Acceptable Use Policy
September 14, 2023
About
The crypto asset ecosystem is made up of a wide range of people with diverse backgrounds and circumstances, which we value and regard as a great asset. As part of our continued commitment to equality, diversity and inclusion, we strive to create an inclusive environment in which all members of our community should expect to be able to thrive, be respected and have a real opportunity to participate in and contribute to webot.com/eu products and services so that they can achieve their fullest potential.
Users are expected to ensure usage of webot.com/eu is carried out in an acceptable, safe, respectful and legally compliant manner.
The purpose of this Policy is to provide all those who use webot.com/eu with clear guidance on the acceptable, safe, respectful and legal way in which they can use the Pionew Ireland’s Resources.
This Policy is designed to ensure that Pionew Europe can offer the widest possible range of crypto asset systems and network resources to our community in a way that is compliant with data security and data protection and is not intended to limit use of Pionew Europe’s information services.
Country/Territories
Customers who are domiciled or registered in the following countries and territories are prohibited. Customers with beneficial owners in these countries and territories are also prohibited.
| ISO Country Name | ISO Country Name |
| Afghanistan | Lebanon |
| Antarctica | Libya |
| Belarus | Mali |
| Bosnia and Herzegovina | Myanmar (Burma) |
| Bouvet Island | Nicaragua |
| British Indian Ocean Territory | Pakistan |
| Burundi | Palestine |
| Central African Republic | Russia |
| Congo, Democratic Republic of the | Somalia |
| Cuba | South Georgia and South Sandwich Islands |
| Ethiopia | South Sudan |
| French Southern and Antarctic Lands | Sudan |
| Guinea | Syria |
| Guinea-Bissau | Tunisia |
| Haiti | Turkey |
| Heard Island and McDonald Islands | Ukraina |
| Hong Kong | United States Minor Outlying Islands (Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Palmyra Atoll, Wake Island and Navassa Island). |
| Iran | Venezuela |
| Iraq | Yemen |
| Korea, Democratic People’s Republic (North Korea) | Zimbabwe |
Industry Risk
Pionew Europe offers to provide Virtual Asset Services only to customers that are adequately registered, regulated (where applicable) and operating within the confines of the legislative framework according to the requirements of the countries that they are registered in or operating in. Pionew Europe must adhere to the following lists of Prohibited Industries.
| Industry Sector | Industry Sector |
| The creation, facilitation, sale or distribution of adult content, including, but not limited to, online dating or marriage services, pornographic services and goods, adult entertainment related activities | Non-licenced counselling centres |
| Bail bondsman/bailiff services | Nutraceuticals |
| Cash-like products, e.g. manufacture or distribution of prepaid cards | Offensive goods related to crime, e.g. photographic memorabilia |
| CBD/marijuana dispensaries | Pay-day lenders |
| Chemicals sale or distribution | Pyramid schemes/Multi-level marketing |
| Copyright media and software | Pyrotechnic devices and hazardous materials, eg fireworks, explosives toxic/flammable goods |
| Counterfeit goods | Regulated and Unregulated financial service companies |
| Drug-related paraphernalia merchants | The financing the production, facilitation, sale or distribution of firearms or other weapons, military or semi-military goods, military software or technologies. |
| Escort or prostitution agencies | Skins/loot box trading |
| Fortune tellers, tarot card and horoscope readers, psychics | Timeshare |
| Gambling businesses, casinos and equivalent enterprises | Tobacco & Electronic Cigarettes |
| Get rich quick schemes | Unlicenced lawyers or legal services |
| Human body parts or human cloning for reproduction purposes | Unlicenced Liquor Sales |
| Illegal telecommunications devices | Unlicenced pharmaceuticals |
| Illegal, Inappropriate or Offensive Items or Activities or products that are not safe | Research, development or technical applications relating to electronic data programs or solutions |
| The creation, facilitation, sale or distribution of any prohibited or illegal good or service or an activity that requires a governmental licence where the customer lacks such a licence; | |
Formation Types
The following list outlines the business types that Pionew Europe will not accept as customers:
| FORMATION TYPE | RISK CATEGORY |
| Pending incorporation or legal registration | Prohibited |
| An unregistered private partnership | Prohibited |
| A holding company for a private individual | Prohibited |
| Unregistered charities | Prohibited |
| A company with bearer shares | Prohibited |
| Unregistered Foundations | Prohibited |
| Dormant entity | Prohibited |
| Struck Off or In Liquidation/Receivership | Prohibited |
Pionew Europe will facilitate discussions with companies going through incorporation or legal registration but will not be able to contract or serve those companies until the incorporation or legal registrations are complete.
The following list outlines the business types that Pionew Europe considers to be High Risk and a determinative factor in the overall customer risk rating:
| FORMATION TYPE | RISK CATEGORY |
| Limited Partnerships / Limited Liability Partnerships | High Risk |
| Registered Charity or Foundations | High Risk |
| Trusts | High Risk |
| Foundations | High Risk |
Exceptions
Any exceptions to this Policy must be referred to the Chief Compliance Officer EMEA for review and approval in writing.
Breaches / Non-Compliance
All users are expected to comply with this Policy at all times.
It is the responsibility of all relevant Pionew Europe Directors and Employees to carefully review and follow the requirements of this Policy, Compliance Manuals and any other Compliance Notices or policy and procedural memoranda that may be issued from time to time. Ultimately, it is the responsibility of each Employee to be aware of and to comply with all applicable laws, regulations, rules and internal policies. Any violation of this Policy or related policies or procedures will be regarded as a serious matter which may result in disciplinary action, up to and including dismissal.
Failure to comply with the relevant requirements may also result in a fine for Pionew Europe, its Directors and Employees and/or imprisonment for Directors and Employees.
03-POL-PEU-085/v1.0