Privacy Notice

Last updated: 21st May 2026

BHODL plc
19-21 Circular Road
Douglas, IM1 1AF
Isle of Man

This Privacy Notice explains how B HODL Plc ("we", "us", "our") collects, uses, and protects information in connection with your use of this Site. We are the data controller for any personal data processed through this Site and we process it in accordance with the Isle of Man Data Protection Act 2018 and the General Data Protection Regulation as applied in the Isle of Man.

This Site is designed to collect as little information as possible. You do not need to create an account or provide identity documents to use it, and we do not collect your name, identity documents, or any information beyond what is described in this Notice.

The only information we require is the technical information needed to open a Lightning Network channel. You may also choose to provide an email address, but this is optional.

1. What We Collect and Why

1.1 Information You Provide

To use this Site you provide the following:

• Lightning Network node public key – to open a channel to your node.
• Node connection details (IP address and/or Tor address) – to establish the channel connection.
• Bitcoin refund address – used only if a refund is due under the protocol following a failed channel opening. It is not retained beyond that purpose.
• Email address (optional) – if you choose to provide it, we will use it only to send you service-related communications such as confirmations and updates relating to your channel. We will not use it for unsolicited marketing without your separate consent.

The technical information above is processed because it is necessary to provide the service you have requested.

1.2 Technical Data

When you visit this Site, our server may record standard technical data including your IP address, browser type, pages visited, and the time of your visit. This is processed on the basis of our legitimate interests in maintaining and securing the Site, and is retained only for as long as it is operationally needed for those purposes.

1.3 Payment Routing Metadata

Our Lightning Network node may have visibility of payment routing metadata associated with transactions routed through your channel including payment amounts, payment hashes, and transaction timing. This is a feature of how the Lightning Network operates.

We do not use this metadata to identify you and do not share it with third parties except where required by law.

1.4 Cookies et al

This Site may use cookies or similar technologies to enable it to function correctly. Any cookies we use are strictly necessary for the operation of the Site and do not track your activity across other websites or build profiles of your behaviour.

2. Legal Basis for Processing

We process your information on the following bases:

• Performance of a service: node public key, connection details, and refund address are processed because they are necessary to provide the service you have requested.
• Consent: your email address, if provided, is processed on the basis of your consent. You may withdraw consent at any time by contacting us.
• Legitimate interests: technical data is processed on the basis of our legitimate interests in maintaining and securing the Site.
• Legal obligation: we may process data where required to comply with applicable law, including Isle of Man AML and financial crime legislation.
• Retention requirements: where applicable law requires us to retain information for a defined period, including Isle of Man anti-money laundering and proceeds of crime legislation, which currently requires retention for five (5) years following the end of a business relationship, we retain it for that minimum mandatory period and delete it promptly on expiry.
• Legitimate interests: payment routing metadata (as described in Clause 1.3) is processed on the basis of our legitimate interests in the operation and integrity of our Lightning Network node infrastructure.

3. How Long We Keep Your Data

We retain information only for as long as it is operationally needed for the purpose for which it was collected.

Once a channel has closed and any outstanding service queries have been resolved, we have no operational need to retain your service information and it is deleted.

Your email address, if provided, is retained for as long as you consent to receiving communications from us. You may withdraw consent at any time by contacting us.

Where applicable law requires us to retain information for a defined period (for example for financial crime prevention or regulatory compliance purposes) we retain it for the minimum period required by law, after which it is deleted.

4. Who We Share Your Data With

We do not share your personal data with third parties for commercial purposes. We may share information only in the following circumstances:

• with technology and infrastructure providers strictly necessary for the operation of this Site, under contractual confidentiality obligations;
• with law enforcement, regulators, or government bodies where required by law or court order, including the Isle of Man Constabulary and the Isle of Man Financial Intelligence Unit; and
• where necessary to protect our legal rights or to prevent fraud or illegal activity.

We do not transfer personal data outside the Isle of Man or the United Kingdom except where necessary for the operation of our node infrastructure, with appropriate safeguards in place.

Where transfers outside the Isle of Man or UK occur, we shall ensure appropriate safeguards are in place in accordance with applicable data protection law, including by relying on adequacy decisions where available, or by entering into standard contractual clauses approved by the relevant supervisory authority.

5. Your Rights

Under applicable data protection law you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• request erasure of your data where it is no longer needed;
• withdraw consent to email communications at any time;
• receive a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format, and to request that we transmit it directly to another controller where technically feasible;
• restrict or object to processing in certain circumstances; and
• lodge a complaint with the Isle of Man Information Commissioner at www.inforights.im .

Given the minimal data we collect, your ability to exercise some rights may be limited in practice.

For example, we may not be able to identify you from a node public key alone without additional information from you.

To exercise any of these rights, please contact us using the details on this Site and as set out above.

6. Automated Processing

The process by which we open a Lightning Network channel following receipt of confirmed payment is automated.

Once payment is confirmed, the channel is opened by our systems without individual human review of each transaction.

This automated process is necessary for the performance of the service you have requested and does not produce legal effects or otherwise significantly affect you beyond the opening of the channel itself.

We do not carry out profiling of our users for any purpose.

7. Security

We apply appropriate technical and organisational measures to protect the information we hold.

No internet transmission is entirely secure and we cannot guarantee the absolute security of data transmitted to or from this Site.

If you become aware of any security concerns in connection with this Site, please contact us immediately.

8. Changes to This Notice

We may update this Privacy Notice at any time by publishing a revised version on this Site with an updated effective date.

It is your responsibility to check this Notice periodically. Continued use of this Site following any update constitutes acceptance of the revised Notice.

9. Contact

If you have questions about this Notice, wish to exercise your rights, or wish to withdraw consent to email communications, please contact us using the contact details published on this Site.

We will respond within thirty (30) calendar days.