UMA Transfer

This document gives you important information you should know before using the Universal Money Address (“UMA”) Service offered by YouHodler through its platform. It is provided in accordance with Regulation (EU) 2023/1114 (MiCA). Please read it carefully before starting any UMA transfer.

1.- About the Company:

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.- Our 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.- What is the UMA Transfer Service:

UMA is a fast and secure way to send crypto or fiat between platforms that support UMA. The actual transfer is carried out using the Bitcoin Lightning Network, which only uses Bitcoin (BTC) to settle the transfer. You can send another crypto or fiat, you do not need to own BTC yourself. We will convert your selected asset into BTC, send it through the Lightning Network, and the receiving platform will convert it into the recipient’s chosen asset.
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Key Points to Know:

• BTC Routing: Regardless of the input or output asset, the actual transfer is conducted entirely in BTC over the Lightning Network. Conversion steps occur at both the initiation and settlement ends of the transaction.
• Fast Settlement: Most UMA transfers are completed in seconds, thanks to the speed of the Lightning Network. This depends on the availability of liquidity and the receiver’s platform being UMA-compatible.
• Conversion Risks: The Company uses real-time rates for internal asset conversion. Clients are informed of the exact amount to be received depending on the amount sent, as well as all the applicable fees both for conversion and transfer of the assets (gas fees), prior to final confirmation.
• Finality & Irreversibility: Once a UMA transfer is sent through the Lightning Network, it cannot be reversed. Please double-check the recipient’s UMA address and ensure their platform supports UMA before sending. If it does not support UMA Network, then transactions shall not be executed.
• Fees: UMA transfers may include:
  
  • A conversion fee, if the asset sent differs from BTC (even if it is showed conversion fees for this last case, it is referred to gas fees);
  • Payer Fee (when Fiat payment is involved);
  • gas/network fee, normally in this case for the transfer executed via Bitcoin Lightning Network.

4.- How UMA works:

Using UMA is simple, secure, and fast. Here's how it works:

1. Clients’ UMA Address: When you accept the terms and conditions of UMA service, Clients are given a personal UMA address (e.g. $yourname@youhodler.com), which shall be used to send and receive Cryptoassets or Fiat through the UMA network.
2. Choose what to send: To start a transfer, Clients must select one of the Cryptoassets or Fiat available in their portfolio. Beneath each option, it is clearly displayed the fees which apply to that transfer. They may be a fixed amount or a percentage over the amount being transferred.
3. Enter the Recipient’s UMA address: Input the UMA address of the person to whom assets are to be sent. Clients must make sure the receiving platform (CASP) also supports UMA, otherwise the transfer cannot be executed by the UMA network (see wallet-to-wallet transfer system).
4. Set the Amount and Asset: Clients must then introduce the type and amount of Cryptoassets or Fiat they want to send and the type and amount of Cryptoassets or Fiat to be received by the recipient. The one to be received by the recipient can be in a different Cryptoasset or Fiat, depending on what their platform supports.
5. Review All the Details: Before confirming the transfer, the Client will be shown a full summary of the transfer details, so they can double-check the accuracy and correctness.

• Recipient’s UMA address;
• Total fees;
• Crypto or Fiat to be sent;
• Crypto or Fiat the recipient will receive.

6. Confirmation: Once the transfer details are reviewed, Client must confirm the transaction. To that end, Clients must: (i) check a box confirming they have reviewed the details of the transaction; (ii) confirm their identity by introducing the code provided by the two-factor authentication (2FA) method; (iii) click the button send. This system helps Clients to protect their account and gives them full control 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:

UMA transfers are designed to be fast, efficient, and nearly instant, thanks to the use of the Bitcoin Lightning Network, a Layer 2 solution that operates off-chain.

• Execution Time: Once initiated, UMA transfers are typically executed in around 5 seconds, depending on Lightning Network routing conditions and internal processing. Because UMA transfers avoid the delays of traditional on-chain validation, they provide near real-time settlement.
  
• Cut-Off Times: UMA transfers are available 24/7, with no cut-off times. Clients can send assets at any time of day, including weekends and holidays. However, underlying blockchain factors (e.g., congestion during initial conversion from Crypto or Fiat to BTC) may affect the speed of asset conversion at either end of the transfer.
  
• Finality: Once the BTC is successfully routed through the Lightning Network and reaches the receiving CASP, the transfer is considered final. From that point, it cannot be reversed.

Clients should be aware that conversion issues at the start or end of the transaction (e.g. converting from BTC to the recipient’s desired asset) may occasionally introduce processing complexity, but once the BTC has been routed and settled, the transfer is irreversible.
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Clients are reminded to verify the UMA address of the recipient is accurate, and that their platform supports UMA transfers. Once confirmed and routed, UMA transfers cannot be cancelled or modified.

7.- Detailed Fee Structure:

At their request, Clients shall be presented with a clear fee breakdown with components including:
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The relevant applicable conversion fees are available and easily accessible from the Client’s account. At the time of execution or at a later stage, Client can request a breakdown of the fees charged in each transaction.

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.
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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 Client’s selected language preference.
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Documents are delivered in durable electronic format, including PDF and HTML, and remain accessible throughout the duration of the Client’s relationship with the Company.
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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 it comes to transferring assets using the Universal Money Address (UMA) service. Here’s how we protect your UMA transactions and account activity:
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How UMA Transfers Work Securely:
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UMA transfers are processed through the Bitcoin Lightning Network, a fast and secure technology that helps move Bitcoin across different platforms almost instantly. This network uses advanced protections like hashed time-locked contracts (HTLCs) to make sure transfers either go through completely or not at all, so your assets are never stuck. It also uses onion routing, a privacy feature that hides your transfer path to protect your identity. UMA is an open-source standard, meaning it is reviewed by experts and built to work securely across different providers.

How We Keep Your Transfers Safe:

In addition to the protections built into UMA and Lightning, our Company adds an extra layer of security through our own systems. We use a combination of hot and cold wallets, so we can process transfers in real time, while also keeping stored assets safe offline. We work with industry-leading security providers to manage keys and approve transactions safely. We also have real-time monitoring tools that check for anything unusual, like failed transfers, delayed confirmations, or unauthorized access. Everything you do on our platform is protected by encrypted communication, and we’ll notify you immediately if we detect suspicious activity.
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Your Role in Security: Authentication Options:
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To help you stay in control of your account, we provide several secure login and transaction confirmation methods:

• Two-Factor Authentication (2FA) is required for all sensitive operations. You can set it up using SMS, email, or an authenticator app.
• Three-Factor Authentication (3FA) is an optional feature that lets you lock your withdrawals, including UMA transfers, until you complete an extra identity check.
• Biometric login—like face or fingerprint recognition—is available on supported devices for added convenience and protection.

You can also customize how you receive alerts, by email, app notification, or text, so you are always aware of what is happening on your account.
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These tools and systems work together to make sure your UMA transfers are safe, reliable, and compliant with all applicable laws and regulations.

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:

You may terminate the Transfer Service 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.
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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.
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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.
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However, we are not responsible for issues beyond our control, including but not limited:

• Problems with the blockchain network or bitcoin lightning 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.
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Even when liability applies, our responsibility is limited to the market value of the cryptoasset on the date of the loss.