Webot EEA Risk Disclaimer
Risk Warning. Crypto-Assets are highly volatile, high-risk assets. Their value can fluctuate significantly, and you may lose all of the funds you invest. Crypto-Assets held with Pionew Ireland Limited are not covered by any deposit guarantee scheme or investor compensation scheme administered by the Central Bank of Ireland or by any other Member State scheme. Past performance is not a reliable indicator of future results. Before using the Services, you should carefully consider whether they are suitable for you in light of your knowledge, experience, financial situation, and investment objectives. If you are in any doubt, you should obtain independent professional advice.
1. About this Risk Disclaimer
This document (the “Risk Disclaimer”) sets out important information about the risks of trading and holding Crypto-Assets through the Webot Platform operated by Pionew Ireland Limited (“Pionew”, “Webot”, “we”, “our” or “us”). It forms part of, and must be read together with, our Terms of Service, Privacy Policy, Fee Schedule, Order Execution Policy, Conflicts of Interest Policy, and Complaints Handling Policy, each of which is published on the Platform.
By accessing the Platform at www.webot.com/eu or our mobile application (collectively, the “Platform”), and by using any of the Crypto-Asset Services, you confirm that you have read this Risk Disclaimer and that you understand and accept the risks described in it. If you do not understand or do not accept these risks, you must not use the Platform or the Services.
This Risk Disclaimer is provided in plain language, on a durable medium and free of charge, in accordance with Article 81 of Regulation (EU) 2023/1114 (“MiCA”) and the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004. References in this Risk Disclaimer to “you” or “your” mean you personally and, where applicable, any person on whose behalf you are accessing the Platform with our prior permission.
We may amend this Risk Disclaimer from time to time to reflect changes in our Services, technology, applicable law, or regulatory requirements. Where amendments materially affect your rights, we will provide you with at least thirty (30) days’ advance notice through the Platform or to your registered email address before the changes take effect.
2. About Pionew Ireland Limited
The Platform is operated by Pionew Ireland Limited, a private limited company incorporated in Ireland with its registered office and principal place of business at:
Pionew Ireland Limited
Office 01, Ground Floor, Penrose Two, Penrose Dock
Cork, Ireland T23 YY09
Pionew is authorised by the Central Bank of Ireland as a Crypto-Asset Service Provider under MiCA. Our authorisation can be verified on the Central Bank of Ireland’s public register at www.centralbank.ie. Apart from our authorisation as a Crypto-Asset Service Provider, Pionew is not licensed in any jurisdiction as a credit institution, investment firm, broker, financial adviser, investment adviser, portfolio manager, or tax adviser, and we do not hold any other financial-services authorisation in Ireland or elsewhere.
The Platform is made available on a cross-border basis to residents of certain EEA Member States, as authorised by the Central Bank of Ireland. A current list of eligible jurisdictions is published on the Platform.
3. Eligibility and prohibited jurisdictions
The Platform is intended for use only by adults (18 years and over) who are legally permitted to access Crypto-Asset Services in their jurisdiction. The Platform is not directed at, nor intended to be distributed to, accessed or used by, any person resident in or accessing the Platform from any prohibited jurisdiction (as set out in the Terms of Service), including, without limitation, jurisdictions subject to comprehensive EU or other applicable sanctions regimes (which currently include, among others, Russia, Belarus, Cuba, Iran, North Korea and Syria, as well as the non-government-controlled areas of certain Ukrainian regions).
It may be unlawful for you to access or use the Platform in certain jurisdictions. To the maximum extent permitted by law, we disclaim all responsibility if you access or use the Platform in breach of any law or regulation of the jurisdiction in which you reside or are then present. By accessing the Platform, you represent and warrant that the laws and regulations applicable to you permit you to do so.
4. Nature of the Services and “no advice”
Through the Platform, Pionew provides Crypto-Asset Services within the meaning of MiCA, namely: (i) custody and administration of Crypto-Assets on behalf of clients; (ii) operation of a trading platform for Crypto-Assets; (iii) exchange of Crypto-Assets for Fiat Currency and for other Crypto-Assets; (iv) execution of Orders for Crypto-Assets on behalf of clients; (v) reception and transmission of Orders for Crypto-Assets on behalf of clients; and (vi) provision of transfer services for Crypto-Assets on behalf of clients.
We do not provide investment advice, portfolio management, placing of Crypto-Assets, margin trading, derivatives, lending, borrowing, staking-as-a-service, or any other Crypto-Asset Service that is outside the scope described above. Nothing on the Platform constitutes a personal recommendation, investment, legal, tax, or other advice. The Platform contents and any market commentary, research, educational material, price information, or product description are provided for general information only, on an arm’s-length and execution-only basis.
We make no representation or warranty that any Crypto-Asset, transaction, or trading strategy is suitable or appropriate for you. You are solely responsible for your trading and investment decisions. Before transacting, you should carefully consider the relevant Crypto-Asset white paper (where available), our Terms of Service, the Fee Schedule, this Risk Disclaimer, and any other risk information published on the Platform, and you should obtain independent professional advice as necessary.
Nothing in this Section 4 excludes any liability that cannot be excluded under applicable EU or Irish law, in particular MiCA, EU consumer protection law, and Irish consumer protection law (including the Consumer Protection Code issued by the Central Bank of Ireland).
5. Risks of trading and holding Crypto-Assets
Crypto-Assets are a relatively new and rapidly evolving asset class based on emerging technologies. The risks below are not exhaustive: there may be other risks that we cannot reasonably anticipate, and known risks may materialise in unexpected ways or in combination.
5.1 Market and price volatility risk
The market price of Crypto-Assets may rise or fall sharply in a short period of time. The price may be affected by, among other things, market sentiment, macroeconomic conditions, regulatory developments, project-specific events, issuer or sponsor activity, network developments, whale or large-holder activity, liquidity conditions, and the actions of other Crypto-Asset Service Providers. There is no central authority that maintains the price of any Crypto-Asset. You should only acquire Crypto-Assets if you are willing and able to bear the risk of losing the entire amount you invest.
5.2 Liquidity risk
Some Crypto-Assets have low or intermittent trading volumes. There may be times when you cannot buy, sell, or transfer a Crypto-Asset at the price or in the quantity you want, or at all. Liquidity may deteriorate suddenly, particularly during periods of stress or in response to news or regulatory action.
5.3 No deposit guarantee or investor compensation
Crypto-Assets are not legal tender and are not money. Crypto-Assets and Fiat Currency held with Pionew are not protected by the Deposit Guarantee Scheme administered by the Central Bank of Ireland, by any investor compensation scheme, by any government insurance scheme, or by any equivalent scheme in any other jurisdiction. If Pionew or a sub-custodian becomes insolvent, you may lose some or all of your assets, subject only to the safeguards described in Section 7.
5.4 Past performance
Past performance of any Crypto-Asset, trading strategy or automated tool is not a reliable indicator of future performance. We do not guarantee any rate of return, the return of your principal, or the achievement of any investment objective.
5.5 Suitability and concentration risk
Trading and holding Crypto-Assets are not suitable for all persons. You should consider your overall investment portfolio, your risk tolerance, and your investment horizon. You should not invest more than you can afford to lose, and you should be cautious of concentrating your savings in Crypto-Assets.
5.6 Technology, blockchain, and cyber risk
Crypto-Assets rely on distributed ledger technology and cryptographic protocols that are new and may not have been fully tested at scale. Blockchains may experience network congestion, higher than normal transaction fees, technical failures, software bugs, hard or soft forks, chain reorganisations, 51% attacks, or other unintended events. We do not own or control any underlying blockchain network, and we make no guarantee regarding its security, functionality, availability, or future development.
Cyber-attacks, hacking, phishing, malware, social engineering, SIM-swap fraud, vulnerabilities in third-party wallets, and other security incidents may affect the Platform, your Account, or the underlying blockchain. Although we maintain a comprehensive ICT risk management framework in accordance with Regulation (EU) 2022/2554 (“DORA”), no system can be guaranteed to be completely secure or error-free.
5.7 Operational risk
The Platform is provided over the internet and mobile networks, and the quality and availability of the Services may be affected by factors outside our reasonable control, including network outages, denial-of-service attacks, infrastructure failures, and the failure of third-party service providers. We may, from time to time, suspend, restrict, or interrupt access to the Platform for scheduled or emergency maintenance, security reasons, regulatory reasons, or to manage operational risk.
5.8 Irreversibility of blockchain transactions
Blockchain transactions are, in general, irreversible. Once a transaction is broadcast and confirmed on the relevant network, it cannot be reversed by Pionew, by the network, or by any third party. You are solely responsible for the accuracy of destination addresses, the choice of blockchain network, and any required memo, tag, or destination identifier. Errors such as sending Crypto-Assets to an incorrect address, using an unsupported blockchain, or omitting a required tag may result in the permanent loss of the Crypto-Asset, for which we accept no liability.
5.9 Forks, airdrops, and protocol changes
Underlying blockchain networks may undergo “forks” (changes to the network protocol that result in two or more separate chains), airdrops, or other protocol changes. We have sole discretion to determine our response to any such event, including whether to support the resulting Crypto-Asset, when to support it, and on what basis. We are not under any obligation to credit, list, or otherwise support any forked, airdropped, or unsupported Crypto-Asset, and you may suffer losses as a result.
5.10 Regulatory and legal risk
The legal and regulatory framework for Crypto-Assets is evolving rapidly in the EU and worldwide. Future regulatory action, supervisory guidance, court decisions, or tax developments may affect the value, transferability, taxation, or legality of particular Crypto-Assets, or the manner in which we are permitted to provide Services. We may be required by law, by the Central Bank of Ireland, or by another competent authority to suspend, restrict, or terminate certain Services, freeze or close Accounts, or refuse particular transactions, sometimes without prior notice to you.
5.11 Sanctions, AML, and counter-terrorist financing risk
We are subject to extensive obligations under EU and Irish anti-money laundering and counter-terrorist financing law (including the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended) and to EU and other applicable financial sanctions. We may be required to delay, refuse, freeze, reverse, report, or unwind transactions, freeze or close Accounts, and disclose information to public authorities, in order to comply with these obligations. Where we do so, we may not be able to give you advance notice or to disclose the underlying reasons.
5.12 Travel Rule and counterparty information
Under the Transfer of Funds Regulation (EU) 2023/1113 (the “Travel Rule”), we are required to collect, verify, transmit, and receive information about originators and beneficiaries of Crypto-Asset transfers. Transfers may be delayed, returned, or refused if the required information is missing, inaccurate, or not received from a counterparty Crypto-Asset Service Provider in good time, or where the counterparty Crypto-Asset Service Provider does not meet our compliance standards.
5.13 Tax risk
The tax treatment of Crypto-Assets and of transactions in Crypto-Assets depends on your individual circumstances and the tax law of the jurisdiction(s) in which you are resident or otherwise subject to tax. Tax law may change, and may apply retrospectively. We may be required to report information about you and your transactions to the Revenue Commissioners and other tax authorities (including under Council Directive (EU) 2023/2226 (“DAC8”)). You are solely responsible for determining and paying your own tax liabilities, and you should seek independent tax advice as appropriate.
5.14 Information and data risk
Some content on the Platform, including pricing information and market data, is provided by unrelated third-party providers. While we select such providers with reasonable care, we do not warrant the accuracy, completeness, reliability, timeliness, or suitability of any third-party content, and we are not responsible for any non-performance of such third-party services. The information on the Platform is provided strictly for general information and arm’s-length transactions only.
5.15 Conflicts of interest
We maintain organisational and administrative arrangements designed to identify, prevent, manage and, where appropriate, disclose conflicts of interest, in accordance with Article 72 of MiCA. Despite these measures, conflicts may still arise. Our Conflicts of Interest Policy is available on the Platform.
6. Order execution, market abuse, and trading
Orders submitted to our trading platform are matched against Orders submitted by other clients. In accordance with Article 76(5) of MiCA, Pionew does not deal on its own account on the trading platform that it operates. Order execution is governed by our Order Execution Policy, which is published on the Platform and which is designed to take all reasonable steps to obtain the best possible result for clients in accordance with Article 78 of MiCA.
You must not engage in, or attempt to engage in, any conduct that constitutes insider dealing, the unlawful disclosure of inside information, or market manipulation within the meaning of Title VI of MiCA. We monitor trading activity on the Platform and may take action, including suspending or closing your Account and reporting to the competent authority, where we identify or suspect market abuse.
7. Custody, segregation, and client assets
Where we hold Crypto-Assets or the means of accessing Crypto-Assets on your behalf, we maintain adequate arrangements to safeguard your ownership rights, in particular in the event of our insolvency, and to prevent the use of clients’ Crypto-Assets for our own account. Your Crypto-Assets are segregated from Pionew’s own Crypto-Assets and from the Crypto-Assets of other clients at the level of our internal records and, where technically feasible, on the relevant distributed ledger.
In accordance with Article 75(4) of MiCA, you will receive a custody statement at least once every three (3) months, and at any other time on request, free of charge. In accordance with Article 75(8) of MiCA, Pionew is liable to you for the loss of Crypto-Assets, or of the means of accessing them, resulting from an incident attributable to us, up to the market value of the lost Crypto-Assets at the time of the loss.
8. Operational resilience and ICT security
As a financial entity within the scope of DORA, we maintain a comprehensive ICT risk management framework, business continuity and disaster recovery arrangements, vulnerability and incident management processes, and controls for the management of ICT third-party risk. We test our resilience on a regular basis and notify you and, where required, the Central Bank of Ireland of major ICT-related incidents in accordance with applicable regulatory timeframes.
Despite these measures, no system can be guaranteed to be completely secure, free of defects, or continuously available. To the maximum extent permitted by applicable law, we do not warrant or guarantee that the Platform or any related software or service will be uninterrupted, error-free, secure, or free from viruses or other harmful code. You are solely responsible for the security of the device, network, software, credentials, and personal information that you use to access the Platform.
9. No warranties and limitation of liability
To the maximum extent permitted by applicable law, and except as expressly provided in our Terms of Service, the Platform and the contents of the Platform are made available on an “as is” and “as available” basis, without representation or warranty of any kind, whether express or implied, including warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, security, reliability, suitability, currency, availability or continuous operation.
To the maximum extent permitted by applicable law, neither Pionew nor its affiliates, directors, officers, employees or agents shall be liable to you for any indirect, incidental, special, consequential or punitive losses, including, without limitation, loss of profit, loss of opportunity, loss of data, loss of goodwill, or any other intangible loss, however caused and on any theory of liability, arising out of or in connection with your use of the Platform or the Services.
Nothing in this Risk Disclaimer or in our Terms of Service excludes or limits any liability that cannot be excluded or limited under applicable law, including liability for fraud, gross negligence or wilful misconduct, or our liability to consumers under EU or Irish consumer protection law.
10. Availability of the Platform and changes to the Services
We will use commercially reasonable efforts to make the Platform available at all times. However, the Platform is provided over the internet and mobile networks, and its quality and availability may be affected by factors outside our reasonable control. We may, at our sole discretion and from time to time, update, modify, or discontinue features of the Platform to enhance security, comply with applicable law, or improve the user experience. We are not responsible for any downtime, inconvenience, or loss resulting from such actions, except as required by applicable law.
11. Help Desk and support
We maintain an online Help Desk on the Platform to answer your questions about the functionalities of the Platform. The Help Desk does not provide personal recommendations, suitability assessments, investment, legal, or tax advice, or recommendations regarding settings on your personal computer or mobile device. Any tutorial, video, or instructional material made available by us is general in nature and is not a substitute for professional advice. Your use of any such material is at your own risk.
12. Complaints handling
In accordance with Article 71 of MiCA and Commission Delegated Regulation (EU) 2025/294, we operate and maintain a free and effective procedure for the prompt handling of client complaints. If you wish to file a formal complaint, you may contact us:
- by email to service@webot.eu;
- through the in-Platform support function; or
- by post to: Pionew Ireland Limited, Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09 (marked for the attention of the Compliance Department).
We will acknowledge your complaint in writing on a durable medium within fifteen (15) business days of receipt and provide a final response within thirty (30) calendar days, unless the complexity of the complaint makes that impracticable, in which case we will explain the reasons for the delay and provide a final response within a maximum of sixty (60) calendar days.
If you are not satisfied with our final response (or if we have not provided a final response within the applicable time limit), you may, where eligible, refer your complaint to the Financial Services and Pensions Ombudsman (FSPO) at Lincoln House, Lincoln Place, Dublin 2, D02 VH29, Ireland (website: www.fspo.ie). EU consumers may also use the European Commission Online Dispute Resolution platform at ec.europa.eu/odr. Submitting a complaint is free of charge.
13. Privacy and data protection
Personal data collected through the Platform is processed by Pionew Ireland Limited as data controller in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation), the Irish Data Protection Act 2018, MiCA, and our Privacy Policy, which is published on the Platform and is incorporated by reference into this Risk Disclaimer. You can contact our Data Protection Officer at dpo@webot.eu with any privacy-related questions or requests.
14. Assignment
We may assign or transfer our rights and obligations under the Terms of Service and this Risk Disclaimer to any affiliate, holding company, subsidiary, business partner, or successor in interest, in accordance with Section 18.4 of our Terms of Service. We will give you reasonable advance notice of any such assignment where required by applicable law and, where it materially affects your rights, you will be entitled to close your Account before the assignment takes effect.
15. Governing law and jurisdiction
This Risk Disclaimer is governed by the laws of Ireland and applicable directly effective EU law, without regard to conflict-of-laws principles. Subject to the mandatory consumer-protection rules that you may rely on under EU law and the law of your habitual residence, the Irish courts shall have non-exclusive jurisdiction to settle any dispute or claim arising out of or in connection with this Risk Disclaimer.
16. Acknowledgement
By using the Platform or any of the Services, you acknowledge and agree that you have read, understood and accepted this Risk Disclaimer; that you understand the risks of trading and holding Crypto-Assets, including the risk of losing all of your invested capital; that you are not relying on Pionew for any personal recommendation, suitability assessment or advice; and that you are using the Platform and the Services on your own initiative, at your own risk and on an arm’s-length, execution-only basis.
17. Contact
Questions about this Risk Disclaimer can be sent to:
Pionew Ireland Limited — Compliance Department
Email: service@webot.eu
Postal address: Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09