Overview

This document explains what Holders and the Holders SDK are, the value they bring to partners and users, and the core ideas and principles (non‑custodial, simple, secure) behind the Holders ecosystem.

What is Holders

Holders is a B2B platform that allows partners (wallets, banks, fintech companies) to quickly and easily integrate crypto-fiat payment functions for secure monetization of their audience without radical product transformation.
Holders provides clear documentation, expertise in traffic and security (including fraud protection and reputation protection), as well as full integration support. Holders SDK helps partners increase revenue, improve their service ratings and gives their users the ability to spend all their money through the partner’s application.
The solution is focused on revenue growth and capitalization (Equity) of partner services, providing end users with the ability to spend all their funds directly through the partner’s product, not just those already within the system.
Holders aims to:

• Become a trusted non-custodial financial partner for globally mobile affluent clients
• Provide superior customer service, high level of security and privacy in managing stablecoin assets — at a level exceeding existing custodial and non-custodial solutions
• Ensure seamless and reliable conversion between fiat and stablecoins through contracts adapted to relevant jurisdictions

Holders for Users

Holders is a solution that provides the simplest and most convenient use of stablecoins for making payments, transfers and opening vestings directly in the user’s mobile wallet through cards and accounts, while maintaining full control over assets and private keys.
Holders offers:

• Confidentiality and respect for client privacy
• Security of storage and transactions
• Expertise in international payments and taxation
• Fiat conversion through OTC channels (not P2P)
• Risk insurance and client fund protection
• Premium service and cards with cashbacks and privileges

Holders Mission

Holders’ mission is to unite people and companies from different countries and protect their right to decentralized accounts in digital dollars, allowing them to freely receive and send payments worldwide without discrimination, borders or banking restrictions.

Holders Philosophy

In ancient times, money could only be physical: hides, coins, paper. Everyone who had them owned them personally. People always wondered: how to preserve them? How to prevent their theft, seizure or loss in fire? Funds were stored in chests and treasuries, but more creative options were also invented: in beehives and fish carcasses, in coffins, in vessels with holy water. However, using money hidden in a fish carcass is inconvenient, and a chest can be broken into or carried away, and the money will still be lost.
Everything changed with the advent of banks. No longer need to hide money, it can be stored in a bank that takes responsibility for storage. Robbers began to carry away safes less often, and everyone has long forgotten about storing funds in chests. Bank cards allowed people to forget what cash looks like, and smartphone payments eliminated the need to use the cards themselves.
But with increased security and convenience, a new problem arose: people no longer own their money, now the bank owns it. The bank decides how much you can spend, where and to whom you can transfer. The bank can freeze funds at any moment and decide for itself whether to return them or not. The bank will independently transfer information about your balances, expenses and deposits to tax authorities.
But how not to lose all the conveniences that the bank provides while maintaining personal ownership of funds? Holders created a unique solution that allows simultaneously maintaining full personal control over money and using all modern conveniences of the banking system — non-custodial accounts based on smart contracts.

Architecture and Principles

Holders was built as a unified ecosystem — from storage and investments to payments and p2p transfers. All ecosystem products are based on unified principles:

• Non-custodial nature: users retain ownership of their keys and funds
• Simplicity instead of complex technologies: complex technical infrastructure is hidden behind intuitive interfaces
• Unified approach to user experience: common interface patterns, terminology and visual language
• Unified approach to security: common standards for key management and transaction monitoring

Holders SDK Target Audience

Businesses and applications with existing audiences seeking to integrate financial services and monetization: crypto wallets, banks (traditional and neo), content platforms (e.g., Fragment), fintech companies, Forex brokers, gaming platforms and other services working with digital values.

• High Net Worth Individuals (HNWI)
• “Digital nomads”
• Entrepreneurs and investors with assets and interests in different jurisdictions

Clients who need a flexible, confidential and jurisdiction-agnostic way to manage stablecoins, and who value privacy (“money loves silence”) combined with premium service level. The target audience includes not only HNWI without clear jurisdiction, but also client types described as “Global citizens”, “World citizens”, “Nomad Capitalists”.

Key Product Features

• Issuance of decentralized accounts for storing and sending funds
• Issuance of bank cards
• Making international payments
• Issuance of vesting accounts
• Top-up with multiple different stablecoins
• Simple integration into partner services
• Conducting user verification
• Adding cards to contactless payment systems

Positioning and Holders’ Place in the Whales Ecosystem

Holders is the “banking layer” of the Whales CORP ecosystem, which turns digital dollar into financial products understandable to everyone: accounts and cards.

• Financial core of the ecosystem. If Tonhub is the user entry into the world of digital assets, and TON Whales is the staking infrastructure, then Holders is responsible for making these assets usable as money: store in accounts, pay in stores, make transfers, receive salaries and payments from companies.
• Connecting link between blockchain and traditional payments. Holders connects smart contracts and stablecoins with Visa cards, bank transfers (SEPA/SWIFT) and Apple/Google Pay, while remaining non-custodial at the fund ownership level.
• Platform for partners. Through Holders, third-party wallets, banks and fintech projects can embed international digital dollar accounts and crypto cards into their products, using Whales CORP infrastructure instead of their own complex integrations.

Thus, Holders occupies a central place in the ecosystem: it makes digital dollar not only a store of value, but also a full-fledged payment instrument for people and companies worldwide.

Holders Monetization Model and Business Logic

Holders earns not from storing user funds or account top-ups, but from payment infrastructure around digital dollar:

• Card payments

Service commission is embedded in each card operation. The commission is fixed and amounts to 1.5% for operations in card currency and 3% for operations in other currencies.

• SEPA, SWIFT fees

Commissions for exchanges between stablecoins and fiat, withdrawals and separate payment scenarios (SEPA, SWIFT, etc.), while basic onboarding and storage remain free for users.

• Whales CORP ecosystem growth

The more users and partners use accounts and cards based on Holders, the higher the volumes of payments, exchanges and staking, which scales the entire holding’s revenue and strengthens the value of digital dollar as the main payment layer.

Legal Status and Privacy

Holders (operated by Walleexer s.r.o., Czech Republic) processes users’ personal data in accordance with GDPR and other applicable EU data protection laws.
In brief:

• Who is responsible for data

Data controller — Walleexer s.r.o. (Czech Republic). The company is responsible for data processing when using Holders websites, applications and services.

• What data is collected

Personal data that users provide themselves (name, contacts, address, document data, wallet/account details and payment data), as well as technical and transactional information automatically collected when using services (IP address, device/browser type, transaction data, activity logs). Additionally, some data may come from banks, payment partners, KYC/AML providers and public sources.

• What data is used for
  • providing and servicing services (account creation, wallet and account operations, support);
  • compliance with legal requirements (KYC/AML, sanctions, regulatory reporting);
  • fraud protection and security assurance;
  • analytics and product improvement;
  • marketing communications — only based on separate consent.
• Legal basis for processing

Processing is conducted based on:

• contract performance with the user;
• compliance with legal obligations (KYC/AML, reporting);
• legitimate interests of the company (security, fraud prevention, service improvement);
• user consent (e.g., marketing, specific partner integrations).
• Cookies and automatic processing

The website and application use cookies and similar technologies (functional, analytical, security). Some cookie processing is based on legitimate interest (service operation and security), some — on consent (analytics, marketing). Limited automatic analysis and decision-making (profiling) is possible for KYC/AML and anti-fraud purposes, with the user’s right to request manual review.

• Data transfer and storage

Data may be transferred to banks, payment providers, KYC/AML providers, auditors, regulators and other trusted partners strictly within the framework of contracts and law. Personal data is stored and processed in the EU/EEA; cross-border transfers outside the EEA — only with sufficient legal safeguards (standard contractual clauses, etc.).

• User rights
• Users have rights of access, rectification, erasure (subject to regulatory storage obligations), restriction of processing, data portability, objection to processing and withdrawal of consent, as well as the right to file a complaint with the data protection regulator.

Security and Audit

The project underwent comprehensive security assessment, including audit of Whales DMCC Holders smart contracts conducted by Trail of Bits in April 2025. A token evaluation policy was developed to ensure compliance with MiCA requirements and prevent work with anonymous assets.

Support and Channels

Support: https://help.holders.io/en/\\\\ Website: https://holders.io/\\\\ News channel: https://t.me/tonhub

History

2023

• Project launch (January 2023). Creation of B2B platform for payments between cryptocurrencies and regular money. Search for partners among financial companies.
• Filing documents with VISA to work with cryptocurrencies.

2024

• Interface simplification for regular users
• Release of first prepaid card with partner CardB.
• Receiving permission from VISA to work with cryptocurrencies.
• Launch of first decentralized account.
• Successful testing in Tonhub. Users began using USDT accounts in Tonhub (product based on Holders) instead of dollar accounts in banks, and wallets with Holders technology instead of digital banks.
• Testing international SEPA/SWIFT transfers with Triple A company.
• Obtaining certificates to work with Apple Pay and Google Pay.
• Launch of non-custodial cards with issuer Wallester and provider Kauri.finance (issuer Quicko)
• Adding support for Solana blockchain.

2025

• Connecting Changelly for top-up with all popular stablecoins.
• Business team and business approach reorganization
• Creation of Trust smart contract
• Beginning of artificial intelligence implementation in the project.

Holders logotypes

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