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hodlhodl

6/10
high confidence · 5 documents read
grade C
total /10

Peer to peer trading platform. Trade globally. Using any payment system. For any currency.

Privacy level
45/100
Trust level
74/100
Accepts
XMRBTCLNCARDCASH
Listing statushigh confidence · 5 documents read
grade C

What the documents mean for you

Hodl Hodl can suspend or close your account at its sole discretion and may demand identity verification at any time. In a dispute support can ask for your passport and bank statements, and its decision is final. They keep your data 5 years after closure.

KYC level 2/4 · Rare KYC

Registration needs only an email address, nickname and password, and new voluntary identity verification is no longer accepted. However, Section 3.5 lets Hodlex Ltd introduce mandatory identification or verification at any time if law or its own internal policies require it, and failing to complete it can get your account suspended or terminated; in disputes support can demand a government-issued ID and bank statements. That is a risk-and-law-driven power to ask, not routine or automated KYC.

There is no identity check at sign-up, but the operator can bring in mandatory verification at any time under law or its own internal policies, and it screens users for sanctions and fraud. If you open or face a dispute, support can ask for your full name, date of birth, country of residence or citizenship, a government-issued ID and bank or payment account statements. If you do not supply requested documents in time, they can rule the dispute against you and suspend or terminate your account.

Warnings

Access refused without explanation or refund

If they believe information you gave is false, inaccurate or incomplete, they can refuse access or terminate your account "without explanation or refund".

Verification can become mandatory

The operator can introduce compulsory identity checks at any time, under law or its own internal policies. If you do not complete them, they can suspend or terminate your account.

Many countries barred

You cannot use the service if you are a citizen, resident, tax resident of or currently located in Russia, Belarus, the United States, Cuba, North Korea, Iran, Iraq, Syria, Sudan, Somalia or any UN-embargoed territory.

How the score was reached

Privacy45/100

Baseline+50
Rare KYC-5
May require KYC/SOF by policy/law-6
Soft KYC-3
Identity-free registration+10
Data sharing-3
Account required-1
Non-custodial wallet+3
Total45

Trust74/100

Baseline+50
Verified+10
Mature service+5
Legally registered+2
May require KYC/SOF by policy/law-4
Soft KYC-1
Peer to peer market+4
Escrow available+6
Non-custodial wallet+5
May suspend your account-4
Third party infrastructure-1
Source code is private-1
Non-custodial protocol+3
Total74

Overall = (privacy × 0.6 + trust × 0.4) / 10, rounded = 6/10, grade C. Each attribute above rests on a clause quoted below or was assigned by a moderator; the rest is what the listing knows.

Attributes15 moved the score

May require KYC/SOF by policy/lawprivacy -6 · trust -4

The service may require identity verification, KYC or Source of Funds information, by its own policy or by law, at any time.

The terms reserve the right to bring in mandatory identification or verification at any time, under law or the company's own internal policies, with suspension or termination if you do not complete it.

“If required by applicable law or our internal policies, we may at any time introduce mandatory identification or verification procedures. Failure to complete required verification constitutes a violation of this Agreement and may lead to account suspension or termination.”

Terms, accounts.hodlhodl.com
May suspend your accounttrust -4

The service reserves the right to suspend or limit access for violations or arrears.

Access can be suspended or limited for rule violations, and unpaid investigation fees can also trigger suspension.

“Investigation fees are payable by invoice or escrow deduction; outstanding Investigation Fees may result in account suspension.”

Terms, accounts.hodlhodl.com
Soft KYCprivacy -3 · trust -1

No formal KYC, but personal information is needed for certain features or services.

No identity check at registration, but personal identity documents are collected when you are in a dispute.

“Identity data | In disputes: full name, date of birth, country of residence/citizenship, government-issued ID, and bank/payment account statements.”

Privacy policy, accounts.hodlhodl.com
Data sharingprivacy -3

Personal data may be shared with authorities or third-party providers for compliance.

Personal data can go to law enforcement, regulators and courts, and is also handed to named operational processors.

“We may disclose your personal data to law enforcement, regulatory authorities, courts, or other public bodies where required by applicable law, a valid legal order, or to protect the rights, property, or safety of Hodlex Ltd, our users, or the public.”

Privacy policy, accounts.hodlhodl.com
Third party infrastructuretrust -1

Entirely on rented servers, so the infrastructure operator is an additional party to trust.

Personal data is stored on Amazon's rented cloud infrastructure, adding an infrastructure operator to the parties handling user data.

“Amazon Web Services (AWS) | Cloud infrastructure and storage for your personal data. Data stored within the EU/EEA region (eu-west-1 / eu-central-1) where technically feasible.”

Privacy policy, accounts.hodlhodl.com
Account requiredprivacy -1

An account has to be created to access and use the service.

You cannot use the platform without registering an account.

“To access our Services you must create a User Account at [accounts.hodlhodl.com](https://accounts.hodlhodl.com/) by providing a valid email address, nickname, and password. You must verify your email address before accessing the Platform.”

Terms, accounts.hodlhodl.com
Source code is privatetrust -1

The source code is not public, so it cannot be reviewed or audited.

Identity-free registrationprivacy +10

Users can create accounts without giving personal information such as a full name, address or phone number.

Opening an account asks only for an email address, a nickname and a password, not a legal name, address or phone number.

“To access our Services you must create a User Account at [accounts.hodlhodl.com](https://accounts.hodlhodl.com/) by providing a valid email address, nickname, and password.”

Terms, accounts.hodlhodl.com
Verifiedtrust +10

Passed repeated checks over time and showed consistent behavior.

Non-custodial walletprivacy +3 · trust +5

The user holds and manages the private keys; the service never has custody of the funds.

Escrow availabletrust +6

A trusted third party holds funds during a peer-to-peer transaction until both sides have delivered.

Each trade uses a 2-of-3 multisig escrow address; the operator holds the third key and can sign with one party to settle a dispute.

“A unique P2SH multisig escrow address is automatically generated, requiring 2-of-3 keys to release funds.”

Terms, accounts.hodlhodl.com
Mature servicetrust +5

This service has been operational for 8 years. While this indicates stability, it is not a future-proof guarantee.

Peer to peer markettrust +4

A marketplace where unknown people trade directly with one another rather than with the operator.

The service is an advertising board where users trade Bitcoin directly with each other; the operator is not a party to the contracts.

“[hodlhodl.com](https://hodlhodl.com/) — a peer-to-peer Bitcoin trading marketplace ("Hodl Hodl" or "Trading Platform");”

Terms, accounts.hodlhodl.com
Non-custodial protocoltrust +3

The protocol never takes custody of the user's funds during an exchange.

The operator states it never holds or custodies user funds and cannot move escrowed Bitcoin on its own, holding only one of three keys.

“Hodlex Ltd holds only one key and cannot unilaterally move your funds.”

Terms, accounts.hodlhodl.com
Legally registeredtrust +2

Legally registered as Hodlex Ltd in Marshall Islands.

What costs you most first. Tap one to read the clause it rests on, or what the listing knows, priced as kycnot.me prices it.

What the documents say

−ID in disputesverification

If you are in a dispute, support can ask for your ID or passport, payment account statements and receipts. Not providing them in time can make you lose the dispute.

“**Gather your evidence** Payment account statements, transaction receipts, ID/passport, and any other documentation support may request. All documents must include complete payment details — partial documents may be disregarded.”

Terms, accounts.hodlhodl.com
−Support decides finallydisputes

Hodl Hodl support rules on trade disputes and has the final word. A completed or resolved contract cannot be appealed, revised or reversed.

“Support will acknowledge your request and inform you of next steps. Customer support has the final word on all dispute outcomes.”

Terms, accounts.hodlhodl.com
~Operator holds a keycustody

Your Bitcoin sits in a 2-of-3 multisig escrow where the operator holds one key alongside the buyer and seller, so it can sign with one side to move the coins.

“One key belongs to the Seller, one to the Buyer, and one to Hodlex Ltd.”

Terms, accounts.hodlhodl.com
−Investigation feeother

They can charge you for internal investigations billed by staff time, and your request stays unfinished until you pay it in full.

“An Investigation Fee may be charged, calculated based on actual time spent by our personnel. We will notify you and obtain consent before commencing a chargeable investigation, except where urgent action is required to prevent crime or abuse.”

Terms, accounts.hodlhodl.com
−Five-year retentionlogging

They keep account and trading data for 5 years after you close the account or last use it, and identity documents for 5 years after a dispute. Access logs are kept 12 months.

“Account and trading/lending data | 5 years after account closure or last activity (whichever is later), to satisfy AML record-keeping obligations under applicable law.”

Privacy policy, accounts.hodlhodl.com
−Data goes to processorsdataSharing

Your data reaches outside companies: Sentry for crash reports (your IP may appear in error logs), Google Analytics, AWS for storage, ProtonMail and SendGrid for email.

“Sentry | Error monitoring and crash reporting. Your IP address may be included in error logs. Data processed in the USA under Standard Contractual Clauses.”

Privacy policy, accounts.hodlhodl.com
−Public profilelogging

Anyone, including people who are not logged in, can see your offers, username, reputation, trade statistics, account status and whether you are online.

“Your profile page: username, reputation score, trade statistics, account status.”

Privacy policy, accounts.hodlhodl.com
−Account can be cut offother

They can terminate, suspend or limit your access at their sole discretion, including if one or more users report you as a scammer or your account sits unused for 24 months.

“We may terminate, suspend, or limit your access at our sole discretion if:”

Terms, accounts.hodlhodl.com

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Scanned 2026-10-25 · read by claude-opus-5 · documents rated medium complexity · re-read when the documents change. Readings are machine-generated from the quoted clauses and are a starting point, not legal advice.