User Code of Conduct

by

Webot EEA User Code of Conduct

Important. This User Code of Conduct (the “Code”) forms an integral part of, and is incorporated by reference into, the Pionew Ireland Limited Terms of Service. By opening or maintaining an Account, accessing the Webot Platform, or using any of the Services, you agree to comply with this Code at all times. Any breach may result in restriction, suspension or closure of your Account, reversal of affected transactions, reporting to competent authorities, and any other remedies available to us under the Terms of Service or applicable law.

1. Purpose and scope

Pionew Ireland Limited (“Pionew”, “Webot”, “we”, “our” or “us”) is a limited liability company incorporated in Ireland (registered office: Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09) and authorised by the Central Bank of Ireland as a Crypto-Asset Service Provider under Regulation (EU) 2023/1114 (“MiCA”).

This Code sets out the standards of conduct expected of all users of the Webot Platform (the “Platform”) and recipients of our Services. Its purpose is to safeguard the integrity, fairness and operational resilience of the Platform; to protect users, our staff and third parties; and to ensure compliance with applicable EU and Irish law, including MiCA Title VI on the prevention and prohibition of market abuse.

This Code applies to every customer of Webot, every visitor of www.webot.com/eu, and every person interacting with us or with other users through the Platform, regardless of the channel used (web, mobile, email, chat or telephone).

2. General obligations

In connection with your use of the Platform, your Account and the Services, and in your interactions with us, with other users and with third parties, you agree to:

  • act honestly, fairly, in good faith and with reasonable care;
  • comply with all applicable laws, regulations and rules, including those concerning financial services, market abuse, anti-money laundering, counter-terrorist financing, sanctions, taxation, data protection, consumer protection, anti-discrimination and fair competition;
  • provide true, accurate, current and complete information when registering for an Account and during onboarding, ongoing due diligence and any other interactions with us, and update that information promptly whenever it changes;
  • use the Platform and the Services only for your own personal, non-commercial purposes and only in the manner expressly permitted by the Terms of Service; and
  • treat our staff, our service providers and other users with respect and courtesy.

3. Prohibited conduct

The following list is illustrative and not exhaustive. We may, in our reasonable discretion and acting proportionately, treat any conduct that we consider analogous to the items below as a breach of this Code.

3.1 Unlawful activity

You must not use the Platform, your Account or any of the Services to:

  • violate any law, statute, regulation, rule, ordinance, court order or sanctions regime applicable to you or to us, including in the areas of financial services, anti-money laundering and counter-terrorist financing, market abuse, sanctions, taxation, consumer protection, fair competition, anti-discrimination, advertising and intellectual property;
  • engage in, facilitate or attempt money laundering, terrorist financing, proliferation financing, tax evasion, bribery, corruption, fraud, theft or any other criminal offence;
  • evade, attempt to evade, or assist any person in evading economic or trade sanctions imposed by the European Union, the United Nations, Ireland, the United Kingdom or the United States, or restrictions adopted pursuant to MiCA, AMLD/AMLR, the Transfer of Funds Regulation (EU) 2023/1113 or DAC8;
  • hold, deposit, withdraw, transfer or trade Crypto-Assets that we reasonably believe to be the proceeds of crime, derived from fraudulent activity, stolen, subject to a freezing or restraint order, or otherwise of unlawful or illegitimate origin; or
  • engage in any conduct that is fraudulent, deceptive, dishonest, suspicious, or that we reasonably consider to be inconsistent with the lawful and orderly use of the Platform.

3.2 Market abuse and trading manipulation

In line with Title VI of MiCA (Articles 86 to 92) and applicable Irish law, you must not engage in, or attempt to engage in, any form of insider dealing, unlawful disclosure of inside information, market manipulation, or other conduct that distorts the integrity of the markets in Crypto-Assets. In particular, you must not:

  • use, or attempt to use, inside information relating to a Crypto-Asset, or recommend or induce another person to use such information, when dealing on the Platform;
  • disclose inside information to any other person otherwise than in the normal exercise of an employment, profession or duty;
  • place or cancel orders, or enter into transactions, for the purpose of generating artificial volatility, creating a false or misleading impression of supply, demand, liquidity or price, or causing prices not to reflect fair market values — including by buying and selling around the same price, splitting orders to inflate apparent activity, or executing successive trades to suggest artificial momentum;
  • place orders with the intention, at the time of placing them, of cancelling the bid or offer before execution (so-called “spoofing” or “layering”);
  • pre-arrange or coordinate orders with another person for the purpose of producing an artificial execution, transferring value between accounts, or moving prices (so-called “wash trading” or “matched orders”);
  • place orders for the sole purpose of assisting another person to engage in transactions that breach this Code or applicable law;
  • place simultaneous buy and sell orders that are designed to, or that could reasonably be expected to, execute against each other; or
  • disseminate, or assist in disseminating, information that gives or is likely to give false or misleading signals as to the price, supply or demand of any Crypto-Asset, including through social media, messaging platforms, online forums or any “pump-and-dump” scheme.

3.3 Account integrity

You are responsible for safeguarding the integrity of your Account at all times. You must not:

  • open or maintain more than one Account except with our prior written consent;
  • open or use an Account in the name of another person, in a false name, or using identification documents, photographs, biometric data or other credentials that do not genuinely belong to you;
  • permit any other person to access, control or use your Account, or share your login credentials, passwords, two-factor authentication codes, API keys or device with any third party;
  • buy, sell, rent, lease or otherwise transfer your Account or any rights associated with it; or
  • circumvent, or attempt to circumvent, any restriction, suspension, closure, geo-blocking, transaction limit or sanctions screening that we have applied to you or to your Account.

3.4 Platform integrity, security and acceptable use

To protect the operational resilience of the Platform and the security of all users, you must not:

  • take any action that imposes, or that may impose, an unreasonable or disproportionately large load on our websites, applications, systems, networks, servers or any infrastructure used to provide the Services;
  • introduce or facilitate the introduction of any virus, worm, trojan horse, malware, ransomware, logic bomb or other malicious code, or any routine that may damage, disrupt, corrupt, misuse, intercept, expropriate or gain unauthorized access to any system, data or information;
  • probe, scan, penetration-test or otherwise test the vulnerability of any system or network connected to the Platform, or breach or circumvent any security or authentication measure, except under the terms of a written authorization issued by us;
  • access, or attempt to access, any account, data or area of the Platform that you are not authorized to access, including any administrative or back-office function;
  • decompile, disassemble, reverse-engineer or otherwise attempt to derive the source code, underlying ideas, algorithms or trade secrets of the Platform or of any of our software, except to the extent that such activity is expressly permitted by mandatory applicable law and cannot be lawfully excluded by contract;
  • scrape, harvest, crawl, index, mirror or otherwise collect content or data from the Platform by automated means, except via interfaces and within the rate limits that we expressly make available for that purpose;
  • misuse any application programming interface (“API”), exceed published rate limits, or use any API for activities that are inconsistent with the API documentation or this Code; or
  • interfere with, or disrupt, the use of the Platform or the Services by any other user.

3.5 Information, communications and content

In your communications and any content you submit through the Platform (including support tickets, chat, comments, profile data and uploaded documents), you must not:

  • provide false, misleading or deceptive information, or impersonate any person or entity;
  • submit forged, altered or fraudulent identification documents, proof-of-address documents, source-of-funds documents, or any other supporting evidence;
  • post or transmit content that is unlawful, defamatory, obscene, sexually explicit, hateful, harassing, threatening, discriminatory, or that incites violence;
  • infringe the intellectual property rights, privacy rights, confidentiality obligations or other rights of any person;
  • send unsolicited commercial communications, chain messages, advertisements, referral spam or other promotional material to other users or to our staff; or
  • abuse, threaten, harass, intimidate or otherwise mistreat our staff, our service providers or other users.

3.6 Misuse of incentives and promotions

Where we offer promotions, rewards, referral programmes or other incentives, you must not abuse them. In particular, you must not create multiple Accounts, use stolen, synthetic or fictitious identities, collude with other users, automate participation, or otherwise act in a manner that is contrary to the spirit and rules of the relevant programme.

4. Privacy and data protection

You must respect the privacy of other users, of our staff and of any third party. You must not collect, store, share or publish personal data obtained through the Platform other than as strictly necessary for the legitimate use of the Services, and never in breach of Regulation (EU) 2016/679 (“GDPR”) or the Irish Data Protection Act 2018. Our processing of your personal data is governed by our Privacy Policy, which is published on the Platform.

5. Cooperation with us and with authorities

You agree to cooperate fully and promptly with any reasonable request from us in connection with onboarding, ongoing customer due diligence, transaction monitoring, sanctions screening, fraud prevention, market-abuse surveillance, security investigations, or compliance with any obligation imposed on us by applicable law (including MiCA, AMLD/AMLR, the Transfer of Funds Regulation (EU) 2023/1113, DAC8, DORA and GDPR). This includes providing additional information, documentation or explanations within the timescales we reasonably specify.

Where we are required to disclose information to the Central Bank of Ireland, An Garda Síochána, the Revenue Commissioners, the Financial Intelligence Unit, the Data Protection Commission, ESMA, EBA or any other competent authority or court, you acknowledge that we will do so to the extent required by law and that, in certain cases, we may be prohibited from informing you of the disclosure.

6. Reporting concerns

If you become aware of any actual or suspected breach of this Code, of any security incident, of any vulnerability in the Platform, or of any conduct that you believe may amount to fraud, market abuse, money laundering or other unlawful activity, please report it to us promptly at service@webot.eu. Where you wish to raise a privacy or data-protection concern, you may also contact our Data Protection Officer at dpo@webot.eu.

We will treat reports confidentially to the maximum extent permitted by law, and we do not tolerate retaliation against any user or member of staff who reports a concern in good faith.

7. Consequences of breach

If we determine, on reasonable grounds, that you have breached or are about to breach this Code, the Terms of Service or any applicable law, we may take any of the following actions, individually or in combination, in a manner proportionate to the conduct concerned:

  • issue a warning or request additional information, documentation or explanations;
  • apply enhanced monitoring, transaction limits, or restrictions on specific products, Crypto-Assets, jurisdictions or features;
  • temporarily suspend access to your Account, to specific Services or to specific functions of the Platform;
  • cancel pending orders, reverse, freeze or refuse to process transactions or transfers, or hold funds pending investigation;
  • close your Account in accordance with the Terms of Service and return any remaining balances in line with applicable law and our internal procedures;
  • recover from you any losses, costs, fines, penalties or expenses (including reasonable legal fees) that we incur as a result of your breach, to the extent permitted by applicable law;
  • submit a Suspicious Transaction or Order Report (STOR) under MiCA, file a Suspicious Activity Report (SAR) under AML legislation, or otherwise report your conduct to the Central Bank of Ireland, the Financial Intelligence Unit, An Garda Síochána, the Revenue Commissioners or any other competent authority; and
  • pursue any other remedy available to us under contract, equity or law.

Nothing in this Code limits our right to take immediate action where we reasonably consider that user funds, the integrity of the Platform, the safety of any person, or our compliance with applicable law are at risk.

8. Updates to this Code

We may update this Code from time to time to reflect changes in our Services, in our risk and control framework, or in applicable law. Where a change materially affects your rights or obligations, we will give you at least thirty (30) days’ prior notice through the Platform, by email or by another durable medium, in line with our Terms of Service. Your continued use of the Platform after the effective date of any update constitutes acceptance of the updated Code.

9. Complaints

If you are dissatisfied with our Services, with the application of this Code, or with any decision we have taken in respect of your Account, you may submit a complaint, free of charge, to service@webot.eu. We will handle your complaint in accordance with MiCA Article 71, Commission Delegated Regulation (EU) 2025/294 and our internal complaints-handling procedure: we will acknowledge receipt within fifteen (15) business days and provide a final reply within thirty (30) calendar days, extendable to sixty (60) calendar days in duly justified cases, of which you will be informed.

If you are not satisfied with our final reply, or if we have failed to provide one within the applicable time-frame, you may refer the matter to the Financial Services and Pensions Ombudsman of Ireland (“FSPO”) at www.fspo.ie, or, if you are a consumer resident in another EU/EEA Member State, to the competent alternative dispute resolution body in your jurisdiction or via the EU Online Dispute Resolution platform at ec.europa.eu/consumers/odr. You retain the right to bring any matter before the competent courts at any time, in accordance with applicable law.

10. Governing law and jurisdiction

This Code 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 over any dispute or claim arising out of or in connection with this Code.

11. Acknowledgement

By accessing the Platform, opening or maintaining an Account, or using any of the Services, you acknowledge that you have read, understood and accepted this User Code of Conduct and that you will abide by it at all times.

12. Contact

For any question relating to this Code or to your conduct on the Platform, please contact:

Pionew Ireland Limited

Customer support and complaints: service@webot.eu

Data protection: dpo@webot.eu

Postal address: Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09.