User Agreement – Webot Blog

Webot EEA Terms of Service

Last Updated: 24 April 2026

These Terms of Service govern your relationship with Pionew Ireland Limited and your use of the Webot Platform if you are an EEA resident.

Regulatory Status. Pionew Ireland Limited (trading as “Webot”) is authorised by the Central Bank of Ireland as a Crypto-Asset Service Provider on 18th December 2025 under Regulation (EU) 2023/1114 (“MiCA”). The Platform is made available to residents of certain EEA Member States, as authorised by the Central Bank of Ireland.

Risk Warning. Crypto-Assets are volatile, high-risk assets. Their value can fluctuate significantly, and you may lose all funds you invest. Crypto-Assets held with us are not covered by any deposit guarantee scheme or investor compensation scheme administered by the Central Bank of Ireland. 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. Detailed risk information is published on the Platform.

1. Introduction and Acceptance

These Terms of Service (the “Terms”) form a legally binding contract between you (“you”, “your”, “User” or “Client”) and Pionew Ireland Limited, a company incorporated in Ireland and trading as “Webot” (“Pionew”, “Webot”, “we”, “our” or “us”). By registering for an Account, accessing the Platform or using any Services, you confirm that you have read, understood and agreed to be bound by these Terms.

These Terms govern our provision of Crypto-Asset Services to you under MiCA and applicable Irish law, and set out your rights and obligations as a User. They should be read together with our Privacy Policy, Cookie Policy, Fee Schedule and the risk information published on www.webot.com/eu, each of which is incorporated into these Terms by reference and forms part of the contract between you and us.

1.1 Electronic Contract

You acknowledge that these Terms, and any notice, confirmation or communication sent by us electronically, are binding and enforceable. Instructions submitted through the Platform have the same legal effect as instructions signed in writing.

1.2 Pre-contractual Information

Before you enter into these Terms, we make available to you on the Platform the pre-contractual information required under MiCA (in particular Articles 66 and 81), the European Union (Consumer Information, Cancellation and Other Rights) Regulations 2013 and the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004, including information about us, the Services offered, all applicable fees (including examples), the risks associated with Crypto-Assets, our complaints handling procedure, and your statutory rights. This information is provided on a durable medium, in a standardised and easily retrievable form, and separately from any marketing communications. You should read this information carefully before accepting these Terms.

1.3 Right of Withdrawal

Where required by applicable Irish consumer law, you have the right to withdraw from these Terms, free of charge and without giving any reason, within fourteen (14) calendar days of their conclusion. To exercise this right, you must send an unambiguous statement to service@webot.eu or by post to our registered office, before expiry of the 14-day period. However, the right of withdrawal does not apply to individual Orders or transactions whose price depends on fluctuations in the Crypto-Asset or financial markets, which are outside our control, once such transactions have commenced with your consent. Where the right of withdrawal is validly exercised, we will refund all payments received from you without undue delay, and in any event within fourteen (14) calendar days, using the same means of payment as the original transaction (unless you expressly agree otherwise).

1.4 Amendments

We may amend these Terms 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. If you do not agree to the amendments, you may close your Account in accordance with Section 13 before they take effect, free of charge. Continued use of the Platform after the effective date constitutes your acceptance of the updated Terms.

2. About Pionew Ireland Limited

Pionew Ireland Limited is 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 on 18th December 2025 under MiCA. Our authorisation and contact details for the Central Bank of Ireland can be verified on the Central Bank’s public register at www.centralbank.ie.

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.

3. Definitions

Capitalised terms used in these Terms have the meanings given below:

“Account” means the account opened in your name for access to the Platform and the Services.
“Applicable Law” means the laws of Ireland and directly applicable EU law, including MiCA, the GDPR, EU AML/CFT legislation and the EU Transfer of Funds Regulation.
“Available Balance” means the Crypto-Assets or Fiat Currency in your Account available for transactions, net of amounts held for open Orders and Fees.
“Business Day” means any day other than Saturday, Sunday or a public holiday in Ireland.
“Crypto-Asset” has the meaning given in Article 3(1)(5) of MiCA: a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology. Throughout these Terms, “Crypto-Asset” is the only term used to refer to digital, virtual or crypto assets.
“Eligibility Criteria” means the eligibility and onboarding requirements referred to in Section 4.
“Fee Schedule” means the schedule of fees, costs and charges published on the Platform.
“Fiat Currency” means euro (EUR) or any other official currency of a State which we accept from time to time.
“Order” means an instruction submitted by you through the Platform to buy or sell a Crypto-Asset, or to exchange between Crypto-Assets and Fiat Currency.
“Platform” means the website at www.webot.com/eu and any associated mobile application, technology, application programming interfaces and services operated by us.
“Security Credentials” means any password, PIN, passkey, biometric, two-factor authentication code, API key or other credential used to access your Account.
“Services” means the Crypto-Asset Services described in Section 5.
“Wallet” means a Crypto-Asset wallet maintained by us for your benefit for the safekeeping of your Crypto-Assets.

4. Account Opening and Eligibility

4.1 Eligibility

To open an Account you must (a) be a natural person at least 18 years of age, (b) be resident in an EEA Member State in which the Platform is made available, (c) not be subject to any sanctions administered by the United Nations, the European Union, Ireland or any other applicable authority, and (d) not be prohibited by Applicable Law from using Crypto-Asset Services. The Platform is intended for personal use by consumers; corporate clients are not currently accepted.

4.2 Application and Onboarding

You must complete our online registration process and provide all information and documentation we request, including for the purpose of customer due diligence under EU AML/CFT legislation. You warrant that all information provided is true, accurate, complete and kept up to date. We may carry out identity verification checks, either directly or through third-party service providers.

4.3 Approval

We may accept or decline your application at our discretion and are not required to provide reasons, except as required by Applicable Law. Upon approval, you are granted a non-exclusive, non-transferable right to use the Platform for your own personal use. You may hold only one Account unless we expressly agree otherwise.

4.4 Account Security and Your Security Obligations

Two-factor authentication is mandatory. You are solely responsible for keeping your Security Credentials confidential and for all activity conducted through your Account. In particular, you must:

keep all Security Credentials safe and take care when using them (for example, making sure that no-one else can observe you using them and that you log out of shared devices);
not choose Security Credentials that other people could easily guess;
not allow any other person to access or use your Security Credentials, or share them with anyone;
not write down any Security Credentials in a way that would be intelligible to others; and
notify us without delay if you believe your Security Credentials have been, or may have been, compromised, misused or stolen, or if you suspect any unauthorised use of your Account.

5. Scope of Our Services

The Services we provide to you under these Terms comprise the following Crypto-Asset Services, each as described in more detail in the sections referenced below:

the operation of a trading platform that enables you to submit Orders to buy and sell supported Crypto-Assets (Section 6);
the provision of custody and administration of Crypto-Assets on your behalf (Section 7);
the provision of transfers of Crypto-Assets on your behalf, including deposits to and withdrawals from your Account and transfers between clients (Section 8); and
the exchange of Crypto-Assets for Fiat Currency, and of Fiat Currency for Crypto-Assets (Section 9).

The list of Crypto-Assets and Fiat Currencies supported, the available payment methods, and any applicable limits (including minimum and maximum Order sizes, deposit and withdrawal limits and aggregate exposure limits) are published on the Platform and may be updated from time to time. We may, at any time and without prior notice, add, remove, suspend or restrict support for any Crypto-Asset, Fiat Currency or payment method for regulatory, compliance, operational, security or technical reasons. Where we withdraw support, we will give you a reasonable period to withdraw, sell or exchange the affected Crypto-Asset.

We do not provide investment advice, portfolio management, margin trading, staking, lending, derivatives or any other service outside the scope described above. We do not hold any other form of authorisation or registration from the Central Bank of Ireland beyond our authorisation as a Crypto-Asset Service Provider under MiCA.

6. Orders, Execution and Trading

6.1 Submitting Orders

You may submit the following types of Orders through the Platform:

Market Orders — executed at the best price available on the Platform at the time of execution;
Limit Orders — executed only at your specified price or better; and
such other Order types as we may make available from time to time (with their specific terms disclosed on the Platform).

All Orders must be pre-funded: before submission, you must hold a sufficient Available Balance in the relevant Crypto-Asset or Fiat Currency to cover the Order and any applicable Fees. An Order is binding on you from the moment it is confirmed by our systems.

6.2 Instructions

We will act on the instructions we receive from you, and you must verify all transaction information before confirming an Order. You are responsible for ensuring that the information you submit is accurate and complete, and we will have no liability for any loss resulting from inaccurate or incomplete information provided by you. We may refuse to process, delay or cancel any Order or pending transaction where we are required or permitted to do so by Applicable Law or by any regulator, court or other authority with competent jurisdiction, including where we suspect money laundering, terrorist financing, breaches of sanctions, fraud or other financial crime.

6.3 Order Matching and No Proprietary Trading

Orders submitted to the trading platform are matched against Orders submitted by other clients. Pionew does not deal on its own account on the trading platform that it operates. Pionew acts as the operator of the matching infrastructure and does not take proprietary positions against client Orders.

6.4 Execution, Best Interests and Trade Confirmation

We will take all reasonable steps to execute client Orders on terms most favourable to the client. Executed Orders are confirmed to you through the Platform, and you can review your trade history and position in your Account at any time.

6.5 Timing

Subject to operational considerations, we accept and process Orders on a continuous basis. We may however treat any instruction received outside normal processing hours, or during a period of planned or unplanned downtime, as if received at the next available processing time. You cannot revoke your consent to an Order once it has commenced execution, but you may cancel unfilled Orders (such as unexecuted Limit Orders) in accordance with the functionality of the Platform.

6.6 Price-Deviation Protection

We may display a warning when you attempt to submit an Order at a price materially away from the most recently executed price for the same trading pair, and may refuse or adjust Orders that fall outside predefined protection bands. Minimum and maximum Order sizes and other controls are published on the Platform.

6.7 Settlement and Errors

Executed Orders are settled promptly by allocating the relevant Crypto-Assets and Fiat Currency to the appropriate Accounts. Settlement is final except where (i) we are required by Applicable Law to reverse a transaction, or (ii) there has been a mis-execution or technical error, in which case we will take reasonable steps to restore you to the position you would have been in had the error not occurred.

6.8 Market Abuse

You must not engage in, or attempt to engage in, any conduct that constitutes insider dealing, unlawful disclosure of inside information or market manipulation within the meaning of Title VI of MiCA. We monitor trading activity on the Platform and will take appropriate action, including suspension or termination of your Account and reporting to the competent authority, where we identify or suspect market abuse.

7. Custody of Crypto-Assets

Pionew provides custody and administration services for Crypto-Assets held on the Platform in accordance with Article 75 of MiCA.

7.1 Safeguarding and Segregation

Where we hold Crypto-Assets or the means of accessing Crypto-Assets on your behalf, we have adequate arrangements in place 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 distributed ledger. In the event of our insolvency, our creditors shall have no recourse to client Crypto-Assets held in custody.

7.2 Title and Ownership

You retain full beneficial ownership of Crypto-Assets held in custody with us. We hold those Crypto-Assets for your benefit and do not acquire any ownership interest in them.

7.3 Wallets and Private Keys

Each Wallet is assigned one or more blockchain addresses for each supported network. Private keys and cryptographic material used to access client Crypto-Assets are held and managed by us under institutional-grade key-management controls. Private keys are not disclosed to clients.

7.4 Unsupported Crypto-Assets and Wrong-Network Deposits

You must only deposit Crypto-Assets that are supported by the Platform and use the correct blockchain network. Pionew is not liable for the loss of any Crypto-Asset sent to a Wallet that is not supported, or sent via an incorrect network.

7.5 Forks, Airdrops and Network Events

We will take reasonable steps to facilitate the exercise of rights attached to your Crypto-Assets (such as airdrops or forks affecting supported Crypto-Assets) and will allocate any newly created Crypto-Assets on a pro-rata basis where we elect to support them. We retain sole discretion as to whether to support any particular fork or network event, taking into account security, legal and operational considerations.

7.6 Statements and Records

You may access your transaction history and current holdings at any time through the Platform. In accordance with Article 75(4) of MiCA, a custody statement will be provided to you at least once every three (3) months, and at any other time on request, free of charge. We maintain records of the Services we provide, and of related activities and transactions, in accordance with our internal retention policies and Applicable Law.

7.7 Liability for Loss of Crypto-Assets in Custody

In accordance with 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. We are not liable for losses that occur independently of the provision of our Services, including those arising from events affecting the underlying distributed ledger networks which we do not control.

7.8 No Deposit Protection

You acknowledge that Crypto-Assets held in custody with Pionew are not protected by the Deposit Guarantee Scheme administered by the Central Bank of Ireland, nor by any investor compensation scheme.

8. Transfers of Crypto-Assets

You may use the Platform to transfer supported Crypto-Assets between Wallets within your Account, to another client of the Platform, or to an external blockchain address either self-hosted or that is maintained by another regulated Crypto-Asset Service Provider.

8.1 Initiating a Transfer

To initiate a transfer, you must log in to the Platform, verify the destination address and blockchain network, specify the amount, and confirm the applicable withdrawal fee. The Platform will display the estimated net proceeds before you confirm. By confirming, you authorise us to execute the transfer.

8.2 Travel Rule and Compliance Checks

Transfers are subject to Regulation (EU) 2023/1113 (the EU Transfer of Funds Regulation) and to our internal AML/CFT controls. We will collect, verify and transmit originator and beneficiary information as required. We may delay, block or decline a transfer pending completion of those checks, or where information received from a counterparty is missing, inaccurate or indicative of risk.

8.3 Irreversibility and Your Responsibility

Blockchain transactions are irreversible. You are solely responsible for the accuracy of the destination address, the blockchain network selected and any required memo or tag. Errors such as sending to an incorrect address or using the wrong network may result in the permanent loss of the Crypto-Asset, for which Pionew accepts no liability.

8.4 Withdrawal Fees and Network Fees

On-chain withdrawals incur a withdrawal fee which is inclusive of any applicable network (gas) fee. Fees are displayed on the Platform before you confirm the transfer. We do not charge a deposit fee for on-chain deposits; however, the sending party may be subject to external network fees or third-party charges that are outside our control.

9. Exchange between Fiat and Crypto-Assets

Pionew provides exchange services allowing you to convert Fiat Currency into Crypto-Assets (on-ramp) and Crypto-Assets into Fiat Currency (off-ramp), subject to the supported payment methods and Crypto-Assets published on the Platform.

9.1 Payment Methods and Name-Matching

Fiat deposits and withdrawals are processed through authorised payment service providers. You must use a payment account held in your own name. We may reject, reverse or return any payment received from a third party or from an unverified source.

9.2 Quoted Rates and Execution

Quoted exchange rates are indicative and valid only for the period displayed. The final rate applied is the rate at which the exchange is executed on the Platform. Exchange rates include a spread that is disclosed on the Platform and in the Fee Schedule.

9.3 Settlement

Fiat settlement times depend on the payment method used and on the relevant payment service provider. Crypto-Asset settlement occurs upon confirmation of the underlying trade and any applicable on-chain movements. We are not liable for delays caused by third-party payment providers, correspondent banks or network congestion.

9.4 Reversals

If you receive funds into your Account that were not intended to be transferred to you (for example, because we have credited your Account incorrectly), we may, after informing you where reasonably possible, remove those funds from your Account.

10. Fees, Costs and Taxes

All fees, costs and charges applicable to the Services are set out in the Fee Schedule published on www.webot.com/eu, in accordance with Articles 75 and 82 of MiCA and the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004. Fees may be expressed as a percentage of the transaction amount or as a fixed amount in EUR. Where fixed fees are displayed in a currency other than EUR, the conversion is made at our wholesale rate at the time of the transaction and no additional foreign exchange fee is applied to the conversion of the fee itself.

Fees are generally deducted from the relevant Available Balance at the time a transaction is executed. If we determine there are insufficient funds to pay any fees due, you authorise us to deduct Fiat Currency or to sell Crypto-Assets from your Account to pay those fees. Our list of fees does not include network or blockchain transaction fees charged by external networks, nor third-party banking or payment provider fees, which are payable by you in addition.

You are solely responsible for determining and discharging any tax liability arising from your use of the Services. Pursuant to Directive (EU) 2023/2226 (“DAC8”), we are required to collect, verify and report information relating to clients and their Crypto-Asset transactions to the Irish Revenue Commissioners, who may in turn share this information with other EU tax authorities. By using the Services you authorise us to collect, process and transmit this information for that purpose.

11. Conflicts of Interest and Applicable Disclosures

11.1 Conflicts of Interest

In accordance with Article 72 of MiCA, we maintain and operate organisational and administrative arrangements designed to identify, prevent, manage and, where appropriate, disclose conflicts of interest that may arise between Pionew, its shareholders, managers, employees, tied agents or any person directly or indirectly linked to Pionew by control, on the one hand, and clients, on the other hand (or between clients). The general nature and sources of conflicts of interest, and the measures we take to mitigate them, are set out in our Conflicts of Interest Policy, which is available on the Platform. Where organisational arrangements are not sufficient to ensure, with reasonable confidence, that risks of damage to your interests will be prevented, we will disclose the conflict to you before undertaking business on your behalf. By using the Services, you acknowledge that conflicts of interest may arise and that you wish to proceed to use the Services on this basis.

11.2 Client Classification

You are treated as a retail client for the purposes of MiCA. We do not classify clients as professional clients or eligible counterparties for the provision of Crypto-Asset Services under these Terms, and all MiCA investor-protection provisions applicable to retail clients will apply to you.

11.3 Operational Resilience

As a financial entity within the scope of Regulation (EU) 2022/2554 (“DORA”), we maintain an ICT risk management framework, business continuity and disaster recovery arrangements, and controls for the management of ICT third-party risk. We periodically test our resilience in accordance with DORA, and will notify you and, where required, the Central Bank of Ireland of any major ICT-related incident in accordance with applicable regulatory timeframes.

11.4 Environmental Disclosures

In accordance with Article 66(5) of MiCA, we publish on the Platform disclosures relating to the principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used to issue the Crypto-Assets in respect of which we provide Services. Where relevant, those disclosures draw on information published in Crypto-Asset white papers.

11.5 Records

We maintain records of the Services we provide and of the related activities and transactions in accordance with our internal document retention policies and Applicable Law, for the periods required by MiCA, the EU AML/CFT framework and Irish law. A copy of records relating to your use of the Services will be provided on request.

11.6 Business Continuity and Transfer

If we merge with, or transfer all or part of our Services to, another entity, we will give you at least two (2) months’ prior notice, so that you can, if you wish, make alternative arrangements. We will ensure that any outstanding business with you is properly completed prior to any such merger or transfer, or that we inform you of how continuity of Service will be provided following any such merger or transfer.

12. Your Obligations and Prohibited Conduct

12.1 Ongoing Eligibility and Compliance

You must at all times remain eligible to use the Platform, comply with Applicable Law (including AML/CFT requirements) and notify us without delay of any change to your personal information, residence, tax residency or sanctions status.

12.2 Prohibited Conduct

You must not, and must not permit any other person to:

use the Platform for money laundering, terrorist financing, sanctions evasion, fraud or any other illegal activity;
deposit Crypto-Assets or funds that are the proceeds of unlawful activity;
provide false, misleading or incomplete information to us;
engage in market abuse or market manipulation (including conduct prohibited under Title VI of MiCA), or submit Orders designed to create a false or misleading impression as to the price, demand or supply of any Crypto-Asset;
use the Platform to transfer Crypto-Assets or funds in a manner designed to obscure beneficial ownership or to circumvent AML/CFT controls;
attempt to reverse-engineer, scrape, decompile or otherwise interfere with the Platform or its underlying software; or
use automated tools (bots, scripts, crawlers) to access the Platform without our prior written consent.

12.3 Self-Reporting

You must contact us without delay if you have reason to believe that you no longer meet our Eligibility Criteria, that your Account has been compromised, or that any prohibited conduct is occurring in connection with your Account.

13. Our Rights, Suspension and Termination

13.1 Our Rights in the Platform

The Platform, its content and all intellectual property rights in it are owned by us or our licensors. You are granted a limited, personal, non-transferable right to access the Platform for the purpose of using the Services. You must not copy, modify or distribute any Platform materials without our prior written consent.

13.2 Availability

The Platform is generally available on a continuous basis, subject to planned and unplanned maintenance. We will endeavour to give reasonable notice of planned downtime but may suspend access without notice where required for security, regulatory or operational reasons.

13.3 Suspension and Restrictions

We may suspend, restrict or terminate your access to the Platform (in whole or in part), or refuse to execute any Order or transaction, where: (i) you breach these Terms; (ii) we are required to do so by Applicable Law, a court order, or a direction of the Central Bank of Ireland or any other competent authority; (iii) we suspect fraud, market abuse or sanctions exposure; (iv) there is a technical or security incident; or (v) your Account has been inactive for an extended period. Where permitted by law, we will notify you of any such action and the reasons for it.

13.4 Termination by You

You may close your Account at any time by submitting a request through the Platform, provided that all outstanding obligations have been discharged. Following closure, we will return any remaining Crypto-Assets or Fiat Currency to a verified address or payment account held in your name, subject to AML/CFT and sanctions checks.

13.5 Termination by Us

We may terminate these Terms by giving you at least two (2) months’ prior notice. We may terminate immediately where you materially breach these Terms, become insolvent, or where continued provision of the Services would breach Applicable Law.

13.6 Consequences of Termination

Termination does not affect rights or obligations that accrued before termination. Clauses concerning fees payable, liability, indemnity, confidentiality, data protection, complaints and dispute resolution shall survive termination.

14. Liability and Indemnity

14.1 Our Liability

Nothing in these Terms 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 Irish or EU consumer protection law. Subject to the foregoing, and to Section 14.2, Pionew shall not be liable for any indirect, consequential, special or punitive loss, loss of profit, loss of data, or loss arising from market movements, blockchain network events, force majeure, or the acts or omissions of third-party service providers where we have exercised reasonable care in their selection and oversight.

14.2 Liability for Loss of Crypto-Assets in Custody

In respect of the custody of Crypto-Assets, our liability is governed by Section 7.7 and Article 75(8) of MiCA.

14.3 Your Indemnity

To the extent permitted by Applicable Law, you shall indemnify us against any loss, claim or expense (including reasonable legal fees) arising from: (i) your breach of these Terms; (ii) your breach of Applicable Law or of the rights of any third party; or (iii) any incorrect or misleading information or instructions provided by you. This indemnity does not apply to losses caused by our gross negligence, fraud or wilful misconduct, and is without prejudice to any statutory protections available to consumers under Irish or EU consumer protection law.

14.4 Basis of Service

The Platform is provided on an “as is” and “as available” basis. We do not warrant that the Platform will be uninterrupted or error-free. We do not provide investment, legal or tax advice, and you are solely responsible for your decisions to buy, sell, hold or transfer any Crypto-Asset.

15. Communications and Complaints

15.1 Communications

We will communicate with you through the Platform, email or other electronic means associated with your Account. Communications will be provided in English. It is your responsibility to keep your contact details current. Instructions submitted through the Platform are binding from the time they are confirmed by our systems.

15.2 Complaints

We are committed to resolving complaints promptly and fairly, in accordance with Article 71 of MiCA, Commission Delegated Regulation (EU) 2025/294, the Consumer Protection Code issued by the Central Bank of Ireland and our Complaints Handling Policy, which is published on the Platform free of charge. Submitting a complaint is free of charge.

You may submit a complaint by any of the following channels:

by email to service@webot.eu;
through the dedicated complaints form on the Platform; or
in writing to:

Pionew Ireland Limited

Office 01, Ground Floor, Penrose Two, Penrose Dock

Cork, Ireland T23 YY09

For the attention of: Complaints Officer

We will acknowledge receipt of your complaint in writing within fifteen (15) business days of receipt, and will provide a substantive final response within thirty (30) calendar days from the date of receipt. Where, in exceptional circumstances, we cannot provide a final response within thirty (30) calendar days, we will inform you in writing before that deadline, explaining the reasons for the delay and stating the date by which we will provide the final response, which will in any event not exceed sixty (60) calendar days from the date of receipt.

Each complaint will be recorded with a unique reference and tracked through to resolution. We publish annual statistics on complaints handling with our competent authority as required by Commission Delegated Regulation (EU) 2025/294.

If you are a consumer and you are not satisfied with our final response, or if we have not issued a final response within the expected time, you may:

refer the matter free of charge to the Financial Services and Pensions Ombudsman (FSPO), Lincoln House, Lincoln Place, Dublin 2, D02 VH29, Ireland — www.fspo.ie — which acts as our designated alternative dispute resolution (ADR) entity for the purposes of Directive 2013/11/EU;
if you are resident in another EEA Member State, use the European Commission’s Online Dispute Resolution (ODR) platform at https://ec.europa.eu/odr; and/or
pursue any legal remedies available to you before the Irish courts or the courts of your Member State of residence.

16. Data Protection

Pionew is the controller of personal data collected in connection with the Services and processes such data in accordance with Regulation (EU) 2016/679 (“GDPR”), the Irish Data Protection Act 2018, MiCA and our Privacy Policy, which is incorporated into these Terms by reference.

We process personal data to provide the Services, comply with AML/CFT, DAC8 and other regulatory obligations, prevent fraud and safeguard our legitimate interests. You have rights of access, rectification, erasure, restriction, portability and objection, subject to the conditions set out in the GDPR. You may contact our Data Protection Officer at dpo@webot.eu and you have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie).

17. Governing Law and Dispute Resolution

These Terms, and any non-contractual obligations arising out of or in connection with them, are governed by the laws of Ireland.

Any dispute arising in connection with these Terms shall be subject to the exclusive jurisdiction of the Irish courts, without prejudice to: (i) your right as a consumer to bring proceedings in the courts of your Member State of residence under Applicable Law; (ii) your right to refer a complaint, free of charge, to the Financial Services and Pensions Ombudsman as our designated ADR entity; and (iii) your right to use the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/odr.

18. General Provisions

18.1 Entire Agreement

These Terms, together with the documents referred to in Section 1, constitute the entire agreement between you and us in relation to the Services, and supersede any previous agreement or understanding between us on the same subject matter.

18.2 Severability

If any provision of these Terms is held to be invalid or unenforceable under Applicable Law, the remaining provisions shall continue in full force and effect.

18.3 Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations to any affiliate or successor, subject to Section 11.6 and to any notice required under Applicable Law.

18.4 No Waiver

A failure or delay by us in exercising any right does not constitute a waiver of that right or of any other right.

18.5 Third-Party Providers

We may engage third-party service providers (including payment institutions, blockchain analytics providers, sub-custodians and cloud infrastructure providers) to support the delivery of the Services. We will exercise reasonable care in their selection and ongoing oversight, and our use of such providers does not affect our regulatory responsibilities under MiCA.

18.6 Third-Party Rights

Save as expressly provided in these Terms, no person other than you and us has any right to enforce any term of these Terms.

18.7 Language

These Terms are concluded in English, and all communications between you and us will be in English, unless we agree otherwise in writing.

Pionew Ireland Limited, Authorised by the Central Bank of Ireland as a Crypto-Asset Service Provider, Registered office: Office 01, Ground Floor, Penrose Two, Penrose Dock, Cork, Ireland T23 YY09, www.webot.com/eu