or take custody of any cryptocurrency or fiat currency through the Service. Swaps Wallet is non-custodial wallet software that lets you operate a self-controlled Tempo wallet. Swaps does not safeguard crypto-assets, private keys, seed phrases, passkey secrets, session keys, or other means of access. Swaps may display balances, prepare transaction data, submit user-authorized signed transactions, and show status, but cannot unilaterally move, freeze, recover, or settle Wallet funds.

1.4 — Compliance basis. Based on the current non-custodial software, comparison, routing, and provider-executed model described in these Terms, Supa Labs OÜ does not itself provide regulated crypto-asset, payment, custody, settlement, or exchange services in its own name. Where regulated services are used, they are provided by independent Providers under their own terms, authorisations, compliance programmes, eligibility rules, and availability limits. If Swaps changes its role to hold funds, safeguard or control means of access, operate payment accounts or e-money balances, or execute transfers or exchanges in its own name, that activity must be separately reviewed before launch.

1.5 — No advice. The Service does not provide investment advice, financial advice, tax advice, or legal advice. Information shown on the Service is informational only. You are solely responsible for evaluating whether any transaction is suitable for you and for complying with the tax laws of your jurisdiction.

1.6 — Subproducts within the Service. The Service includes the following subproducts, each subject to these Terms plus the linked supplemental terms:

  • Quote & Redirect (core comparison flow): governed by these Terms.
  • Search Address Report: governed by these Terms plus the Search Address Report Terms.
  • Swaps Search via ChatGPT App / MCP connector: governed by these Terms plus the Search Address Report Terms and the Developer / API / MCP Terms. V1 is read-only. The public ChatGPT Apps Directory candidate is Search-only: address checks, transaction explanations, fund tracing, taxonomy, and corridor-support information. It does not provide crypto purchase quotes, checkout links, trades, transfers, payments, or provider sessions inside ChatGPT. Private Developer Mode and other MCP surfaces may expose route-quote retrieval for testing or agent use; any checkout link points only to a Swaps-owned domain and the actual checkout happens externally there under these Terms and the relevant Provider's terms. There is no OAuth in V1; authenticated workspace, report, or credits flows return auth_required and are not executed inside ChatGPT. Tool responses may include request IDs for support and debugging.
  • Swaps Search inside the Swaps iOS app: same intelligence and tooling as the ChatGPT App / MCP path, exposed natively within the iOS app. Legal coverage of Swaps Search across web, iOS, ChatGPT, and MCP surfaces is identical; the disclosures in the Search Address Report Terms, the AI Disclosure, and these Terms apply to all four channels.
  • Friend Rate Referral: governed by these Terms plus the Friend Rate Programme Terms.
  • Developer API / agent.swaps.app / MCP package: governed by these Terms plus the Developer / API / MCP Terms.
  • AI Concierge / AI-generated content: governed by these Terms plus the AI Disclosure.
  • Payment Links: governed by these Terms plus the Payment Link Terms. Non-custodial; the regulated Provider (Bridge) settles directly to the merchant; Swaps is never a fund destination and earns up to a 1% Provider developer fee.
  • Wallet Service: governed by these Terms plus the Wallet Service Terms. A live (Beta), non-custodial passkey wallet on the Tempo network for holding, receiving, and sending supported USD stablecoins. Swaps never holds your signing material and is not a counterparty, custodian, or exchanger in respect of the Wallet. (Separately, the historical Tempo Passkey Wallet Lab — a testnet-only, allowlisted experiment — is governed by §24 below.)
  • Payroll: governed by these Terms plus the Payroll Terms. Execution-only payouts for verified individual or business customers via the Provider (Bridge); Swaps is not an employer of record and does not custody payroll funds.
  • Swaps Accounts (staged): reusable provider-issued virtual-account deposit details for eligible individual or business holders, governed by these Terms and the Accounts product policy. Bridge remains the provider-side source of truth for verification, fiat processing, settlement, and availability; Swaps does not issue a bank account or custody funds.
  • Tempo Passkey Wallet Lab (hidden, testnet-only, allowlisted): governed by these Terms plus §24 below. Not a public wallet launch and not a Provider-equivalent custody service. Restricted to allowlisted testers via Supabase authentication, served only on tempo.swaps.app, only on the Tempo Moderato testnet.

In the event of a conflict between these Terms and a supplemental document, the supplemental document controls for the subproduct it covers.

2. Definitions

  • "Provider" — a third-party regulated business that offers crypto purchase, sale, swap, payments, or other services, and is listed on the Service. Current Providers are listed in About Swaps.
  • "Offer" — a quote, rate, payment-method availability, or service combination presented by the Service based on data sourced from one or more Providers.
  • "User", "you" — any natural person or legal entity who accesses or uses the Service.
  • "Account" — your registered profile on the Service, if any. An Account is optional for most Service features.
  • "Content" — any information, text, data, code, or other material made available through the Service.
  • "Credits" — non-cash, non-transferable, internal Service units used for paid Service features such as Search Address Report packs.
  • "PII" — personally identifiable information as defined under applicable data-protection law.

3. Eligibility

3.1 — Age. You must be at least 18 years old to use the Service. If you are under 18, you must not access or use the Service.

3.2 — Legal capacity. You must have the legal capacity to enter into contracts under the laws of your jurisdiction. If you use the Service on behalf of an entity, you represent that you are authorised to bind that entity to these Terms.

3.3 — Restricted jurisdictions. You must not use the Service if you are located in, ordinarily resident in, a national of, or subject to comprehensive sanctions of, any of the jurisdictions listed in the Sanctions policy. The Service is geographically restricted at the network layer in those jurisdictions; attempts to circumvent the geo-block (via VPN, proxy, or otherwise) violate these Terms.

3.4 — Sanctioned persons. You must not use the Service if you are listed on, or owned or controlled by a person listed on, any sanctions list maintained by the United Nations, the European Union, the United Kingdom Treasury (OFSI), the United States Department of the Treasury (OFAC), or other applicable authority. Swaps enforces this at the perimeter through network-layer geo-blocking of comprehensively sanctioned jurisdictions and through country-level provider-routing controls; the licensed Providers we route to perform their own sanctions screening of natural and legal persons at KYC time. If you appear on a sanctions list, your access will be blocked (whether by Swaps perimeter controls or by the Provider's KYC programme) and any data we hold will be retained for the period required by law. See the Sanctions policy for details.

3.5 — One Account per person. Each natural person may maintain one Account. Multiple Accounts created to circumvent referral, search-credit, or rate-limit controls violate these Terms and may be terminated without refund.

4. Provider relationship — what we do and do not promise

4.1 — Provider selection. When you click through to a Provider, you transact directly with that Provider under the Provider's own terms of service, privacy policy, AML/KYC programme, refund and dispute policy, and operational practices. We have no role in those terms or that contract.

4.2 — Provider regulatory status. Each Provider is regulated by its own supervisory authority. The Service surfaces Providers based on their availability and operational signals, not on independent regulatory audit. We do not warrant a Provider's licence status, solvency, security practices, or compliance with any law.

4.3 — Rate accuracy. Quotes displayed on the Service are estimates based on Provider data refreshed approximately every 30 seconds. The binding quote — the price at which you actually transact — is the quote the Provider returns at checkout, not the quote previewed on the Service. Quotes may change between preview and checkout due to market movement, payment-method differences, KYC/identity factors specific to you, or other Provider-side conditions.

4.4 — Coverage accuracy. Country, payment-method, and asset coverage shown on the Service reflects Provider data and integration status at the time of display. Coverage can change without notice. A Provider's appearance for your country/method combination does not guarantee successful completion of your transaction.

4.5 — Routing transparency. Offers are sorted by an internal Smart Routing Engine score combining price (60%), coverage (15%), reliability (15%), and speed (10%). Provider commission economics do not influence sort order. You may see different offers at different times depending on Provider status; we do not manipulate which Provider you see based on revenue per click.

4.6 — Provider failures. If a Provider fails to honour a quote, fails KYC, fails to deliver funds, freezes your transaction, charges fees other than those displayed, holds your funds, or otherwise fails to perform, your remedy is against the Provider, not against Swaps. We will, where reasonable and lawful, share with you the information we have about your interaction with the Service to assist you in pursuing the Provider — see Limits & Enforcement §4.

5. Quotes, redirects, and your transaction

5.1 — Preview vs binding. A quote shown on the Service is a preview. It becomes binding only when the Provider confirms it at its checkout. If the Provider's binding quote differs from the preview by more than 50 basis points (0.5%), the Service shows you a reconfirmation modal before you proceed. Silent substitution of Provider or price is prohibited by our internal architecture.

5.2 — Encrypted handoff. When you choose an offer, the Service transmits to the chosen Provider only the information needed to initiate the transaction (pair, amount, destination address, and where required, an email reference). Sensitive fields are encrypted in transit via AES-GCM tokens generated by redirect_init and never appear in URLs in plaintext.

5.3 — Cooling-off and right of withdrawal. Cryptocurrency purchases, sales, and swaps fall within the EU consumer-protection exception for goods whose price depends on financial-market fluctuations beyond the trader's control (Directive 2011/83/EU, Article 16(b)). Once the Provider has executed your transaction, you do not have a right of withdrawal. Where the Provider has not yet executed, refund and cancellation are subject to the Provider's policy, not ours.

5.4 — Failed transactions. If your transaction fails (wrong network, expired quote, KYC denial, provider outage), Swaps does not refund — because Swaps did not receive payment. Refunds, where due, come from the Provider that received your payment. Our Limits & Enforcement §4 explains how we will assist you in reaching the Provider.

6. Search Address Report

6.1 — What it is. The Search Address Report is a paid informational product. For a one-time fee (typically €1 or local equivalent for a full report, or via Credit packs of 5/10/20 reports), the Service generates an informational report about a blockchain address — risk signals, exposure indicators, on-chain context — using public on-chain data and third-party risk feeds.

6.2 — Not legal evidence. Reports are informational, not legal evidence. They are not admissible as expert opinion in court without separate qualification. They are not certifications of fraud, theft, or any legal conclusion. They are not investment advice. They are not law-enforcement reports.

6.3 — Refund window. If a Report returns empty data (zero risk signals and zero on-chain context), you may request a Credit refund within 24 hours by emailing legal@swaps.app. Credit refunds are non-cash — they restore the Credit balance to your Account.

6.4 — Full Search terms. See the Search Address Report Terms for full details on data sources, accuracy disclaimers, and how to dispute a Report finding.

7. Friend Rate referral programme

7.1 — What it is. Friend Rate is a loyalty programme: when a user you referred completes their first qualifying transaction, you receive 10 Credits and your friend receives 5 welcome Credits.

7.2 — Non-cash. Credits are non-cash, non-transferable, non-redeemable for cash, and have no expiry. They can only be spent on paid Service features (such as Search Address Report packs).

7.3 — Anti-fraud. Self-referral, multi-account referral, paid-traffic farming, and other fraudulent referral patterns are prohibited and may result in revocation of Credits, suspension of the Account, and ban without notice. See the Friend Rate Programme Terms.

7.4 — Programme modification. We reserve the right to modify, suspend, or terminate the Friend Rate programme at any time, provided already-earned Credits are honoured for at least 90 days after termination.

8. Fees and revenue

8.1 — Service fees to user. The core Quote & Redirect flow is free to the user. Paid Service features (Search Address Report, Credit packs) are disclosed at the point of purchase.

8.2 — Provider commissions. We earn referral commissions from some Providers when you transact with them. These commissions are disclosed at a high level here but the specific commission rate per Provider is commercially sensitive. Commissions do not influence which Provider appears for you (see §4.5).

8.3 — Currency. Service fees are denominated in EUR by default; the Service may display equivalent values in other currencies at indicative rates. Payment is processed by a payment processor (such as Stripe) — see the Privacy Policy for the data those processors receive.

9. Account

9.1 — Optional. You may use the core comparison flow without an Account. An Account is required for Credits, referral rewards, transaction history, and Search Address Reports.

9.2 — Accuracy. You must provide accurate information at Account creation and keep it current.

9.3 — Account security. You are responsible for keeping your Account credentials confidential. We use industry-standard authentication (Supabase Auth and OAuth providers). Account passkeys, where available, are only a way to sign in to your Swaps Account faster. They do not create a wallet, authorize Tempo wallet transactions, give Swaps custody of funds, or give Swaps your private keys. Your device, browser, or password manager controls the local passkey authenticator, and magic link remains available as a fallback. We will never ask you for your password or wallet seed phrase. Anyone claiming to be Swaps support and asking for your seed phrase is impersonating us.

9.4 — Account deletion. You may delete your Account at any time by emailing legal@swaps.app. We will delete your personal data within 30 days, subject to data we are required by law to retain.

10. Acceptable use

10.1 — Permitted use. You may use the Service for personal, non-commercial purposes consistent with these Terms and applicable law, and for commercial purposes consistent with the the Developer / API / MCP Terms where applicable.

10.2 — Prohibited use. You must not, and must not assist others to:

  • Use the Service for money laundering, terrorist financing, sanctions evasion, fraud, tax evasion, or any other unlawful purpose.
  • Use the Service from a restricted jurisdiction (see the Sanctions policy) or while on a sanctions list (see §3.4).
  • Create or attempt to create multiple Accounts to circumvent rate limits, referral controls, or Search credit caps.
  • Reverse-engineer, decompile, disassemble, scrape beyond published rate limits, abuse the API, or attempt to extract data not made available to you.
  • Interfere with the operation of the Service, including by overwhelming infrastructure, exploiting vulnerabilities, or distributing malware.
  • Impersonate Swaps, any Provider, any other user, or any other person.
  • Use the Service to defame, harass, threaten, or harm others.
  • Use the Service in any way prohibited by applicable law.

10.3 — Full AUP. See the Acceptable Use Policy for the detailed Acceptable Use Policy, including thresholds and enforcement.

11. Intellectual property

11.1 — Service. The Service (software, design, brand, content authored by Swaps) is owned by Supa Labs OÜ and protected by copyright, trade-mark, and other intellectual-property law. Open-source components are listed in the Service's open-source acknowledgements and are governed by their respective licences.

11.2 — Provider brand assets. Provider logos and brand assets shown on the Service belong to the respective Providers and are used by Swaps under fair-use / nominative-use principles to identify the Provider. We do not modify Provider logos in colour, proportion, or transformation.

11.3 — User content. You retain ownership of any content you submit (such as support messages, feedback, address-search queries). You grant Swaps a non-exclusive, worldwide, royalty-free licence to use that content as necessary to provide the Service and as set out in the Privacy Policy.

11.4 — Trade-marks. "Swaps", the Swaps yin-yang S logo, and related marks are trade-marks of Supa Labs OÜ. You may not use them without our written permission, except to refer to the Service factually.

12. AI-generated content

Where the Service generates content using AI (such as the AI Concierge, the agent.swaps.app endpoints, or MCP responses), that content is generated by automated systems and may be inaccurate, incomplete, or out of date. See the AI Disclosure for the full disclosure. You should verify AI-generated answers before relying on them.

13. Privacy

Our processing of your personal data is described in the Privacy Policy. It includes lawful bases under GDPR, retention periods, recipient categories, and your data-subject rights.

14. Risks — read this

14.1 — Crypto risk. Cryptocurrency is volatile. Prices can change drastically within seconds. You may lose some or all of the value of any crypto you buy. You may receive less than you expected from any sale or swap. Past performance does not predict future results.

14.2 — Provider risk. Providers can fail, go bankrupt, suffer security breaches, freeze accounts, delist assets, or otherwise interrupt service. Your funds while in a Provider's custody are subject to that Provider's risk — not Swaps' risk, because Swaps does not custody.

14.3 — Network risk. Blockchain networks can experience congestion, forks, reorgs, and other disruptions. Transactions sent to the wrong network or wrong address can be irrecoverable. Crypto is unforgiving of human error; Swaps cannot reverse a confirmed on-chain transaction.

14.4 — Regulatory risk. Cryptocurrency law differs by jurisdiction and changes. Use the Service consistent with the law of your jurisdiction.

14.5 — Full risk disclosure. See the Risk Disclosure.

15. Disclaimers

15.1 — As-is. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT WARRANTIES OR CONDITIONS OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, AVAILABILITY, OR ERROR-FREE OPERATION.

15.2 — Provider disclaimer. WE MAKE NO WARRANTY OR REPRESENTATION ABOUT ANY PROVIDER, ANY PROVIDER'S SERVICES, ANY PROVIDER'S SOLVENCY, SECURITY, OR REGULATORY COMPLIANCE, OR ANY OUTCOME OF YOUR TRANSACTION WITH A PROVIDER.

15.3 — Information disclaimer. WE MAKE NO WARRANTY OR REPRESENTATION ABOUT THE ACCURACY, COMPLETENESS, OR TIMELINESS OF ANY INFORMATION, QUOTE, COVERAGE DATA, BLOG POST, HELP ARTICLE, AI-GENERATED ANSWER, OR SEARCH ADDRESS REPORT.

15.4 — Statutory carveout. Nothing in this section excludes or limits any warranty, condition, right, or remedy that cannot be excluded or limited under applicable law. Consumer users in the European Union retain all rights granted by mandatory consumer-protection law in their country of habitual residence.

16. Limitation of liability

16.1 — Cap. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, OUR TOTAL CUMULATIVE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE SERVICE — WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), WARRANTY, STATUTE, OR ANY OTHER LEGAL THEORY — IS LIMITED TO THE GREATER OF (A) ONE HUNDRED EURO (€100) OR (B) THE TOTAL AMOUNT YOU PAID TO SWAPS IN FEES IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

For users billed in USD: the equivalent cap is the GREATER of (A) ONE HUNDRED US DOLLARS ($100) OR (B) the total amount you paid to Swaps in fees in the 12 months preceding the event giving rise to the claim.

16.2 — Excluded damages. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WE ARE NOT LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES; LOST PROFITS; LOST REVENUE; LOST DATA; LOST OPPORTUNITY; LOSS OF GOODWILL; OR LOSSES ARISING FROM PROVIDER ACTIONS, BLOCKCHAIN CONGESTION, MARKET MOVEMENTS, OR THIRD-PARTY ACTS, EVEN IF WE WERE ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

16.3 — Statutory carveout (EU/UK). Nothing in this section excludes or limits liability that cannot be excluded or limited under applicable law, including liability for (a) death or personal injury caused by our negligence, (b) fraud or fraudulent misrepresentation, or (c) any other liability that cannot lawfully be excluded. EU and UK consumer-protection floor: where mandatory law in your country of habitual residence prescribes minimum statutory remedies, those remedies are not displaced by this section.

16.4 — Independence of cap. The cap in §16.1 applies to all claims in aggregate, not per-incident. The existence of multiple incidents does not multiply the cap.

17. Indemnification

To the fullest extent permitted by applicable law, you agree to indemnify, defend, and hold harmless Supa Labs OÜ, its officers, employees, contractors, and affiliates from and against any claim, demand, loss, liability, damage, cost, or expense (including reasonable legal fees) arising out of or relating to (a) your breach of these Terms, (b) your violation of applicable law, (c) your use of the Service in any way other than as expressly permitted, (d) your transaction with any Provider, (e) your evasion of any sanctions, KYC, or anti-fraud control, or (f) your infringement of any third party's rights. This obligation survives termination of these Terms.

18. Force majeure

We are not liable for any failure or delay in performance caused by events beyond our reasonable control, including but not limited to: Provider outages or failures; blockchain network congestion, forks, or reorgs; failure of payment processors; cyberattacks; government or regulatory action; sanctions; war, civil unrest, or terrorism; pandemic; failure of internet infrastructure; or any act of God.

19. Suspension and termination

19.1 — By you. You may stop using the Service at any time. You may delete your Account by emailing legal@swaps.app.

19.2 — By us. We may suspend or terminate your access to all or part of the Service, with or without notice, if (a) you breach these Terms, (b) we are required to do so by law or by a competent authority, (c) we detect abuse, fraud, sanctions match, or security risk, (d) we discontinue the Service or a part of it, or (e) we determine in our reasonable judgement that continuing your access would be harmful to other users, to Providers, or to the Service. Termination does not relieve you of obligations accrued before termination.

19.3 — Effect of termination. Sections that by their nature should survive — including §11 (IP), §16 (Limitation of Liability), §17 (Indemnification), §20 (Governing Law), §21 (Dispute Resolution), and §23 (Miscellaneous) — survive termination.

20. Governing law

These Terms are governed by the laws of the Republic of Estonia, without regard to its conflict-of-law principles. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

21. Dispute resolution

21.1 — Primary forum. The courts of Tallinn, Estonia have exclusive jurisdiction over any dispute arising out of or relating to these Terms or the Service, subject to the consumer carveouts in §22.

21.2 — Pre-litigation contact. Before filing a claim, you agree to first contact us at legal@swaps.app with a written description of the dispute. We will respond within 30 calendar days and attempt to resolve in good faith.

21.3 — Class action waiver (US users only). If you are a US resident, you agree that any dispute will be resolved on an individual basis and you waive any right to bring or participate in a class action, collective action, or representative proceeding to the maximum extent permitted by US law. This waiver does not apply to EU or UK users, where class-action waivers are unenforceable in B2C contexts.

21.4 — Injunctive relief. Either party may seek injunctive relief in any competent court to protect its intellectual-property or confidential-information rights, without first satisfying §21.2.

22. Consumer carveouts (EU, UK, California, Brazil, India)

22.1 — EU consumers. If you are a consumer habitually resident in the European Union, you have the right to bring proceedings in the courts of your country of habitual residence under Article 18 of Regulation (EU) 1215/2012 (Brussels I recast). Mandatory consumer-protection law of your country of habitual residence applies to the extent it grants you rights you cannot waive. Unfair-term provisions of Directive 93/13/EEC and any national implementation override conflicting provisions of these Terms.

22.2 — UK consumers. If you are a consumer in the United Kingdom, your statutory rights under the Consumer Rights Act 2015 are not displaced by these Terms. UK GDPR governs processing of your personal data.

22.3 — California residents. California residents have the right to opt out of "sale" or "sharing" of personal information under the California Consumer Privacy Act (CCPA) as amended by CPRA. See the Privacy Policy §California for the "Do Not Sell or Share My Personal Information" mechanism and the rights to know, delete, and correct.

22.4 — Brazilian users. Brazilian users have the rights granted by the Lei Geral de Proteção de Dados (LGPD). Our LGPD-required Data Protection Officer can be contacted at legal@swaps.app.

22.5 — Indian users. Indian users have the rights granted by the Digital Personal Data Protection Act, 2023 (DPDP Act). Our DPDP-required Grievance Officer can be contacted at legal@swaps.app. We aim to respond to data-protection requests within 30 calendar days.

23. Miscellaneous

23.1 — Entire agreement. These Terms, together with the supplemental documents linked from them and from the Legal Notice, constitute the entire agreement between you and Swaps regarding the Service and supersede any prior agreement.

23.2 — Severability. If any provision of these Terms is held to be invalid, illegal, or unenforceable, that provision is severed and the remaining provisions remain in full force and effect. A court is empowered to modify an invalid provision to the minimum extent necessary to make it valid and enforceable, preserving the original intent to the greatest extent possible.

23.3 — No waiver. Our failure to enforce any provision of these Terms is not a waiver of that provision or any other provision.

23.4 — Assignment. You may not assign these Terms or your rights under them without our prior written consent. We may assign these Terms in connection with a merger, acquisition, or sale of assets, provided your rights are not materially diminished.

23.5 — Notices. Notices to you may be given by email to the address associated with your Account or by posting on the Service. Notices to us must be sent to legal@swaps.app and (for matters requiring formal service) to our registered office: Supa Labs OÜ, Oru tn 2, Tallinn 10127, Estonia.

23.6 — No agency. Nothing in these Terms creates a partnership, joint venture, agency, fiduciary, or employment relationship between you and Swaps, or between Swaps and any Provider.

23.7 — Third-party beneficiaries. Providers are not third-party beneficiaries of these Terms. Your separate contract with a Provider governs your relationship with that Provider.

23.8 — Language. These Terms are published in English. Translations into other languages (DE, ES, FR, RU, PT) are provided for convenience. In case of conflict between the English version and a translation, the English version controls.

23.9 — Modifications. We may modify these Terms by posting an updated version with a new "Last updated" date. Material changes will be notified by email (where you have an Account) or by in-product banner. Your continued use of the Service after a material change constitutes acceptance. If you do not accept a change, you must stop using the Service.

24. Tempo Passkey Wallet Lab (hidden, testnet-only)

The Tempo Passkey Wallet Lab is a testnet-only experiment available only to allowlisted testers on tempo.swaps.app, which preceded the public Swaps Wallet Service. It is not a custodial product, not a payment-link or checkout wallet, and is unrelated to authentication passkeys used for Swaps login. The terms in this section apply only to use of the Lab. The live, public Swaps Wallet Service is governed by §26 above and by the Wallet Service Terms.

24.1 — No private-key custody. Swaps does not store seed phrases, private keys, credential secrets, or any raw signing material. Passkey signing material is created and held exclusively by the user's device, browser, or password manager (for example iCloud Keychain, Windows Hello, Google Password Manager, or an authenticator built into your browser).

24.2 — What Swaps stores. Swaps stores only metadata necessary to operate the Lab: the credential identifier, the credential public key, the authenticator GUID (AAGUID), the declared transports, the relying-party identifier (swaps.app), the wallet row, status, and audit-log entries. None of this is a secret. The list of stored fields is documented in the Privacy Policy §2 and in the underlying schema tempo_passkey_credentials. By design — and enforced through the credential schema's public-key format constraints, edge-function access control, and the documented column constraints on tempo_passkey_credentials — Swaps does not store any private key, seed phrase, credential secret, or signing material.

24.3 — Testnet only. The Lab operates exclusively on the Tempo Moderato testnet. It does not connect to Tempo mainnet, to any other production blockchain, or to any production payment system. No promise of mainnet wallet availability is made by the existence of the Lab.

24.4 — Allowlist access. Access to the Lab requires (a) authentication via Supabase, (b) inclusion in the backend allowlist (env var TEMPO_PASSKEY_LAB_USER_IDS), (c) access from tempo.swaps.app, and (d) the feature flag enabled. Unauthorised attempts are logged and denied. Allowlist status may be revoked at any time without notice.

24.5 — "Remove from Swaps" does not delete your device passkey. When you select "Remove from Swaps" for a Lab wallet, Swaps disables the corresponding row in wallet_entities and detaches the stored credential metadata (tempo_passkey_credentials.wallet_entity_id := NULL). Swaps cannot and does not delete the passkey from your device, browser, or password manager. To fully remove a passkey from your device, you must do so yourself in your device or password-manager settings (iCloud Keychain, Windows Hello, Google Password Manager, or the equivalent for your browser/OS). This separation reflects the WebAuthn standard and is not a limitation Swaps can override.

24.6 — Device control and recovery. You control passkey and device access. If you lose access to the device or password manager that holds your passkey, you may lose the ability to interact with your Lab wallet. Swaps cannot recover a Lab wallet for you because Swaps does not hold the signing material. Cross-device passkey synchronisation, if any, is provided by your password-manager vendor under that vendor's terms.

24.7 — Lab status — may change or end. The Lab is experimental and may be limited, modified, suspended, or terminated at any time before any public wallet launch, with or without notice. Lab state is not guaranteed to be preserved across changes. Swaps is not obliged to preserve, migrate, export, or continue the Lab in any form.

24.8 — No financial or investment advice. The Lab does not constitute investment advice, custody services, payment services, or any regulated financial service. See the Terms of Service §1.4 for the current compliance basis.

24.9 — Separation from Swaps authentication. The passkey used in the Tempo Lab is a wallet credential and is distinct from any authentication passkey or password used to log in to Swaps via Supabase. Removing or revoking one does not affect the other.

25.1 — What it is. Payment Links lets a verified merchant create a public request for payment (an invoice) that the merchant's customer pays by pushing funds over a convenient rail. Swaps presents the request and instructs the Provider to settle it; Swaps is not the seller, buyer, payee, or any other party to the payment.

25.2 — Non-custodial, Provider-executed. Swaps never receives, holds, or takes custody of Payment Link funds and is never a destination for funds. The regulated Provider (Bridge) creates and executes the transfer under its own authorisations and settles directly to the merchant's settlement destination.

25.3 — Key limits and fee. Activation is by default limited to Provider-verified (Bridge KYB) business customers in approved status. Where a payer pays as an individual, the payment is capped at the equivalent of USD $4,000 per payment. Swaps earns a fee of up to 1%, collected as the Provider's developer fee on a settled transfer.

25.4 — No refunds from Swaps. Because Swaps never holds the funds, Swaps does not and cannot reverse, refund, or claw back a Payment Link payment. Refunds and disputes are between the payer, the merchant, and the Provider.

25.5 — Full terms. See the Payment Link Terms for full details, including rails, settlement, underpayment tolerance, and dispute handling.

26. Wallet Service

26.1 — Live in Beta. The Swaps Wallet Service is live and available to all users as a Beta product. It is non-custodial wallet software on the Tempo network (Tempo mainnet, chain ID 4217) for holding, receiving, and sending supported USD stablecoins, and for paying a Swaps Payment Link directly from the wallet balance. As a Beta product, its features and behaviour may change.

26.2 — Direct Tempo Wallet use. Direct Wallet use means holding, receiving, and sending supported stablecoins on Tempo. You sign with a wallet passkey on your device, browser, or password manager. Swaps stores only public credential metadata, your wallet address, wallet status, and audit-log entries needed to display and operate the Wallet interface.

26.3 — Non-custodial passkey wallet. The signing material (your passkey / private key / seed) is created and held exclusively by your device, browser, or password manager. Swaps never stores private keys, seed phrases, passkey secrets, session keys, or other credential signing material, and is not a counterparty, custodian, or exchanger in respect of the Wallet.

26.4 — Technical broadcast and status layer. Swaps may display balances, prepare transaction data, submit user-authorized signed transactions to the network or a supported route, and show transaction status. This technical role does not give Swaps unilateral ability to move, freeze, recover, or settle Wallet funds.

26.5 — Wallet-adjacent provider flows. Fiat buy/sell, cross-network receive/send routes, Payment Links, Pay Invoice, and Payroll are separate from direct Tempo Wallet use. They may use independent Provider or protocol infrastructure and are available only when shown in-product for the relevant asset, network, corridor, route, and amount. Provider verification may apply where a non-Wallet provider service is used.

26.6 — No Swaps KYC for wallet-only Tempo use; gas; fees. No Swaps identity verification (KYC) is required to hold, receive, or send supported stablecoins directly on Tempo. Direct Tempo network (gas) fees, payable in a stablecoin and set by the Tempo network, apply to on-chain transactions. There is no Swaps fee for holding your Wallet balance or for direct Tempo receive/send. Supported cross-network Send may include a Swaps software, routing, or interface fee plus network or provider costs, all shown before approval; that fee is not custody, money transmission, exchange, or payment execution by Swaps.

26.7 — Bound to Swaps; supported routes only. The Wallet is a passkey wallet bound to the swaps.app domain. It can be used only on Swaps; the wallet passkey cannot sign on other websites or applications (including other Tempo apps), a wallet created elsewhere cannot be imported into Swaps, and the Swaps Wallet cannot be exported to sign elsewhere. Direct Tempo transfers use your Tempo wallet address. Wrong asset, wrong network, stale amount-bound deposit address, or unsupported route use may be delayed or permanently lost. There is no fiat buy or sell inside the Wallet. See the Wallet Service Terms.

26.8 — No recovery. Because Swaps holds no signing material, Swaps cannot recover a wallet if you lose access to the device or password manager that holds your passkey. There is no Swaps-side reset.

26.9 — Full terms. See the Wallet Service Terms for full details, including session signing keys and the relationship to the historical Tempo Lab.

27. Payroll

27.1 — What it is. Payroll is an execution-only tool for verified individual or business customers to instruct payout transfers to a list of recipients. It is currently in private beta. The figures you enter are the figures instructed for payout, unchanged.

27.2 — Not an employer of record. Swaps is not an employer of record, payroll-tax agent, or worker-classification service. Tax, withholding, filings, payslips, worker classification, and record-keeping are the Employer's sole responsibility.

27.3 — Non-custodial, Provider-executed. Payroll is non-custodial and pass-through. Swaps never receives, holds, or takes custody of payroll funds and is never a destination for them. The regulated Provider (Bridge) executes and settles all payouts under its own authorisations; Swaps is not the payer, payee, or any other counterparty to a payroll run.

27.4 — No Swaps fee today. Swaps currently charges no fee on payroll runs. Any future fee will be disclosed before it applies. Provider and network costs are borne by the Employer under the Provider's terms.

27.5 — Full terms. See the Payroll Terms for full details, including eligibility, rails, recipient destinations, and failed-payout handling.

Contact: legal@swaps.app Operator: Supa Labs OÜ · Registry 17399414 · Oru tn 2, Tallinn 10127, Estonia

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