hodlhodl
grade C
Peer to peer trading platform. Trade globally. Using any payment system. For any currency.
grade C
What the documents mean for you
Hodl Hodl can make identity checks mandatory at any time and can suspend or close your account at its discretion without refund. A dispute can require a government ID. It records your IP and MAC address and keeps account data 5 years after closure.
There is no routine identity check at sign-up: an account needs only an email address, nickname and password. But Section 3.5 lets Hodlex Ltd introduce mandatory identification or verification at any time where law or its own internal policies require it, and refusing means suspension or termination. In a dispute, support can demand a government-issued ID and bank statements, which is an identity demand made to you rather than a disclosure of data already held.
Verification is set off by a dispute over a trade, or by the operator deciding that law or its own internal policy requires identification. In a dispute you may have to hand over 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 complete a required verification, they treat it as a breach of the agreement and may suspend or close your account; if you do not give support the requested documents in a dispute, they may decide the dispute in favour of the other party.
Warnings
You cannot use the service if you are a citizen, permanent resident, tax resident, or located in the United States, Russia, Belarus, Cuba, North Korea, Iran, Iraq, Syria, Sudan, Somalia or any UN-embargoed territory. Sanctions-listed people are also barred.
They process your data to screen for sanctions compliance and to detect fraud, money laundering and abuse, citing AML/CFT legal obligations. Records are kept for AML purposes for 5 years.
Your public offers, username, reputation score, trade statistics, account status and online indicator are visible to anyone, including people who are not logged in. You can reduce this by making offers private and changing profile settings.
Once a contract reaches "In Progress", your payment details become visible to the other trader. Chat messages and file attachments with counterparties are stored by the operator.
How the score was reached
Privacy48/100
Trust75/100
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.
Attributes14 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 introduce mandatory identity verification at any time, based on law or the operator's own internal policies.
“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.”
https://accounts.hodlhodl.com/terms-of-service
May suspend your accounttrust -4
The service reserves the right to suspend or limit access for violations or arrears.
The operator can suspend or limit access on grounds including suspected false information, unpaid investigation fees, inactivity, or a scam report from other users.
“We may terminate, suspend, or limit your access at our sole discretion if:”
https://accounts.hodlhodl.com/terms-of-service
Data sharingprivacy -3
Personal data may be shared with authorities or third-party providers for compliance.
Personal data may 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.”
https://accounts.hodlhodl.com/privacy-policy
Third party infrastructuretrust -1
Entirely on rented servers, so the infrastructure operator is an additional party to trust.
Personal data is stored on Amazon Web Services, a rented cloud infrastructure provider, so that operator is an extra party 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.”
https://accounts.hodlhodl.com/privacy-policy
Account requiredprivacy -1
An account has to be created to access and use the service.
Using the platform requires creating a user account.
“To access our Services you must create a User Account”
https://accounts.hodlhodl.com/terms-of-service
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.
Sign-up asks only for an email address, a nickname and a password; no name, address or phone number is required, and voluntary identity verification is no longer accepted.
“by providing a valid email address, nickname, and password. You must verify your email address before accessing the Platform.”
https://accounts.hodlhodl.com/terms-of-service
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 holding the Bitcoin until release.
“A unique P2SH multisig escrow address is automatically generated, requiring 2-of-3 keys to release funds.”
https://accounts.hodlhodl.com/terms-of-service
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 platform is an advertising board where users trade Bitcoin directly with each other rather than with the operator.
“Hodl Hodl allows Users to buy and sell Bitcoin directly with one another.”
https://accounts.hodlhodl.com/terms-of-service
Non-custodial protocoltrust +3
The protocol never takes custody of the user's funds during an exchange.
The operator holds one of three escrow keys and states it cannot move funds on its own; no clause in the trading terms lets it seize or freeze escrowed Bitcoin unilaterally.
“Hodlex Ltd holds only one key and cannot unilaterally move your funds.”
https://accounts.hodlhodl.com/terms-of-service
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
They can refuse access or close your account if they believe any information you gave is false, inaccurate or incomplete, with no explanation and no refund.
“We reserve the right to refuse access or terminate your account if we believe any information is false, inaccurate, or incomplete, without explanation or refund.”
https://accounts.hodlhodl.com/terms-of-service
If a trade goes to dispute, support can ask you for your full name, date of birth, citizenship, a government ID and bank or payment account statements.
“Identity data | In disputes: full name, date of birth, country of residence/citizenship, government-issued ID, and bank/payment account statements.”
https://accounts.hodlhodl.com/privacy-policy
They can suspend or limit your account for failing to supply requested documents on time, for 24 months of inactivity, or because one or more users reported you as a scammer.
“you fail to provide requested documents within a specified deadline;”
https://accounts.hodlhodl.com/terms-of-service
Hodl Hodl support rules on 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.”
https://accounts.hodlhodl.com/terms-of-service
For 'in person' payment trades they do not mediate. Locked Bitcoin only goes back to the Seller if both sides agree or the Seller signs the release themselves.
“Support does not mediate 'in person' payment method disputes. Bitcoin is returned to the Seller unless both parties explicitly agree otherwise, or the Seller independently signs a release transaction.”
https://accounts.hodlhodl.com/terms-of-service
They record your IP and MAC address, browser, operating system, hardware model, login times, API activity, chat logs and an approximate location taken from your IP.
“Log and usage data | Features used, offer creation, API activity, contract participation, login times and frequency, platform settings, performance logs, crash diagnostics.”
https://accounts.hodlhodl.com/privacy-policy
Account and trading data is kept 5 years after you close the account or last use it, ID documents 5 years, and technical access logs 12 months or longer during a security investigation.
“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.”
https://accounts.hodlhodl.com/privacy-policy
They can charge a fee based on staff time for investigations such as account restoration or 2FA resets, and unpaid fees can lead to account suspension or deduction from escrow.
“Investigation fees are payable by invoice or escrow deduction; outstanding Investigation Fees may result in account suspension.”
https://accounts.hodlhodl.com/terms-of-service
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