Custody & Administration Standard Agreement
1 The Agreement
These Terms constitute a legally binding agreement between you (also referred to herein as “you”, “your”, “User,” or “Client”) and Pionew Ireland Limited (also referred to herein as “Pionew”, “Webot” “we”, “our” or “us”). This agreement governs the terms on which Pionew Ireland Limited provides custody and administration of Crypto-assets on behalf of the Client, as defined under Article 75 of the Markets in Crypto-Assets Regulation (MiCAR)
By entering into this agreement, you acknowledge that you have read, understood, and accepted the terms set out herein and that these terms constitute a legally binding contract.
Electronic contracts
You acknowledge and agree that you are satisfied that electronically executed contracts are enforceable despite the legal risks associated with them. You agree not to dispute the contents of any notice or communication sent by us using electronic equipment.
2 About Us
Pionew Ireland Limited trading as Webot is a Crypto-asset Service Provider (CASP) registered with the Central Bank of Ireland on 11 July 2023, specialising in innovative financial solutions within the Crypto-asset sector. We offer secure, compliant, and user-friendly solutions to Clients looking to transact in Crypto-assets.
We operate a Crypto-asset trading platform, www.webot.com/eu.
3 Definitions
You agree and understand that the defined terms used in this Custody Agreement, if not defined in our User Agreement, shall have the meanings set forth below:
Available Balance means your Total Asset Value less any amounts held for Open Orders and Fees.
Available Jurisdiction means a jurisdiction where the Platform is available for service.
Blockchain Address means a public address on a blockchain in which Crypto-assets can be held (for example, a Bitcoin address for Bitcoins).
Business Day means a day that is not a Saturday, Sunday or Bank Holidays in Europe.
Crypto-asset means any asset that is:
- expressed as a unit;
- capable of being transferred, stored and traded on a peer-to-peer basis, with or without conditions or limitations; and
- approved by Pionew Ireland Limited 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:
(i) is transferred on any additional layer on top of a blockchain relating to another Crypto-asset or any side chain; or
(ii) is a derivative of another Crypto-asset, has enhanced features or functionality that supplements or interacts with another Crypto-asset, is to be treated as a distinct Crypto-asset from such other Crypto-asset and its use in connection with the Services will be subject to approval by Pionew Ireland.
Custody means Pionew Ireland Limited providing the service of safekeeping Crypto-assets on behalf of its clients, including the holding and protection of the private cryptographic keys necessary to access and transfer to those assets, while ensuring the secure, segregated, and traceable storage of Clients’ Crypto-assets.
Financial Crime Regulation means any Applicable Law, internal policy or regulatory requirement pertaining to money laundering, terrorism financing, bribery, corruption, Tax evasion, fraud, the trafficking of arms, drugs, humans or wildlife, slavery, proliferation of weapons of mass destruction, or evasion of sanctions. A reference to a violation of Financial Crime Regulation includes any acts or attempts to circumvent or violate any Applicable Laws relating to Financial Crime Regulation.
Platform means www.webot.com/eu, which is operated by Pionew Ireland in accordance with the Agreement.
Standard Agreement means this document.
Wallet means any Crypto-asset Wallet provided to you by us.
4 Custody and Administration
Pionew Ireland Limited will provide custody and administration services for the Crypto-assets of Clients which are held on the Platform on behalf of Clients.
Webot will not provide custody and administration services for any party other than Clients who hold Crypto-assets on the Platform.
Crypto-assets for each Client are recorded in a dedicated Client Webot Wallet.
Each Webot Client will be assigned a series of Wallets with a unique blockchain address for each Wallet, specific to you, which enables you to deposit Crypto-assets to your own Wallet address. You will be assigned a unique Wallet address for each blockchain supported by us from time to time for the purpose of Crypto-asset transfers. You are responsible for ensuring that you use the corresponding Wallet address for the specific blockchain you choose at your own discretion when initiating any Crypto-asset transfers.
In support of consumer protection, clients will not be issued with the private keys to the Wallets as these are the most sensitive pieces of information from a security perspective and sharing them increases the risk of theft, hacking, or unauthorised transactions.
Your Wallet enables you to store, track, transfer, and manage your balances of supported Crypto-assets. Your Webot Wallet is intended for use with supported Crypto-assets as outlined on the Platform. It is important that you do not attempt to use your Webot Wallet to store, send, request, or receive any Crypto-assets other than those which are supported by the Platform. Otherwise, you may suffer loss of assets if you attempt to send unsupported Crypto-assets to your Wallet with us.
You acknowledge and agree that Pionew Ireland Limited is not liable for any unsupported Crypto-asset that is sent to a Wallet. We may terminate support for certain Crypto-assets due to compliance, regulatory or technical reasons. If you do not sell or send such Crypto-assets off platform prior to Webot terminating its support for such Crypto-assets, then Pionew Ireland Limited may, at its discretion, remove such Assets from your Webot Wallet and credit your Wallet with the equivalent market value of a Supported Crypto-asset or fiat currency minus transaction costs. If you have any questions about our current list of supported Crypto-assets, please visit our website or contact us.
You shall also understand and accept that:
(a) any Crypto-assets we hold on your behalf do not enjoy the same protections as are available in respect of traditional credit institution deposits and financial products (for example, the Deposit Guarantee Scheme administered by the Central Bank of Ireland); and
(b) under no circumstances are we under any duty to return to you any Crypto-assets originally delivered to, or otherwise held by, us, but we have a duty to send you assets of an identical type, and in the same nominal amount, of the Crypto-assets we hold on your behalf, subject to other rights of yours under this Agreement and the Applicable Law.
5 Transfer Services
The Platform facilitates the on-chain transfer of supported Crypto-assets to external/destination blockchain wallets, as selected by our Clients. In order to ensure an accurate transfer of your assets, it’s important that a series of steps are followed to ensure that both accurate and secure transfers are executed by you. This includes:
To initiate the transfer process, you must first check the receiving wallet address and verify that it supports the specific Crypto-asset that you intend to transfer. It is important that the correct blockchain and wallet address are used when sending to or receiving from an external wallet, in order to ensure that the chosen blockchain network matches the one to be used for the transfer, a step that is crucial in order to prevent the potential loss of assets due to network incompatibility.
You may log into the Platform with your credentials and two factor authentication, and navigate to the withdrawal section, where you can enter the blockchain address of the destination wallet, select the appropriate blockchain network, specify the amount to transfer, and review any applicable withdrawal fees. The applicable withdrawal fee will be deducted from the transfer amount, and the net proceeds of the transfer will be displayed for your reference before you confirm the transfer. An estimated timeframe for confirmation of the transfer by the blockchain network may also be provided for your reference; however, the actual confirmation time will depend on the conditions of the blockchain at the time of transfer. As this is beyond our control, we make no guarantees or commitments regarding the timing of such confirmation.
It is important that you check and confirm all associated details of the transfers are complete and accurate. Errors, such as using the wrong Wallet address or network, may result in irreversible losses of your assets. To support consumer protection and to increase awareness, customer facing warnings are shared on the Webot platform, as a reminder to verify that details are correct, prior to executing the transfer.
Once the transaction is approved by us upon completion of the necessary compliance checks, it is broadcast to the blockchain, where it undergoes confirmation by network validators, with the time required for this confirmation varying, depending on network congestion and the specific blockchain being used by the Client.
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 Webot Wallet from an external source, whether from another CASP or a self-hosted blockchain 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/or applicable charges imposed by the blockchain network validators and/or third-party CASPs, will be credited to your Webot 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, any third-party CASPs, your wallet service providers, or the blockchain network itself.
6 Exercise of Rights Attached to Crypto-assets
We will facilitate the exercise of rights attached to your Crypto-assets. You will be notified of any event that may create or modify the rights associated with your Crypto-assets. You will be entitled to any newly created Crypto-assets or rights arising from such events, based on and in proportion to your positions at the time of the occurrence of that change or event.
7 Statements of Your Crypto-assets
Your Crypto-assets are segregated from the Crypto-asset holdings of Webot. Also, your Crypto-assets will be segregated from our estate in your interest, which means creditors of Webot, if any, shall have no recourse to your Crypto-assets, in particular in the event of insolvency.
8 Asset Segregation
Pionew Ireland Limited records, internal client position registers, and the platform ledger, with these end-of-day reconciliations being designed to verify that all transaction entries and Crypto-asset balances are complete, accurate, and properly attributed to the correct client accounts. Any discrepancies are promptly investigated and resolved through established escalation and incident response procedures, and this approach ensures ongoing compliance with MiCAR while also enabling Webot to maintain a high standard of client asset protection.
9 Security Systems
We have implemented and are committed to continuously maintaining ICT systems, protocols and tools that are robust, secure, and scalable in full alignment with applicable EU regulations. These systems are designed to manage ICT risk effectively and ensure operational continuity under both normal and stressed market conditions.
In case of any loss of your Crypto-assets as a result of an incident that is attributable to Webot, we will be liable to you for the loss of any Crypto-assets or of the means of access to the Crypto-assets, and our liability will be limited to the market value of the Crypto-asset that you lost, at the time the loss occurred.
Incidents not attributable to Webot include any event that occurred independently of the provision of Webot services, or independently of the operations of Webot, such as a problem caused by the operation of any blockchain network, which Webot does not control. In such cases of any loss of your Crypto-assets as a result of an incident that is not attributable to Webot, we will not be liable to you for the loss of any Crypto-assets.
10 Fees
- Crypto-asset withdrawals incur a gas fee in the case of on-chain withdrawals (i.e. a withdrawal of a Crypto-asset from one platform provider to another). Gas fees are ultimately charged by validators on blockchains, and can vary among different blockchains based on the technology of each blockchain. A withdrawal fee, inclusive of any applicable gas fees, will be charged when you initiate an on-chain withdrawal. The applicable fee will be clearly displayed on our Platform prior to your confirmation of the withdrawal.
- We do not charge any deposit or gas fees for on-chain deposits of Crypto-assets.
11 Applicable Law
Unless otherwise specified, this Agreement and your use of the custody and administration services of Crypto-assets provided by Pionew Ireland Limited are governed by the law in force in the Republic of Ireland.
12 Means of Communication
Clients may communicate with us, and receive information, through secure electronic channels including our official website, and designated customer service email 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 mail, in your Webot account profile.
It is your responsibility to ensure that the details of your Agreed Communication Method are correct and the Agreed Communication Method is operational and available for receipt of all communications and to notify us of any changes to the details of your Agreed Communication Method as soon as practicable after the change is made.
In some cases, our communications may only be posted on the Platform.
12.2 Notice to us
Notices to us should be sent electronically to our support system at service@webot.eu
13 Customer Complaints
At Webot, we are committed to accountability, transparency, and continuous improvement in our work and conduct. You may send us complaints in relation to any aspect of our business.
Complaints may be submitted electronically to service@webot.eu or alternatively in writing to Office 1C North Valley Business Park, Old Mallow Road, Cork, T23 WN15, IRELAND