Effective date: April 10, 2026

Last updated: April 10, 2026

These End User Terms of Service ("Terms") govern your access to and use of the Swaps crypto-to-crypto conversion service ("Swaps" or the "Service") made available by Swappedcom Inc., a Delaware corporation ("Swapped," "we," "us," or "our"). Swaps is made available to you through a third-party platform or application ("Merchant") that has integrated the Swaps API. By using Swaps, you agree to these Terms. If you do not agree, you must immediately stop using the Service.

Swapped may update these Terms from time to time. Changes will be effective when posted. Your continued use of Swaps after any changes constitutes your acceptance of the updated Terms.

ARBITRATION NOTICE AND CLASS ACTION WAIVER

By agreeing to these Terms, any disputes between you and Swapped will be resolved through binding individual arbitration. You waive any right to a jury trial or to participate in a class action. See Section 9 for details.

1. Eligibility

You must be at least eighteen (18) years old to use Swaps. By using the Service, you represent and warrant that you meet this age requirement and are legally capable of entering into a binding contract. You may not use Swaps on behalf of another person or entity unless you are duly authorized to do so.

2. What Swaps Is (and Is Not)

Swaps is a crypto-to-crypto conversion service. It allows you to exchange one supported cryptocurrency for another. Swaps is not a fiat-to-crypto or crypto-to-fiat service. Swapped does not:

• hold or custody your funds or private keys;

• operate a hosted wallet or user account on your behalf;

• provide investment, financial, tax, or legal advice; or

• review, monitor, or endorse any digital asset as to its legality, value, or suitability.

Swaps is delivered to you through a Merchant's platform. Swapped is not responsible for that platform's interface, disclosures, or customer support — those are the Merchant's responsibility.

3. How a Conversion Works

3.1 Initiating a Conversion

A "Conversion" is a transaction in which you exchange one supported cryptocurrency (your "Source Cryptocurrency") for another (your "Destination Cryptocurrency"). To initiate a Conversion, you will be provided a deposit address through the Merchant's platform. Once you send your Source Cryptocurrency to that address, Swapped will execute the Conversion and deliver your Destination Cryptocurrency to the wallet address you (or the Merchant on your behalf) have designated.

3.2 Quotes and Pricing

Quotes are indicative only and are valid for a limited time. The Conversion rate is not locked in when you receive a quote — it becomes final only once your Source Cryptocurrency transaction achieves at least one (1) blockchain confirmation. Rates may differ from the quote due to market movements.

3.3 Fees

Each Conversion includes two components of cost:

• the Margin — a spread applied by Swapped to the prevailing market rate, representing Swapped's compensation for the Service; and

• the Network Fee — the blockchain transaction fee required to deliver your Destination Cryptocurrency, deducted from the output amount you receive.

3.4 Minimum Transaction Amount

Conversions below a minimum notional value will be rejected or refunded. The minimum is equal to twice the Network Fee of the Destination Cryptocurrency plus EUR 0.01. If the Network Fee required to return your funds exceeds the value received, no refund will be made.

3.5 Irreversibility

All Conversions are final and irreversible once broadcast to the blockchain. Swapped has no ability to reverse blockchain transactions. You are solely responsible for providing accurate wallet addresses and ensuring you send funds on supported networks. Errors — including incorrect addresses or unsupported networks — may result in permanent loss of funds.

4. Your Responsibilities

By using Swaps, you represent, warrant, and agree that you will:

• only use Swaps for lawful purposes and in compliance with all applicable laws and regulations;

• provide accurate wallet addresses and ensure all cryptocurrency is sent on supported blockchain networks;

• not initiate or facilitate Conversions on behalf of any sanctioned individual, entity, or jurisdiction;

• not use Swaps in connection with fraud, money laundering, terrorist financing, ransomware, stolen funds, darknet markets, mixers, tumblers, or any other illicit or prohibited activity;

• not attempt to circumvent Swapped's compliance, sanctions screening, or monitoring processes; and

• cooperate with any compliance review or request for information from Swapped to the extent required by applicable law.

5. Sanctions and Prohibited Conduct

5.1 Sanctions Screening

Swapped screens all inbound funds and wallet addresses against global sanctions lists, including those administered by OFAC (US), the EU, the UN, and the UK, using blockchain analytics tools. Swapped may monitor transaction behavior and risk profiles at its discretion.

5.2 Blocked or Restricted Transactions

If Swapped determines that a Conversion involves or is associated with a sanctioned person, entity, or jurisdiction, or any prohibited activity, Swapped may freeze, block, or decline the transaction and file reports with relevant authorities. Swapped will notify you where legally permitted to do so.

5.3 Prohibited Jurisdictions

You may not use Swaps if you are located in, a resident of, or acting on behalf of a person or entity in any jurisdiction subject to comprehensive sanctions (including those administered by the US, EU, UK, or UN).

5.4 Prohibited Activities

Conversions associated with any of the following are strictly prohibited:

• fraud, theft, scams, or unauthorized access to funds;

• money laundering, terrorist financing, or corruption;

• ransomware, extortion, or proceeds of crime;

• darknet marketplaces or illicit online services;

• mixers, tumblers, or tools designed to obscure transaction origin; or

• any activity Swapped determines poses legal, regulatory, or compliance risk.

6. Digital Asset Risks

You acknowledge and accept the following risks inherent in using Swaps:

• Digital asset values are highly volatile and may fluctuate significantly between the time you request a quote and when your Conversion is confirmed.

• Blockchain transactions are irreversible. Errors in wallet addresses or network selection may result in permanent, unrecoverable loss of funds.

• Swaps may be unavailable or delayed due to blockchain congestion, maintenance, market events, or other factors outside Swapped's control.

• Swapped does not guarantee any specific exchange rate, execution speed, or liquidity for any digital asset.

• Regulatory treatment of digital assets varies by jurisdiction and may change. You are responsible for understanding the legal status of digital assets in your location.

You are solely responsible for any taxes arising from your use of Swaps, including taxes on digital asset conversions or dispositions.

7. Disclaimers and Limitation of Liability

7.1 No Warranties

Swaps is provided on an "AS IS" and "AS AVAILABLE" basis. Swapped makes no warranties, express or implied, including as to uninterrupted access, accurate pricing, execution speed, or error-free performance.

7.2 Limitation of Liability

To the fullest extent permitted by law, Swapped is not liable for any indirect, incidental, special, punitive, or consequential damages, including loss of funds, loss of profits, or reputational harm. Swapped is not liable for losses arising from:

• market volatility or rate changes between quote and execution;

• incorrect wallet addresses, unsupported networks, or user error;

• blockchain delays, failures, or irreversibility;

• compliance actions, sanctions freezes, or law enforcement requests; or

• failures of third-party infrastructure or the Merchant's platform.

Swapped's total liability to you for any claims arising in any 180-day period is limited to the fees Swapped retained from Conversions you processed in that period.

8. Termination and Service Changes

Swapped may modify, suspend, or discontinue Swaps or any supported digital asset at any time, with or without notice. Your access to Swaps may also be suspended or terminated if you breach these Terms or for legal, regulatory, compliance, or security reasons. Upon termination, any pending Conversion for which Swapped has already received funds will be completed or unwound as applicable.

9. Dispute Resolution and Arbitration

9.1 Binding Arbitration

Any dispute arising out of or relating to these Terms or your use of Swaps will be resolved through binding arbitration administered by the American Arbitration Association (AAA) before a single arbitrator. Arbitration will take place in Delaware and be conducted in English. All proceedings will be confidential.

9.2 No Class Actions

All claims must be brought individually. You waive any right to participate in class actions, collective proceedings, or consolidated arbitration. Either party may seek injunctive or equitable relief in a court of competent jurisdiction for matters relating to intellectual property or unauthorized use of the Service.

10. Privacy

10.1 Your Primary Privacy Relationship is with the Merchant Swaps is made available to you through a Merchant's platform. The Merchant is responsible for collecting, managing, and protecting your personal data in connection with your use of their platform. You should read the Merchant's privacy policy carefully before using Swaps. It governs how your personal data is handled, what rights you have, and who to contact with privacy requests.

Swapped is not responsible for the Merchant's data practices and makes no representations about how the Merchant processes your personal data.

10.2 Swapped's Independent Processing Swapped processes a limited amount of data independently and for its own purposes, specifically:

• wallet addresses and transaction data submitted through the Merchant's integration, to execute and record Conversions; and

• the same data, for Swapped's own compliance obligations — including sanctions screening, AML monitoring, and financial crime detection — under applicable law.

For this limited processing, Swapped acts as an independent data controller. Swapped does not use this data for marketing or any purpose unrelated to the operation and legal compliance of Swaps.

10.3 EU/EEA/UK Users — GDPR If you are located in the EU, EEA, or UK, you have rights under the General Data Protection Regulation (GDPR) or UK GDPR in respect of personal data that Swapped processes about you (as described in Section 10.2 above). These include the right to access, rectify, or request erasure of your data, to object to certain processing, and to lodge a complaint with your national data protection authority.

Note that many of these rights are subject to limitations where Swapped is required to retain or process data to comply with legal obligations — in particular, AML and sanctions record-keeping requirements mean transaction data must be retained for a minimum of five (5) years.

To exercise your rights in respect of Swapped's own processing, contact us at admin@swapped.com. For all other privacy matters, contact the Merchant directly.

10.4 Swapped's Privacy Policy For further information about Swapped's data practices, see our Privacy Policy at swapped.com/legal/privacy-policy. 

11. Governing Law

11.1 Non-EU/EEA/UK Users If you are located outside the European Union, European Economic Area, and United Kingdom, these Terms are governed by the laws of the State of Delaware, without regard to conflict-of-law principles. Any dispute not subject to arbitration under Section 9 will be heard exclusively by the courts located in Delaware, and you consent to personal jurisdiction and venue in those courts.

11.2 EU/EEA/UK Users If you are located in the European Union, European Economic Area, or United Kingdom, these Terms are governed by the laws of Denmark. Any dispute not subject to arbitration under Section 9 will be subject to the non-exclusive jurisdiction of the Danish courts.

Nothing in this Section limits any rights you have under the mandatory consumer protection laws of your country of residence. Where applicable EU or UK law provides you with rights that cannot be excluded or limited by contract — including under Rome I Regulation (EC) No 593/2008 or its UK equivalent — those rights are unaffected by these Terms.

12. General

• Entire Agreement. These Terms constitute the entire agreement between you and Swapped regarding Swaps.

• Severability. If any provision is found invalid, the remaining provisions continue in full force.

• Force Majeure. Swapped is not liable for delays or failures caused by events outside its reasonable control.

• Independent Parties. Swapped, and you are independent parties. These Terms do not create any partnership, agency, or joint venture.

No Third-Party Beneficiaries. These Terms do not create any third-party beneficiary rights.