Terms of Service

Last updated: 2026-10-03 Version: 2.6 Status: Advance notice Effective: New products and features: first use on or after 7 October 2026; existing services: 10 November 2026, subject to the notice period below

For newly available products and features, this edition applies when you first choose to use the relevant service and accept its terms, on or after 7 October 2026. The product must actually be launched and available to you. For changes to services you already use, this edition applies from 10 November 2026, but never earlier than 30 days after we notify you of the changes, or a later date required by applicable law. Until then, the previous conditions continue for those existing services. Accepting in advance does not shorten that transition. Publication and acceptance do not make a product available or establish regulatory permission.

These Terms govern Swaps.app, our dashboard, mobile and mini apps, public API, agent.swaps.app, hosted and npm MCP servers, and other interfaces linking to these Terms (the "Service"). The operator is Supa Labs OÜ, registry code 17399414, Oru tn 2, Tallinn 10127, Estonia ("Swaps", "we", "us"). Contact: legal@swaps.app.

Your explicit acceptance records your agreement to the identified published revision. You may accept a future revision before its stated effective date; doing so does not bring that date forward. The notice and acceptance screen identify the dates and services to which it applies. Conditions for a newly chosen product can apply on a different date from changes to your existing services. Until the applicable change takes effect, the existing terms continue to govern those existing services. Mandatory legal rights are preserved throughout.

The in-product acceptance screen identifies whether you are accepting personally or personally and for a named business account. Acceptance for a business account requires its account owner to have authority to bind the business. It does not record personal acceptance by other members or acceptance for another account. A further account requires its own authorised acceptance. Personal acceptance does not by itself determine whether you act as a Consumer or a Business User.

1. The Service and our role

1.1 Software and providers. Swaps supplies comparison, routing, wallet software, payment-request and payout orchestration, address intelligence and developer tools. Depending on the product, a transaction uses a third-party provider, a user-authorised wallet transaction, a blockchain contract, or a combination. Some providers open an external checkout; others are integrated into our interface.

Our functions can include preparing payment data, submitting authorised instructions to a provider, monitoring payment status and triggering a contract's predetermined distribution. The applicable product terms identify which functions Swaps performs. Providing these tools does not give us general authority to spend from your wallet or decide a different recipient for an already bound contract payment.

1.2 Separate contracts. We supply the Service under these Terms. The merchant or recipient is responsible for the underlying goods, services, employment or other obligation being paid. Each provider supplies its services under the terms presented for that route. These relationships do not remove our responsibility for our own Service.

For Bridge-powered features, Swaps acts as an integrating developer providing the interface and submitting authorised instructions. The applicable Bridge entity supplies its financial services under its own agreement with the user. We remain responsible for our integration and support. This arrangement does not extend to a separate Relay or Crypto Processing contract route.

1.3 Route-specific control. Swaps Wallet uses a passkey-controlled wallet whose transactions require the user's signing authority. Provider accounts and funding wallets may hold funds under provider controls. Cross-network routes may involve funds held in transit.

For direct Tempo Crypto Processing, funding and contract settlement are separate steps. The payer authorises the funding transfer through their wallet or sending service. Swaps can then submit a separate transaction to trigger the contract's fixed distribution, without a further payer signature. The contract's merchant address, fee address and merchant amount are bound to the payment address and cannot be changed for that address. Swaps' release automation does not hold the payer's wallet signing authority. The Crypto Processing Terms explain this mechanism and its limits.

Read the product terms: these arrangements have different cancellation, recovery and insolvency risks. Receipt of a fee or accidental excess must not be confused with control of your wallet. An accidental excess is not automatically a donation or additional agreed fee.

1.4 Regulatory status. Supa Labs OÜ does not claim authorisation as a bank, crypto-asset service provider, payment institution or electronic-money institution. A provider's authorisation does not extend to Swaps. Describing software as non-custodial, or using a provider, does not itself establish a regulatory exemption. We may restrict a route where its legal, contractual or operational requirements are not met. An available interface does not mean every feature is available to every person or jurisdiction.

1.5 No professional advice. Quotes, reports, risk signals and AI explanations are information, not investment, legal or tax advice, a recommendation to transact, or certification of an address or person.

1.6 Supplemental terms. These Terms apply with the relevant Wallet Terms, Payment Link Terms, Crypto Processing Terms, Payroll Terms, Pay an Invoice Terms, Accounts Terms, Address Check Terms, Referral Terms and API Terms. The AUP, Sanctions Policy, Risk Disclosure and Limits and Enforcement also apply. Product provisions take priority for that product; a separately signed agreement takes priority where expressly stated. Mandatory law prevails.

Product terms govern the relevant payment or service route; API Terms govern developer access, delegated authority and confirmation requirements. Provider terms govern the provider's services and do not replace our obligations. Privacy is a notice about processing and rights; acceptance of this contract does not supply optional cookie consent or a separate payment mandate.

2. Definitions

A User uses the Service; an Account is a Service account or business workspace. A Consumer acts outside their trade, business or profession; a Business User acts for business purposes. A Provider supplies an external financial, blockchain, identity, screening or other service; the term does not imply every provider is regulated. A Merchant, Payer or Recipient has the role described in the product terms. An Agent is software acting under user instructions and credentials. Credits are Service usage units, not money, deposits or crypto-assets.

3. Eligibility and authority

You must be at least 18 and legally able to contract. Provide accurate information, use the correct personal or business profile, and have authority over the funds, account and instructions you submit. Businesses must keep authorised-user and requested ownership information accurate.

Availability depends on residence, establishment, transaction purpose, provider eligibility, assets, networks and restrictions. Do not bypass verification, misrepresent your location or holder type, or divide activity to evade limits. Supported business accounts and delegated users are permitted; accounts created to evade enforcement are not.

4. Quotes, instructions and completion

Quotes are time-sensitive. Rates, fees, availability and amounts received can change before acceptance or execution. The confirmation screen and applicable provider terms identify your offer. An estimate is not a guaranteed settlement amount or time.

Check the asset, network, address, beneficiary, amount, fees and reference before confirming. Send only supported assets through the displayed instructions. An API response, wallet connection, draft invoice, webhook or "funded" status is not itself proof of settlement. API credentials and wallet signatures serve different purposes; neither substitutes for the other where both are required.

Creating or sharing a payment request does not authorise a debit from the payer's wallet. Where you choose a contract-based route, review the stated distribution and release conditions before funding it. Subsequent automated settlement implements that route; it is not authority to change the agreed destination or initiate unrelated payments.

Cancellation may stop future activity without reversing a payment or an issued invoice. Blockchain transactions may be irreversible. This technical limitation does not extinguish a legal claim or remedy.

5. Credits and paid digital services

Address Check is our address and transaction report service, including when accessed through Ask Swaps. The Address Check Terms apply across these access points. Its one-time introductory free-check allowance is shared per user as set out in Limits & Enforcement, section 3.1; changing the interface or product name does not create another allowance.

Price, usage entitlement and material restrictions, including any expiry, are disclosed before purchase. Credits are usable only for stated features and cannot be transferred or redeemed for cash except where offered or required by law.

We must deliver purchased services as described. Failed paid operations are addressed under the applicable product's credit or refund procedure. These Terms do not make an undelivered service non-refundable or exclude statutory withdrawal, conformity or refund rights.

6. Referrals

The Referral Terms govern qualification, credits and attribution. Fraudulent, self-generated or otherwise ineligible activity may be disqualified after assessment. Changes and enforcement remain subject to mandatory law.

7. Fees

Swaps may receive provider commissions and charge disclosed platform, transaction, conversion, cross-network, report or subscription fees. The product or confirmation screen identifies applicable charges and whether included in or added to the payment. Provider, network and intermediary charges may also apply.

Commission creates a commercial relationship with a provider. Offer ordering depends on the selected sort and operational criteria; we do not promise an exhaustive or independent market comparison. An accidental overpayment is not a fee merely because a contract sends it to a fee address. Product terms explain investigation and return procedures.

8. Access and security

Protect credentials, API keys, webhook secrets and wallet signing material. Account sign-in and wallet signing passkeys can have different roles. Account recovery does not necessarily recover wallet signing authority.

You are responsible for instructions you authorise and for managing your personnel and integrations. Report suspected compromise through support or security@swaps.app and revoke affected credentials where possible. Credential use is evidence of an instruction, but does not automatically waive your rights concerning an unauthorised transaction, security defect or our own conduct. We assess the circumstances and applicable law.

9. Account closure

You may stop using the Service and request closure through support. Cancel future arrangements, reconcile pending instructions and preserve wallet access and records. Closure does not automatically cancel provider transactions or erase on-chain records.

The Privacy Policy explains erasure and lawful retention. Closure does not permit indefinite retention of all personal data. Properly incurred obligations remain due, subject to refunds and other legal entitlements.

10. Use and intellectual property

We grant you a limited, non-exclusive right to use the Service for intended personal or business purposes and to integrate documented APIs where permitted. We retain our software and branding; third-party components retain their licences.

Do not copy or resell the Service except as permitted, infringe rights or bypass security. This does not prohibit interoperability or other activity mandatory law permits. You retain your content and grant only the rights reasonably needed to process and deliver it for the Service and its lawful operation.

11. Your content and obligations

You must have the rights and lawful basis to submit invoices, recipient details and other data. Provide required notices to payers, workers and recipients. Do not place secrets, unnecessary sensitive data or signing material in public descriptions, prompts or URLs.

You remain responsible for your underlying sale, wage, invoice, tax and consumer obligations. A payment tool does not make Swaps an employer, merchant of record, escrow agent or tax representative.

12. Providers

Provider eligibility, verification, fees, execution, complaints and recovery terms apply to their services. Providers may delay, reject or restrict transactions under their obligations. An integration or logo does not guarantee solvency or authorisation for your route. This does not exclude liability for our own representations or performance.

13. AI and agents

The AI Disclosure explains limitations. Review material instructions, amounts, recipients and permissions before authorising an agent or transaction. An agent must act within actual authority; an account connection or general chat message is not permission for every financial action. The API Terms describe confirmation requirements.

14. Data and cookies

The Privacy Policy explains processing and rights; the Cookie Policy explains optional choices. Acceptance of these Terms is not consent to optional tracking or unrelated processing. A DPA applies only to processing within its agreed customer-instruction scope.

15. Service quality

We will provide the Service with reasonable care and skill and comply with mandatory standards. Network and provider information can be incomplete, delayed or inaccurate. Unless expressly agreed, we do not guarantee uninterrupted access, a transaction time, a risk-free asset or financial outcome.

Where a feature is labelled Preview or Beta, the label describes its development stage and possible limits on availability, support or functionality. It is not a promise of a future release or uninterrupted operation. It does not remove mandatory rights, excuse a failure to use reasonable care or establish regulatory approval or exemption. Test and live environments are distinguished in section 24.

16. Liability

Nothing limits liability that cannot lawfully be limited, including for fraud, intentional misconduct, gross negligence where exclusion is prohibited, death or personal injury where applicable, or statutory consumer and data-protection rights. These Terms do not authorise retention of money to which we are not entitled.

For Business Users, to the extent lawful, we exclude indirect or consequential losses, lost profits, business opportunities and goodwill. Aggregate liability arising from the Service in a twelve-month period is limited to the greater of EUR 100 or the fees you paid us in that period, subject to the exceptions above and any expressly agreed written terms.

For Consumers, that cap and those Business User exclusions do not apply. Liability and remedies follow applicable consumer and mandatory law. We remain responsible for losses that law makes us responsible for. You must take reasonable steps to limit avoidable loss.

16.1 Cybersecurity incidents, misuse and AI errors

No connected service or AI system is guaranteed to be secure, uninterrupted or error-free. AI output may be inaccurate, fabricated or affected by malicious instructions in external content. An AI response does not itself authorise a transaction or prove that it completed. Review material outputs and transaction details, protect credentials, and use the permissions and confirmation controls provided for the feature.

To the extent permitted by applicable law, we are not responsible for losses attributable to your unlawful use, your own incorrect instructions that the Service accurately presented and carried out as authorised, or compromise of your devices or independently operated integrations outside our reasonable control. This exclusion does not apply to the extent our own breach of duty contributed to the loss. It does not limit responsibility imposed by mandatory law, including liability that does not depend on fault, or change any statutory burden of proof. Confirming a transaction is not an automatic waiver of a claim concerning misleading information, a security defect or an unauthorised action.

An attack, outage or AI error does not by itself determine who is liable. Responsibility depends on the applicable duties, cause and circumstances. The limitations and non-excludable rights in this section continue to apply. These provisions do not excuse us from maintaining appropriate security, meeting data-protection duties or providing the Service with reasonable care and skill.

17. Business indemnity

Business Users indemnify us for reasonable third-party claims and losses caused by their material breach, unlawful use or infringing content, including conduct of persons they authorise. This does not cover our own breach, negligence or misconduct. We must notify you promptly, permit reasonable participation in the defence and mitigate loss. No settlement may admit your fault or impose a non-monetary obligation without your consent. This section does not apply to Consumers.

18. Events outside reasonable control

A party is not responsible for failure caused by an event outside its reasonable control to the extent law permits, provided it reasonably mitigates and resumes performance. This does not waive accrued obligations, required refunds or mandatory rights.

19. Suspension and termination

We may restrict a feature, credential or account where reasonably necessary for security, suspected misuse, non-payment, provider restrictions or law. Measures should be proportionate. Where practicable and lawful we give notice and explain the reason; urgent measures may precede notice. See Limits and Enforcement for review.

Interface restrictions do not themselves reverse blockchain transactions, cancel provider instructions or freeze wallets. We may terminate for material breach or discontinue a service with appropriate notice. Remaining paid entitlements and pending instructions are addressed under the product terms and law, not automatically forfeited.

20. Governing law

Estonian law governs. Consumers retain mandatory protections of their habitual-residence law where applicable.

21. Complaints and courts

Contact legal@swaps.app with the relevant reference and outcome sought; never send signing material. We will consider your complaint and explain our response. A provider complaint may also need to go to that provider.

Business disputes are subject to competent courts in Tallinn, Estonia, unless otherwise agreed in writing. Consumers retain courts available under mandatory law. These Terms do not require consumer arbitration or unlawfully waive participation in proceedings.

Eligible consumers may contact the Estonian Consumer Disputes Committee through TTJA or the European Consumer Centres Network, without losing access to a court.

22. Consumer withdrawal

Where a statutory distance-contract withdrawal right applies, the period is generally 14 days from concluding a service or digital-content contract. For an Address Check or Credits contract, you can use Withdraw from contract, review your declaration and confirm its submission. We acknowledge receipt electronically, including your declaration and its receipt date and time. You can also notify legal@swaps.app with an unambiguous statement identifying yourself, the contract and your decision. You may write: "I withdraw from my contract for [service/order], concluded on [date]. Name: [name]. Contact: [contact]. Date: [date]."

Early digital-content supply can end this right only where legal conditions are satisfied, including any required prior express consent, acknowledgement and confirmation. Starting services during the period permits a proportionate charge only where legal conditions are met; loss after full performance also requires the applicable conditions. These Terms alone do not supply separate consent.

Different rules or exceptions may apply to a provider's financial service or market-priced transaction. You must receive the relevant transaction disclosures. Blockchain irreversibility is not a universal withdrawal exception. Required refunds, conformity remedies and other mandatory rights remain.

23. General and changes

23.1 Notices. Keep your email current. We use your contact details and the Service; notices requiring a durable medium will be provided in that form.

23.2 Assignment. You may not transfer the agreement without consent except where law permits. We may transfer it in a reorganisation or sale without reducing mandatory rights and with required notice.

23.3 Severability. Invalid provisions are severed or adjusted only as law permits.

23.4 No waiver. Delay enforcing a right does not waive it.

23.5 Agreement. These and applicable supplemental and written terms govern the Service without excluding non-excludable statements or rights.

23.6 Language. English is the reference if translations differ, subject to mandatory language and consumer interpretation rules.

23.7 Contact. Legal and privacy: legal@swaps.app; security: security@swaps.app; support through the Service.

23.8 Survival. Provisions needed for accrued obligations, disputes, data protection and intellectual property survive as applicable.

23.9 Changes. Revisions may reflect Service, legal, security, provider or commercial changes. For material changes affecting existing users we normally give at least 30 days' advance notice by email or another appropriate durable medium, or longer where required. A shorter period may apply to necessary legal or urgent security changes, with explanation where lawful. Changes apply prospectively. You may decline a material change. Once it applies, new actions requiring the updated terms may remain unavailable until you accept. Declining alone does not remove access to your history, account recovery or management of transactions already in progress, and does not require you to close your account. You may also close the affected service without a termination charge, subject to prior obligations and applicable refunds. Express agreement will be obtained where required; continued use is not a substitute for new tracking consent, a payment mandate or another required authorisation.

24. Test environments

Test mode and lab features simulate activity. Do not send real funds or personal data to test environments or represent simulated results as completed payments. Check network and environment labels.

Preview or Beta does not itself mean test mode. Check the environment, network and route before using a feature; where real transactions are enabled, their fees, settlement risks and applicable product terms still apply. Do not use an operation if its test or live status is unclear. A preview label does not expand account eligibility or permitted jurisdictions.

25. Payment Links

Eligible merchants and individuals can request payment through available bank or crypto routes. Requirements and recovery differ. The Payment Link Terms apply.

26. Wallet

The Wallet supports on-chain balances and transactions with optional provider and cross-network routes. The Wallet Terms explain signing authority, transit and recovery.

27. Payroll

Payroll routes instructions for eligible payers' workers and recipients. It does not determine wages, tax or employment status. The Payroll Terms apply.

28. Crypto Processing

Merchants can issue invoices for supported stablecoin payments. The Crypto Processing Terms govern contracts, cross-network routes and payment exceptions.

29. Recurring invoices

Scheduling recurring invoices is not permission to debit a wallet. Each invoice requires the authorisation described in the product. Cancelling scheduling does not necessarily cancel an issued invoice or the merchant contract.

30. API and MCP

Authenticated developer surfaces can create resources and submit scoped instructions. A read-only public variant does not make every developer connection read-only. The API Terms apply.

31. Pay an Invoice

This product routes eligible payer funding toward a beneficiary through supported providers. Funding and bank settlement are separate. The Pay an Invoice Terms apply.

32. Accounts

Accounts displays provider-issued deposit instructions and status. This does not mean Supa Labs OÜ opened a bank deposit account in your name. The Accounts Terms and provider terms explain the arrangement.