Webot EEA Standard Custody and Administration Agreement
Important. This Standard Custody and Administration Agreement (the “Agreement”) governs the custody and administration of Crypto-Assets that Pionew Ireland Limited holds on your behalf in accordance with Article 75 of Regulation (EU) 2023/1114 (“MiCA”). It forms an integral part of, and must be read together with, our Terms of Service, Privacy Policy, Risk Disclaimer, Fee Schedule and User Code of Conduct, each of which is published on the Platform.
1. The Agreement
This Agreement constitutes a legally binding contract between you (“you”, “your”, the “User” or the “Client”) and Pionew Ireland Limited (“Pionew”, “Webot”, “we”, “our” or “us”). It sets out the terms on which Pionew provides custody and administration of Crypto-Assets on behalf of the Client, as defined in Article 75 of MiCA.
By entering into this Agreement, you acknowledge that you have read, understood and accepted the terms set out herein and that this Agreement constitutes a legally binding contract between you and us.
1.1 Electronic contracts
You acknowledge and agree that contracts executed by electronic means are valid and enforceable, and that the legal risks associated with such execution are acceptable to you. You agree not to dispute the contents or validity of any notice, communication, agreement or document delivered to you by us through electronic equipment or by any other Agreed Communication Method (as defined below).
2. About Us
Pionew Ireland Limited, trading as Webot, is a limited liability company incorporated in Ireland with its registered office at 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 (“CASP”) under MiCA, and is authorised, among other crypto-asset services, to provide the custody and administration of crypto-assets on behalf of clients within the meaning of Article 75 of MiCA.
We operate the Crypto-Asset trading and custody platform available at www.webot.com/eu (the “Platform”).
3. Definitions
Capitalised terms used in this Agreement and not otherwise defined herein shall have the meaning given to them in our Terms of Service. In addition, the following definitions apply:
Agreed Communication Method means any of the channels you have agreed with us for the delivery of communications, including the Platform, email, in-app notifications, and, where applicable, telephone or postal mail.
Available Balance means your Total Asset Value less any amounts held for Open Orders and Fees.
Available Jurisdiction means a jurisdiction in which the Platform is made available to Clients by Pionew.
Blockchain Address means a public address on a blockchain at which Crypto-Assets may be held (for example, a Bitcoin address for bitcoin).
Business Day means any day other than a Saturday, Sunday or public holiday in Ireland.
Crypto-Asset means any asset that is (i) expressed as a unit; (ii) capable of being transferred, stored and traded on a peer-to-peer basis, with or without conditions or limitations; and (iii) approved by Pionew from time to time for use in connection with the Platform. Crypto-Assets do not include fiat currencies. For the avoidance of doubt, any Crypto-Asset that (a) is transferred on any additional layer on top of a blockchain relating to another Crypto-Asset, or on any side chain, or (b) is a derivative of another Crypto-Asset, or has enhanced features or functionality that supplements or interacts with another Crypto-Asset, shall be treated as a distinct Crypto-Asset from such other Crypto-Asset and its use in connection with the Services shall be subject to approval by Pionew.
Custody means the service, provided by Pionew on behalf of its Clients, of safekeeping Crypto-Assets, including the holding and protection of the private cryptographic keys necessary to access and transfer those assets, and the secure, segregated and traceable storage of Clients’ Crypto-Assets.
Financial Crime Regulation means any Applicable Law, internal policy or regulatory requirement relating to money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, the trafficking of arms, drugs, humans or wildlife, slavery, the proliferation of weapons of mass destruction, or the evasion of sanctions. A reference to a violation of Financial Crime Regulation includes any act or attempt to circumvent or violate any Applicable Law relating to Financial Crime Regulation.
Platform means www.webot.com/eu, operated by Pionew in accordance with this Agreement and the Terms of Service.
Standard Agreement means this Standard Custody and Administration Agreement.
Wallet means any Crypto-Asset wallet provided to you by us through the Platform.
4. Custody and Administration
Pionew provides custody and administration services in respect of Crypto-Assets that Clients hold on the Platform. We do not provide custody or administration services to any party other than Clients holding Crypto-Assets on the Platform.
Crypto-Assets held by us for each Client are recorded in a dedicated Client Wallet maintained on the Platform. Each Client is assigned a series of Wallets, each with a unique Blockchain Address that is specific to that Client and to a particular blockchain network supported by us from time to time. Such Wallets enable you to deposit, store, track, transfer and manage your balances of supported Crypto-Assets.
You are responsible for ensuring that, when you initiate any Crypto-Asset transfer, you use the Wallet address that corresponds to the specific blockchain network you have selected. Sending Crypto-Assets to a Wallet address on the wrong blockchain network, or sending unsupported Crypto-Assets to your Wallet, may result in irreversible loss of those assets.
In the interests of consumer protection, Clients are not issued with the private keys to their Wallets. Private keys are the most sensitive element of any Crypto-Asset custody arrangement, and disclosing them to Clients would materially increase the risk of theft, hacking and unauthorised transactions.
Your Wallet is intended for use only with Crypto-Assets that we support, as listed on the Platform. You must not attempt to use your Wallet to store, send, request or receive any Crypto-Asset that is not supported by the Platform; if you do so, you may suffer the irreversible loss of those assets.
You acknowledge and agree that Pionew is not liable for any unsupported Crypto-Asset that is sent to a Wallet. We may terminate support for any Crypto-Asset for compliance, regulatory, technical or operational reasons. If you do not sell or transfer such a Crypto-Asset off the Platform before we terminate support for it, we may, acting reasonably and in accordance with applicable law, remove that Crypto-Asset from your Wallet and credit your Wallet with the equivalent market value of a supported Crypto-Asset or fiat currency, less reasonable transaction costs. Information about the Crypto-Assets currently supported by us is available on the Platform; you may also contact us if you have any questions.
You further acknowledge and agree that:
- any Crypto-Assets that we hold on your behalf do not benefit from the protections that apply to traditional credit-institution deposits and other regulated financial products (including, in particular, the Deposit Guarantee Scheme administered by the Central Bank of Ireland and any investor compensation scheme); and
- we are under no duty to return to you the specific Crypto-Assets originally delivered to, or otherwise held by, us, but we are under a duty to deliver to you Crypto-Assets of an identical type and in the same nominal amount as the Crypto-Assets we hold on your behalf, subject to your other rights under this Agreement and applicable law.
5. Transfer Services
The Platform enables you to initiate on-chain transfers of supported Crypto-Assets to external destination wallets that you select. To enable accurate and secure transfers, the steps set out below must be followed.
Before initiating a transfer, you must verify the destination wallet address and confirm that it supports the specific Crypto-Asset that you intend to transfer. It is essential that the correct blockchain network and wallet address are used both when sending Crypto-Assets to, and when receiving Crypto-Assets from, an external wallet, and that the chosen blockchain network matches the network to be used for the transfer; this step is critical to prevent the loss of assets due to network incompatibility.
To initiate a transfer, you must log into the Platform with your credentials and complete two-factor authentication, navigate to the withdrawal section, enter the Blockchain Address of the destination wallet, select the appropriate blockchain network, specify the amount to be transferred and review any applicable withdrawal fees. The applicable withdrawal fee will be deducted from the transfer amount, and the net proceeds will be displayed for your reference before you confirm the transfer. An estimated time-frame for confirmation of the transfer by the relevant blockchain network may also be displayed; however, the actual confirmation time depends on the conditions of the blockchain at the time of transfer and is beyond our control. We therefore make no guarantee or commitment regarding the timing of any such confirmation.
It is your responsibility to check and confirm that all details of the transfer are complete and accurate. Errors, including the use of an incorrect wallet address or blockchain network, may result in irreversible loss of assets. To support consumer protection and user awareness, the Platform displays customer-facing warnings prompting you to verify these details before executing the transfer.
Once a transaction has been approved by us following any necessary compliance checks, it is broadcast to the relevant blockchain, where it undergoes confirmation by network validators. The time required for confirmation varies according to network congestion and the specific blockchain used. Once the transaction is confirmed by the blockchain, the transferred Crypto-Assets will appear in the destination wallet.
When you initiate a deposit of Crypto-Assets to your Wallet from an external source, whether from another CASP or from a self-hosted wallet, you are responsible for ensuring that the deposited token is a Crypto-Asset supported by Webot and that the corresponding blockchain network is also supported by us. The net amount of your deposited Crypto-Assets, after deduction of any gas fees and any applicable charges imposed by blockchain network validators or third-party CASPs, will be credited to your Wallet once the transaction has been broadcast and confirmed by the relevant blockchain network. Webot shall not be liable for any loss of Crypto-Assets resulting from errors, omissions or failures attributable to you, to any third-party CASP, to your wallet service provider, or to the blockchain network itself.
6. Exercise of Rights Attached to Crypto-Assets
We will facilitate the exercise of any rights attached to your Crypto-Assets to the extent reasonably practicable. We will notify you of any event of which we become aware that may create or modify the rights associated with your Crypto-Assets. You will be entitled to any newly created Crypto-Assets, or any other rights arising from such an event, on the basis of, and in proportion to, your positions at the time the relevant change or event occurs, subject to applicable law and to our policies on supported networks, forks, airdrops and similar events.
7. Statements of Your Crypto-Assets
In accordance with Article 75(5) of MiCA, we will provide you with a statement of the Crypto-Assets we hold on your behalf at least once per month and additionally upon your reasonable request. Statements will be made available to you in electronic form through the Platform and will clearly identify, in respect of the relevant period:
- the type and quantity of each Crypto-Asset held;
- the balance of each Crypto-Asset;
- the value of each Crypto-Asset; and
- all transfers, movements and other operations executed in relation to your Crypto-Assets.
In addition, we will promptly provide you with any information concerning operations on your Crypto-Assets that requires a response or action from you, by email and/or by notifications on the Platform.
8. Asset Segregation
Your Crypto-Assets are held separately from any Crypto-Asset holdings of Pionew. They are also segregated from our estate in your interest, with the result that creditors of Pionew, if any, shall have no recourse to your Crypto-Assets, in particular in the event of our insolvency.
We maintain comprehensive internal records, including client position registers and the Platform ledger, and perform regular end-of-day reconciliations between our records and the underlying blockchain positions. These reconciliations are designed to verify that all transaction entries and Crypto-Asset balances are complete, accurate and properly attributed to the correct Client accounts. Any discrepancy is promptly investigated and resolved through our established escalation and incident-response procedures. This approach supports our ongoing compliance with MiCA and enables us to maintain a high standard of client-asset protection.
9. Security Systems
We have implemented, and are committed to maintaining on a continuing basis, ICT systems, protocols and tools that are robust, secure and scalable, in alignment with applicable EU regulations, including Regulation (EU) 2022/2554 (the Digital Operational Resilience Act, or “DORA”). These systems are designed to manage ICT risk effectively and to ensure operational continuity under both normal and stressed market conditions.
In the event of any loss of your Crypto-Assets resulting from an incident that is attributable to Webot, we will be liable to you for the loss of those Crypto-Assets, or of the means of access to them, in accordance with applicable law. Our liability in such circumstances will be limited to the market value of the Crypto-Assets lost at the time the loss occurred.
Incidents that are not attributable to Webot include any event that occurs independently of the provision of our Services or of the operation of our business, such as an incident caused by the operation of any blockchain network that we do not control. In any such case, we will not be liable to you for any loss of Crypto-Assets resulting from that incident.
10. Fees
On-chain withdrawals of Crypto-Assets (that is, withdrawals of a Crypto-Asset from one platform provider to another) incur a gas fee. Gas fees are ultimately charged by validators on blockchain networks and may vary between blockchains depending on the technology of each network. A withdrawal fee, inclusive of any applicable gas fee, will be charged when you initiate an on-chain withdrawal. The applicable fee will be displayed on the Platform before you confirm the withdrawal.
We do not charge any deposit or gas fees in respect of on-chain deposits of Crypto-Assets. Further information on fees is set out in our Fee Schedule published on the Platform.
11. Applicable Law
Unless otherwise specified, this Agreement and your use of the custody and administration services provided by Pionew are 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 Agreement.
12. Means of Communication
You may communicate with us, and receive information from us, through secure electronic channels including the Platform and our designated customer-service email address service@webot.eu.
12.1 Notices and electronic delivery
You authorise us to deliver all communications, agreements, documents, notices, disclosures and confirmations to you by an Agreed Communication Method. You may change your Agreed Communication Methods, including telephone, email and postal mail, in your Webot account profile.
It is your responsibility to ensure that the details of your Agreed Communication Method are correct and that the Agreed Communication Method is operational and available for receipt of all communications, and to notify us of any change to those details as soon as reasonably practicable after the change is made.
In some cases, our communications may be made available solely on the Platform, in which case we will take reasonable steps to make you aware of them.
12.2 Notices to us
Notices to us should be sent electronically to our customer-support address service@webot.eu, or by post to our registered office at Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09. Privacy and data-protection enquiries may also be sent to our Data Protection Officer at dpo@webot.eu.
13. Customer Complaints
We are committed to accountability, transparency and continuous improvement in our work and conduct. You may submit a complaint to us in relation to any aspect of our Services, free of charge, at any time.
Complaints may be submitted electronically to service@webot.eu, or in writing to our registered office at Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09.
We will handle your complaint in accordance with Article 71 of MiCA, Commission Delegated Regulation (EU) 2025/294 and our internal complaints-handling procedure: we will acknowledge receipt of your complaint 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.
14. Contact
Questions about this Agreement can be sent to:
Pionew Ireland Limited — Custody Operations / Compliance
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.