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Z.com EX - Buy/Sell Bitcoin

Latest release: 2.0.4 ( 15th January 2023 ) 🔍 Last analysed 8th November 2021 . Custodial: The provider holds the keys
4.3 ★★★★★
82 ratings
5 thousand
7th August 2020

As the provider of this product holds the keys, verifiability of the product is not relevant to the security of the funds!

As part of our Methodology, we ask:

Is the product self-custodial?

If the answer is "no", we mark it as "Custodial: The provider holds the keys".

A custodial service is a service where the funds are held by a third party like the provider. The custodial service can at any point steal all the funds of all the users at their discretion. Our investigations stop there.

Some services might claim their setup is super secure, that they don’t actually have access to the funds, or that the access is shared between multiple parties. For our evaluation of it being a wallet, these details are irrelevant. They might be a trustworthy Bitcoin bank and they might be a better fit for certain users than being your own bank but our investigation still stops there as we are only interested in wallets.

Products that claim to be non-custodial but feature custodial accounts without very clearly marking those as custodial are also considered “custodial” as a whole to avoid misguiding users that follow our assessment.

This verdict means that the provider might or might not publish source code and maybe it is even possible to reproduce the build from the source code but as it is custodial, the provider already has control over the funds, so it is not a wallet where you would be in exclusive control of your funds.

We have to acknowledge that a huge majority of Bitcoiners are currently using custodial Bitcoin banks. If you do, please:

  • Do your own research if the provider is trust-worthy!
  • Check if you know at least enough about them so you can sue them when you have to!
  • Check if the provider is under a jurisdiction that will allow them to release your funds when you need them?
  • Check if the provider is taking security measures proportional to the amount of funds secured? If they have a million users and don’t use cold storage, that hot wallet is a million times more valuable for hackers to attack. A million times more effort will be taken by hackers to infiltrate their security systems.
The product cannot be independently verified. If the provider puts your funds at risk on purpose or by accident, you will probably not know about the issue before people start losing money. If the provider is more criminally inclined he might have collected all the backups of all the wallets, ready to be emptied at the press of a button. The product might have a formidable track record but out of distress or change in management turns out to be evil from some point on, with nobody outside ever knowing before it is too late.

Help spread awareness for build reproducibility

Please help us spread the word discussing the risks of centralized custodians with Z.com EX - Buy/Sell Bitcoin  via their Twitter!

Do your own research!

Try out searching for "lost bitcoins", "stole my money" or "scammers" together with the wallet's name, even if you think the wallet is generally trustworthy. For all the bigger wallets you will find accusations. Make sure you understand why they were made and if you are comfortable with the provider's reaction.

If you find something we should include, you can create an issue or edit this analysis yourself and create a merge request for your changes.

The Analysis 

App Description

Z.com EX is a cryptocurrency exchange platform.

Here’s what you can expect:

  • Trade: buy, sell, and exchange cryptocurrency
    We offer competitive pricing in liquidity market which the most powerful exchange platforms. You can enjoy real-time balance updates and notifications anytime, anywhere straight from your phone.

The Site

Terms of Conditions, section 18:

We may, in our discretion and without liability to you, with or without prior notice, suspend or terminate your access to all or a portion of our Services, terminate the agreement between you and Z.com Ex entered into in accordance with these Terms, and delete or deactivate your Z.com Ex Account and all related information and files in such account in any of the following events:[…]

In the homepage, the exchange advertises a “high level of protection.”

As part of our financial platforms, Z.com EX is compliant with the most recent and stringent security standards. Our products are regularly tested to ensure customer assets and their personal data remain safe at all time.

The App

The user may add a bank account to this app. It is mandatory to complete KYC verification to deposit/withdraw.

Nothing on the app indicates that you can export private keys.


This is a custodial app and thus not verifiable.