Cryptoasset Withdrawals (wallet-to-wallet transfer)

This document provides key precontractual information required under Regulation (EU) 2023/1114 (MiCA) for clients using the transfer services offered by the Company via the Platform. Please read this information carefully before initiating any transfer.

1.- Company information:

Legal Name: YouHodler Italy, S.r.l.

Registered Office: 20121 Milan, via del Lauro 9, Italy

Contact Details: support@youhodler.com 

VASP Registration Number: PSV58

Authorisation Status: The Company is duly authorised to operate as a Crypto-Asset Service Provider (CASP) under the MiCA framework. Further information can be found in the User Agreement, which clients must accept prior to accessing the Transfer Service.

2.- Supervisory Authority:

Competent Authority: Commissione Nazionale per la Società e la Borsa (CONSOB)

Address: Via G.B. Martini, 3, 00198 Rome, Italy

Website: www.consob.it

Contact Email: consob@consob.it

3.- Description of the Service:

Withdrawals of Cryptosset or wallet-to-wallet transfer are carried out through standard on-chain transfers over the native Layer 1 blockchain network corresponding to the specific Cryptoasset selected by the Client.

For example: (i) Bitcoin (BTC) withdrawals are processed via the Bitcoin mainnet which functions under a Proof of Work (PoW) consensus mechanism or BNB smart chain under a Proof of Stake Authority consensus algorithm; (ii) Ethereum (ETH) withdrawals are executed via the Ethereum mainnet, operating under a Proof of Stake (PoS) consensus mechanism.

Each withdrawal is initiated by the Client and transmitted directly to the destination blockchain address provided, without intermediaries, using the selected network protocol. The transaction must undergo validation by the nodes or validators of the relevant network, depending on the consensus model in place (e.g. PoS, PoW, etc.).

Key Considerations:

• Network Validation: All transactions are subject to confirmation by the blockchain. The number of confirmations required for finality may vary depending on the asset and network protocol.
  
• Execution Times: Settlement times are non-deterministic and may fluctuate based on network congestion, fee prioritization mechanisms, and the block production rate.
  
• Finality and Irreversibility: Once confirmed on-chain, withdrawals are irreversible and cannot be recalled or amended. Clients are responsible for ensuring the accuracy of the recipient address and the selected DLT network.
  
• Network Fees: Clients are informed of estimated network (gas) fees at the time of initiating the withdrawal. These fees are variable and determined by current market and network conditions. The fee is deducted from the client’s balance upon confirmation of the transaction.

Clients are advised to verify all transaction details prior to submission and to ensure compatibility of the receiving wallet with the selected blockchain network. The Company does not assume responsibility for losses arising from incorrect or incompatible wallet addresses, user error, or network-related delays, unless such issues result from gross negligence or technical failure attributable to the Company.

4.- Transfer Initiation and Consent Procedure:

Wallet-to-wallet transfers allow Clients to send Cryptoasset directly to another blockchain address using the native network of the Cryptoassett. These are the steps to be followed to execute this type of transfers:

1. Select Cryptoasset to be transferred: Clients must choose the type of Cryptoasset to be sent from the list displayed on the Platform, provided it is available in their portfolio. Beneath each of the Cryptoassets it is displayed the minimum applicable fees, which may vary depending on the conditions of each particular transfer and the type of Cryptoasset;. 
2. Select the available network: Once the Cryptoasset to be transferred has been selected, Clients must select the network among the ones available over which the transfer shall be executed. For instance: (i) for Bitcoin mainnet for BTC; (ii) Ethereum mainnet for ETH.
3. Set the amount: Clients must select the amount of Cryptoassets to be transferred and received. Underneath of this option appears the minimum amount it can be transferred, as well as the approximate time for its execution, which may vary from a few seconds to a few hours.
4. Recipient’s address: Clients must introduce the wallet address of the destination. Clients must ensure that the address introduced is accurate, as in most of the cases after confirming the instructions of the transfer, this will not be reversible.

After having introduced all the transfer parameters, Clients must:

1. 2FA: Clients are required to verify their identity and secure the transfer by introducing the authentication code, provided by the 2FA method, which must be priorly set up.
2. Check confirmation box: Clients are requested to verify the parameter introduced, by being requested to confirm that they duly verified the data. Clients have a summary of the information they introduced, the relevant applicable gas fees and estimation time for execution, so they can confirm all these parameters.
3. Send Button: After clicking on the send button, another window with the summary of the transaction will pop up, so Clients can finally confirm the parameters before sending.

5.- Conditions for Rejection:

The Company may reject or suspend a transaction under the following circumstances:

• Insufficient funds or Cryptoassets to execute the transfer;
• Incomplete or missing Travel Rule or KYC data;
• Incompatibility of destination wallet or network;
• AML/CTF or sanctions screening alerts;
• Technical failure (e.g., Lightning liquidity failure, chain reorg);
• Non-compliance with applicable terms and conditions.

6.- Execution Timeframe and Finality:

The execution of wallet-to-wallet transfers occurs directly on the Layer 1 blockchain of the selected Cryptoasset (e.g. Bitcoin, Ethereum). As a result, the timing depends entirely on the performance of the blockchain network at the moment of the transfer.

• Execution Time: Transfers may take anywhere from a few minutes to a few hours. Factors such as network congestion, block time, and transaction fees all influence how quickly the transfer is confirmed.
  
• Cut-Off Times: There are no formal cut-off times. Transfers can be initiated and processed 24/7, including weekends and holidays. However, blockchain congestion or unusually low fees may cause delays.
  
• Finality: Finality is achieved once the transaction has received a sufficient number of network confirmations, making it extremely unlikely to be reversed or modified. Although the finality shall depend on the relevant consensus system applicable in each network, transfers are meant to be irreversible when transactions have been executed according to the parameters introduced by the Client. 

Clients are reminded to always verify the destination address, Cryptoasset type, and network before confirming a wallet-to-wallet transfer, as errors cannot be corrected once finality is reached.

7.- Detailed Fee Structure:

At their request, Clients shall be presented with a clear fee breakdown with components if the fees paid. It must be noted that withdrawals have not more fees than the ones of the relevant network, as indicated in the chart  below:
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8.- Communication Methods and Technical Specifications:

The Company communicates with Clients through secure and user-friendly digital channels, including:

• A secure web-based portal and mobile applications (iOS and Android);
• Email and in-app messaging for notifications and updates.

All communications are protected using TLS encryption, and sensitive actions are safeguarded with two-factor authentication (2FA) and IP/device monitoring.

Transaction records and audit logs are available in structured formats, such as CSV, and confirmations are provided in PDF format for easy access and storage.

9.- Language and Contractual Communications:

All contractual and operational documentation is provided in both English and Italian, depending on the selected language preference of the Client.

Documents are delivered in durable electronic format, including PDF and HTML, and remain accessible throughout the duration of the relationship of the Client with the Company.

Clients may request access to this information at any time. Any updates or changes to the content of these documents will be communicated to the Client in advance of their implementation, in accordance with applicable legal and regulatory requirements.

10.- Security and Fraud Alerts:

At YouHodler Italy, your security is our top priority, especially when you’re sending crypto directly from your wallet to an external one using the blockchain protocols corresponding to such a crypto, such as, but not limited to Bitcoin, Ethereum, or Litecoin. Here’s how we protect your wallet-to-wallet transfers and account activity.

How Wallet-to-Wallet Transfers Work Securely

When you send a cryptoasset from your YouHodler wallet to another wallet, the transaction is processed through the underlying blockchain network for that specific asset (also known as a Layer 1 network). These public blockchains, such as Bitcoin or Ethereum, are decentralized, meaning they are not controlled by any single party. They use powerful security features like:

• Proof-of-Work or Proof-of-Stake validation, to ensure that only legitimate transactions are confirmed;
• Cryptographic signatures and wallet addresses, to prevent tampering and unauthorized changes;
• Immutable transaction records, so once a transfer is confirmed, it cannot be altered;
• Public transparency, which allows anyone to independently verify your transaction.

How We Keep Your Transfers Safe

To complement the security of blockchain technology, YouHodler adds extra protections on its own platform to ensure that your transfers are reliable and secure:

• We use a hybrid custody system, combining hot wallets for fast transactions with cold wallets for offline protection of long-term assets.
• We partner with industry-leading security providers like Ledger Vault and Fireblocks to manage private keys and approve transactions securely.
• Our internal risk and vault system checks each transaction using multi-step approval rules and routes transfers based on risk level.
• We monitor the system in real time, flagging issues such as:
  
  • Failed or repeated routing attempts;
  • Suspicious login attempts;
  • Delays in blockchain confirmations.

• Encrypted communication: All communication between you and our platform is encrypted using TLS/SSL protocols, protecting your data from interception or fraud.
• Security Alerts: If anything unusual happens, like an unauthorized login or a failed transfer,you’ll receive an immediate notification.

Your Role in Security: Authentication Options

We give you tools to help protect your account and authorize transfers securely:

• Two-Factor Authentication (2FA) is required for all sensitive actions, including withdrawals. You can set it up using SMS, email, or an authenticator app.
• Three-Factor Authentication (3FA) is an optional setting that lets you lock outgoing transfers. To unlock them, you’ll complete an extra identity check.
• Biometric login, like facial or fingerprint recognition, is available on supported devices for additional security.
• You can customize how you receive security alerts—by email, app notification, or SMS—so you’re always informed.

Built by Experts, Compliant by Design

Our security is also backed by a dedicated team of experts. Our Chief Information Security Officer (CISO), Head of Risk, and Chief Compliance Officer, and their respective teams, work together to oversee the systems and ensure they meet the highest regulatory and safety standards. We regularly test and update our protections to meet the highest legal, regulatory, and cybersecurity standards.

11.- Right to Terminate:

The Client may terminate the agreement with the Company at any time by following the steps below:

• Submitting a request for account closure through the Platform or via official support channels;
• Withdrawing any remaining crypto-assets or fiat balances from the account;
• Receiving confirmation from the Company that the account has been closed, following the completion of all necessary compliance checks.

Any obligations incurred prior to the effective date of termination,  including pending transactions, outstanding fees, or regulatory reporting duties, shall remain valid and enforceable after account closure.

12.- Reporting Unauthorized or Erroneous Transfers:

If a Client believes that a transfer was made without proper authorization or that something went wrong with the transaction, the issue should be reported as soon as possible, and no later than thirty (30) calendar days from the date the transaction receipt is issued or the activity appears in the Client’s account.

Reports can be submitted by filling the relevant form available here: https://www.youhodler.eu/complaint. Upon receiving a report, the Company will investigate the matter and provide a clear explanation of the outcome.

13.- Company’s Liability:

We are responsible for carrying out your transfer exactly as you request it. This means using the address, asset type, network, and amount you enter. If we process it correctly, we are not liable for any losses caused by: (i) Mistyped wallet addresses; (ii) Choosing the wrong blockchain network; and/or (iii) Sending to an unsupported or fraudulent wallet. Always double-check the details before confirming a transfer.

If a transfer fails or causes a loss, we will only be responsible if the problem was clearly and demonstrably caused by us, for example:

• A serious internal error (like processing a transfer with clearly conflicting instructions);
• A failure of our systems or technical infrastructure which is under our control;
• A mistake due to not applying required security or compliance checks.

If this happens, we will act quickly to correct the issue. This may include reversing the transfer (if technically possible) or reimbursing the value of the cryptoasset lost.

However, we are not responsible for issues beyond our control, including but not limited to:

• Problems with the blockchain network (delays, forks, bugs);
• Failures of third-party wallet providers or custody partners;
• Force majeure events (e.g., natural disasters or systemic failures).

If we acted in good faith and followed all required rules, and the loss occurred for reasons outside of our service, we cannot be held liable.

Even when liability applies, our responsibility is limited to the market value of the cryptoasset on the date of the loss.