1. Introduction
This Acceptable Use Policy (“Policy”) governs the use of all services provided by Zuger-see Financial LLC, a registered Money Services Business (MSB) in the United States, operating the VARTO mobile financial application ("VARTO").
This Policy forms an integral part of the User Agreement and is binding upon all users accessing or using the VARTO application or related services (“Services”).
By using VARTO, you agree to comply with the terms set forth herein.
2. Permitted Use
You may use the VARTO Services solely for lawful purposes, including but not limited to:
- Personal peer-to-peer (P2P) transfers;
- Bill payments;
- E-commerce transactions;
- Sending personal remittances to eligible recipients abroad in accordance with applicable law.
You represent and warrant that you will not use the Services for any prohibited or unauthorized purpose.
3. Prohibited Uses and Activities
You may not use VARTO Services:
- In violation of any local, state, federal, or international law, regulation, or sanctions regime;
- In any manner that is fraudulent, deceptive, misleading, or abusive;
- To exploit or harm minors;
- To transmit, distribute, or facilitate the distribution of spam, unsolicited communications, or malware;
- To conduct or facilitate money laundering, terrorist financing, or tax evasion activities;
- To engage in activities that may expose Zuger-see Financial LLC to reputational or legal risk.
4. Prohibited Transactions and Business Activities including but not limited to
4.1 Illegal or Restricted Products and Services
- Adult content, pornography, sexual services;
- Alcohol, tobacco, cannabis products, controlled substances;
- Unapproved pharmaceuticals, nutraceuticals, or supplements making false health claims;
- Explosives, hazardous chemicals, or dangerous materials;
- Counterfeit goods, intellectual property infringement.
4.2 Gambling and Betting Services
- Gambling, lotteries, fantasy sports, games of chance, or any unauthorized wagering activities;
- Transactions supporting gambling activities in restricted jurisdictions.
4.3 Unlicensed or High-Risk Financial Services
- Binary options trading, unlicensed forex, CFDs;
- Escrow services, unless pre-approved in writing;
- Unlicensed trust or corporate service providers, shell banks, or illegal superannuation funds.
4.4 Other Prohibited Activities
- Trafficking of weapons, military equipment, or dual-use goods;
- Transactions involving sanctioned individuals, entities, or jurisdictions (as determined by OFAC, UN, EU, or other authorities);
- Multi-level marketing schemes, Ponzi schemes, or other deceptive investment programs;
- Trafficking in endangered species or derivatives thereof;
- Operations involving unregistered charities or nonprofit entities from jurisdictions not approved by Zuger-see Financial LLC.
5. Use of VARTO Accounts
Use of Varto accounts for unlicensed business activities is prohibited. Zuger-see Financial LLC reserves the right to review and terminate accounts suspected of business-related or prohibited usage.
- Personal remittance to family and friends;
- Authorized digital wallet transactions;
- Payments for personal goods and services.
Use of Varto accounts for unlicensed business activities is prohibited. Zuger-see Financial LLC reserves the right to review and terminate accounts suspected of business-related or prohibited usage.
6. How We Share Your Information
We do not sell your personal information. However, we may share your data with:
- Service Providers: Including payment processors, compliance vendors (e.g., Plaid), and fraud detection services;
- Regulatory Authorities: Such as FinCEN, IRS, or law enforcement;
- Financial Institutions and Partners: As required to process your transactions;
- Business Transfers: In the event of a merger, acquisition, or asset sale;
- Analytics and push notification service providers.
7. Enforcement and Remedies
Zuger-see Financial LLC may, at its sole discretion:
- Suspend, restrict, or terminate your access to VARTO Services for violations of this Policy;
- Cancel or reject any transaction inconsistent with this Policy or applicable laws;
- Report violations to relevant regulatory or law enforcement authorities;
- Seek legal remedies, including but not limited to damages and injunctive relief.
8. Modifications
Zuger-see Financial LLC reserves the right to amend this Policy at any time. Updates will be posted on the VARTO website or application. Continued use of the Services constitutes acceptance of the revised Policy.
9. Governing Law
This Policy shall be governed by and construed in accordance with the laws of the State of Washington, USA, without regard to its conflict of law provisions.
10. Contact Information
For questions regarding this Policy, please contact:
Compliance Department
Zuger-see Financial LLC
Email: compliance@zuger-see.com