Imprint / Legal Notice
UpSwap operator identity, contact channels, regulatory points of contact, and the operator information required for compliance with German TMG §5 and the EU DSA.
This English translation is provided for convenience and informational purposes only. In the event of any discrepancy or conflict, the Chinese version (linked below) prevails as the authoritative legal document.
1. Operator statement
This service (UpSwap) is operated by UpSwap team.
Operator statement:
All contractual obligations, liability, and dispute resolution are governed by the Terms of Service.
2. Contact
Please direct all formal communications through the channels below. Each address serves a specific function — choose the closest match for the fastest handling:
- User support: support@upswap.io
- Privacy / data subject requests: privacy@upswap.io
- Compliance / law enforcement: compliance@upswap.io
- Security / vulnerability disclosure: security@upswap.io
3. Governing law and jurisdiction
The operation of this service, its contractual obligations, and dispute resolution are governed by:
- Governing law: Laws of the British Virgin Islands (BVI)
- Dispute resolution: arbitration administered by Singapore International Arbitration Centre (SIAC)
- Liability cap: 500 USD in the aggregate per user
4. Regulatory status
UpSwap is a non-custodial cross-chain swap aggregation widget that does not hold user assets, does not open accounts, and does not issue crypto assets. Based on the FATF Recommendation 15 guidance on DeFi and non-custodial services, and the treatment of anonymizing software providers under FinCEN 2019 Guidance § 4.5.1, we take the position that this service does not constitute:
- A virtual asset service provider (VASP) as defined by the FATF
- A money services business (MSB) under the US BSA, 31 USC 5330
- A crypto-asset service provider (CASP) under EU MiCA — relying on the Recital 22 exemption for users who retain sole control of their private keys
- A virtual asset trading platform under the Hong Kong SFC regime — we do not hold user assets or match orders
- A digital payment token service under the Singapore MAS regime — we do not receive customer funds
This statement does not constitute legal advice. Users should consult local counsel in their own jurisdiction.
5. Eligibility and service restrictions
This service is not offered to the following regions or persons. By continuing to use it, you confirm that none of the following applies to you:
- Residents, citizens, or tax residents of the United States, the United Kingdom, mainland China, North Korea, Iran, Syria, Cuba, Crimea / Donetsk / Luhansk / Zaporizhzhia / Kherson, or Saint Kitts and Nevis
- Individuals or entities on the OFAC SDN List or the UN, EU, or UK sanctions lists
- Natural persons under 18 years of age
See the AML & Sanctions Policy for the full list of restricted regions and the underlying basis.
6. DSA transparency statement
Under the EU Digital Services Act (DSA, Regulation 2022/2065), should this service be deemed an "Information Society Service", users may submit content-related notices and complaints (Notice & Action) via compliance@upswap.io.
7. Updates and version control
This page is updated as our operating status changes. See the page header for the last updated date and version number.
Material changes (such as the establishment of a corporate operator or an address change) will be announced prominently on the site 7 days in advance.