Welcome to Varto

These Terms of Service (“Terms”) form a legally binding agreement between you and Zuger-see Financial LLC, doing business as Varto (“Varto,” “we,” “us,” or “our”).

These Terms apply to all users of the Services and govern your access to and use of the Varto mobile application and related services (the “Services”).

The availability of specific features and services may vary based on your country of residence and applicable law.

By creating an account or using the Services, you agree to these Terms and consent to receive all communications, disclosures, notices, and agreements related to the Services electronically, including through the Varto App or by email, where permitted by applicable law. You agree that such electronic communications satisfy any legal requirements that such communications be in writing.

You confirm that you are at least eighteen (18) years old and legally able to enter into this agreement.

In addition, you agree to comply with our Privacy Policy, which describes how we collect, use, and protect your personal information. By using the Services, you acknowledge that you have reviewed the Privacy Policy and consent to the processing of your personal information as described therein, and you confirm that the information you provide is accurate and complete.

Please read these Terms carefully, together with any applicable policies and agreements.

These Terms consist of multiple sections, each of which is important and should be read thoroughly. Hyperlinked terms throughout this document provide access to additional information for your convenience.

We may update these Terms & Conditions from time to time. If any change materially reduces your rights or increases your responsibilities, we will provide you with at least 30 days’ prior notice by posting an announcement on our website or within the Services. Your continued use of the Services after any such change constitutes your acceptance of the revised Terms.

The “Last Updated” date at the top of this page reflects the most recent changes to these Terms.

We reserve the right, at any time and without liability, to modify or discontinue any part of the Services (including access through third-party platforms); to impose, modify, or waive fees associated with the Services; or to make the Services, or specific features within them, available to some or all users.

If you do not agree to these Terms, do not use the Services.

About Us

We are Zuger-see Financial LLC, doing business as “Varto,” a Money Services Business registered with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) under MSB Registration Number 31000271862103, and a company incorporated under the laws of the State of Washington, United States of America, with our corporate office located at 1633 SE 84th CT, Vancouver, WA 98664, USA.

Certain regulated services offered through the Varto App, including digital asset and virtual currency transfer services, are provided by or through licensed third-party partners in accordance with applicable law.

Scope of Services

Varto provides access to domestic and cross-border digital asset transfer services through the Varto mobile application, which Varto uses under a license from a third party. The Services are designed to make domestic and international transfers faster and more accessible by leveraging digital assets and modern payment infrastructure.

The Services leverage blockchain technology and supported stablecoins to facilitate the transfer of value across borders.

To access the Services, you must first register for a Varto Account through the Varto App.

A Varto Account enables registered users to access the Services through the Varto application, including initiating transactions, viewing transaction and account activity, and accessing other functionality made available in connection with the Services.

For clarity:

• A Varto Account is not a stored-value account.
• You cannot store or maintain funds in a Varto Account.

To access and use features involving stablecoins, you must also establish an account and a custodial digital asset wallet with Bridge Ventures LLC (“Bridge”), a U.S.-based financial services provider and a partner of Varto.

Wallets are opened and maintained in the United States and are accessible through the Varto application.

You will only be able to access your Bridge Account using the username and password associated with your Varto Account.

Users who are residents of the United States may fund their custodial wallets via Automated Clearing House (ACH) transfers from a U.S. bank account. Funds received through ACH may be converted into stablecoins by Bridge and credited to the user’s custodial wallet operated by Bridge.

Users who are residents of the Philippines may fund their custodial wallets by receiving stablecoins transferred from other users.

The Services allow users to initiate cross-border transfers through the Varto application using stablecoins. Such stablecoins may be converted to fiat currency and paid out to a recipient’s bank account or mobile wallet in the Philippines by a licensed third-party service provider in the Philippines that partners with Varto.

Important User Responsibilities

The Service is intended for personal use only. Business or commercial use is prohibited unless we expressly agree in writing.

You should send money only to individuals you know and trust, such as family or close friends.

Do not use the Service to send money to:

• strangers,
• unfamiliar contacts,
• individuals you do not trust, or
• persons involved in unsolicited or suspicious requests.

We strongly encourage you to remain vigilant against fraud. Be cautious of:

• unsolicited offers,
• high-pressure situations,
• requests from unknown parties,
• or opportunities that appear “too good to be true.”

If you are uncertain about a transfer, pause and verify before sending money.

Getting Started

To begin using the Varto Services, you must first download the Varto App and complete the registration process to create your Varto Account.

Registration Requirements

To create a Varto Account, you will be required to provide the following information during registration:

• a valid mobile phone number,
• a valid email address,
• a secure passcode that will be used to log in to your account.

Verification Requirements

As part of our security measures, Varto requires verification of your phone number and email address to confirm their validity and ownership.

This verification is essential to authenticate your identity and ensure the security of your Varto Account.

Verifying your contact information allows us to:

• assist you in recovering access to your account if needed,
• alert you to any unauthorized changes to your phone number, email address, or account credentials,
• ensure timely delivery of important updates about your transfers and account activity.

By providing and verifying accurate contact details, you help us maintain the integrity and security of the Services.

SMS Terms & Conditions

Varto uses SMS messages as part of its security and authentication process. By creating a Varto Account and providing your mobile phone number, you consent to receive SMS messages for purposes related to account access and security.

Purpose of SMS Messages

Varto sends SMS messages exclusively for the following purposes:

• account registration and activation,
• login authentication and delivery of one-time passwords (OTP),
• identity verification,
• verification of contact information,
• important security alerts related to your Varto Account.

Varto does not send marketing or promotional SMS messages.

Your Consent

By providing your mobile number and selecting Continue, you give express consent to receive SMS messages from Varto for the purposes described above. SMS verification is required to access and use your Varto Account.

Message Frequency

Message frequency varies depending on your activity, such as login attempts or verification requirements.

Message & Data Rates

Your mobile carrier may apply standard message and data rates. Varto is not responsible for carrier charges.

STOP Instructions

You may opt out of receiving SMS messages at any time by replying STOP.

After sending STOP, you will receive a confirmation message. However, opting out of SMS messages may prevent you from accessing your Varto Account, as SMS-based verification is required for security purposes. If you want to join again, reply START, or re-enable SMS within the app.

HELP Instructions

For assistance, reply HELP to any Varto message or contact us at:

support@varto.app

Delivery and Carrier Limitations

SMS delivery may depend on mobile carrier networks, and Varto cannot guarantee delivery of SMS messages.

Accuracy of Contact Information

You must provide a valid mobile phone number and notify us promptly if your number changes.

Failure to maintain accurate contact information may limit or prevent access to your account.

Program Changes

Varto may modify or discontinue its SMS authentication program at any time as required by law, mobile carrier requirements, or operational needs.

Partner Services

Certain features of the Services, including custodial digital asset wallet services and stablecoin-related functionality, are provided by Bridge Ventures LLC (“Bridge”), a U.S.-based financial services provider and a partner of Varto.

By accessing or using any wallet-related features or other services provided by Bridge, you acknowledge and agree that your use of such services is subject to Bridge’s applicable terms of service and privacy policy, as may be updated by Bridge from time to time.

Bridge’s terms of service and privacy policy will be made available to you through the Varto App and may also be accessed via links provided in connection with the Services.

As a condition of using the Services and the services provided by Bridge, you agree to provide accurate and complete information about yourself and authorize Varto to share your information, as well as transaction-related data, with Bridge and other service providers as reasonably necessary to provide the Services, support wallet and transaction functionality, and comply with applicable law.

Bridge provides custodial wallet services pursuant to its own terms and policies. Varto does not control and is not responsible for Bridge’s services, except as expressly described in these Terms.

Identity Verification

Varto and its partners (including Bridge) are required to comply with U.S. laws relating to anti‑money laundering (AML), counter‑terrorist financing (CTF), sanctions, Section 326 of the USA PATRIOT ACT and consumer protection.

You authorize us and our service providers to:

• verify your identity;
• conduct ongoing monitoring;
• obtain information from third‑party verification providers.

Failure to complete verification may result in suspension or termination of access to the Services.

To provide a secure and efficient verification process, we may engage trusted third-party identity verification providers.

Depending on the specific situation, you may be asked to:

• Name
• Date of Birth
• Place of residence
• Taxpayer Identification Number (i.e., Social Security Number) for U.S. persons
• One or more for a non-U.S. person:
• A taxpayer identification number,
• Passport number and country of issuance,
• Alien identification card number, or
• Number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

Authorization

You authorize Varto to make any inquiries, directly or through third parties, that we deem reasonably necessary to validate the information you provide. This may include verifying your identity through third-party databases, information service providers, or other reliable sources.

We reserve the right to request additional documentation or information at any time to confirm your identity and to require you to take specific actions to verify ownership of your phone number, email address, or any payment instrument associated with your account.

Sending a Transfer

General

Through your Varto Account, you may initiate digital asset–based transfers (each, a “Transfer”) to designated Recipients by providing the required information about yourself and the Recipient.

A Recipient may receive funds even if they do not have a Varto Account.

To initiate a transfer, you must ensure that:

• all information you provide is accurate and complete,
• you have sufficient available balance in your custodial wallet to complete the transfer,
• the transfer complies with these Terms, the applicable terms of Bridge, and all applicable laws and regulations.

Varto may request additional information about the Sender, the Recipient, or the purpose of the transfer before processing.

Processing Your Transfer

By submitting a transfer request, you authorize Varto to process the Transaction on your behalf in accordance with your instructions.

Varto reserves the right, in its sole discretion, to accept or reject any transfer request submitted through your Varto Account, including circumstances where:

• the transfer may violate these Terms or applicable law,
• the transfer appears to be potentially fraudulent, unauthorized, or high-risk,
• required information is incomplete, inaccurate, or cannot be verified,
• regulatory or compliance screening (including AML/OFAC checks) requires rejection or delay.

Varto has no obligation to process any transfer that does not fully satisfy our requirements or those of our partners.

Accuracy of Transfer Information

You are solely responsible for ensuring that all information provided in connection with a transfer, including the Recipient’s name, payment details, and contact information - is complete and accurate. Once a transfer has been submitted, it may not be possible to change its details. Subject to applicable law, you agree that you will be bound by all payment instructions initiated through your Varto Account, and that Varto will not be liable for any losses resulting from your provision of incorrect or incomplete transfer details.

Due to the nature of blockchain transactions, transfers involving digital assets may be irreversible once initiated.

Varto’s Limitation of Liability

Subject to applicable law, Varto shall not be liable for any failure to complete a transfer in any of the following circumstances:

• the payment instructions you provide are incomplete, inaccurate, or contain errors;
• the custodial wallet does not have sufficient funds;
• we are unable to verify your identity or the legitimacy of the transfer;
• processing the transfer would violate these Terms, applicable law, or regulatory requirements;
• processing is delayed or prevented due to compliance screening, fraud monitoring, or third-party partner requirements;
• technical issues or outages occur outside of Varto’s reasonable control, including those involving partner financial institutions, other licensed service providers, or telecommunications networks.

To the fullest extent permitted by law, Varto shall not be liable for indirect, incidental, punitive, or consequential damages arising out of your use of the Service.

Service Fees

In exchange for your use of the Service, you agree to pay a service fee (“Service Fee”) for each transfer you initiate, in addition to the principal amount of the transfer (“transfer amount”).

The applicable Service Fee will be clearly disclosed within the Varto App or website prior to your authorization of the transfer.

Service Fees:

• are payable at the time the transfer is submitted and may be assessed in stablecoins, fiat currency, or their equivalent, depending on the applicable transaction flow.
• may vary depending on the Recipient’s country, currency, payout method, or other factors,
• are subject to change at Varto’s discretion.

You authorize Varto to collect Service Fees.

Foreign Currency Exchange

If your transfer involves currency conversion, Varto and/or its service providers may earn revenue from the difference between:

• the exchange rate at which we acquire foreign currency, and
• the exchange rate provided to you.

The applicable exchange rate will be displayed before you authorize the transfer.

Exchange rates vary by destination country and may change without notice.

Third-Party Fees

You are solely responsible for any fees, charges, or costs imposed by third parties in connection with your use of the Service.

These may include fees from your:

• the bank at which you maintain your account,
• mobile service provider,
• internet service provider.

Such charges may include data fees, SMS/text message fees, international transaction fees, or other charges under your agreements with these providers.

Receiving a Transfer

Fiat Payouts in the Philippines

For transfers involving recipients in the Philippines, the conversion of stablecoins to fiat currency and the delivery of funds to the designated recipient are performed by an independent, licensed off-ramp service provider in the Philippines that partners with Varto.

Upon initiation of a withdrawal or payout request through the Varto application, stablecoins may be debited from the user’s custodial wallet operated by Bridge and transferred to the off-ramp provider for conversion into fiat currency. The off-ramp provider is responsible for executing the fiat payout to the recipient using the payout method selected by the user, which may include transfer to a bank account, credit to a mobile wallet, or other supported payout methods, in accordance with applicable Philippine law.

Varto does not perform fiat currency conversion, hold fiat funds, or execute local payouts in the Philippines. The off-ramp provider is solely responsible for compliance with local regulatory requirements applicable to fiat conversion and payout services, including consumer protection obligations.

Recipient Verification

To ensure secure delivery and compliance with local and international regulations, Recipients may be required to verify their identity before receiving funds.

Verification requirements may include:

• presenting a valid government-issued photo ID,
• providing a reference number or transfer identifier,
• completing additional verification steps required by local law or applicable regulatory authorities.

Failure to satisfy verification requirements may delay or prevent disbursement.

U.S. Transfer Disclosures; Cancellation, Refunds, and Digital Asset Risks

If you initiate a transfer from the United States for personal, family, or household purposes, you may have certain rights under applicable law, where applicable, including the right to receive pre-transaction disclosures and receipts, the right to cancel certain transfers within a limited time after initiation, and the right to dispute errors. Information about applicable timeframes, cancellation rights, refund eligibility, and how to submit an error notice will be provided in the Varto App in connection with your transfer and in our applicable disclosures.

Certain Services may involve the use of stablecoins, blockchain networks, or other digital assets. Digital asset transactions involve risks and may be subject to market, liquidity, operational, or regulatory factors. Blockchain transactions may be irreversible, and once initiated, a transfer may not be recoverable. Varto is not a bank, and Varto Accounts are not FDIC-insured. Custodial wallet services and digital asset custody may be provided by third-party partners under their own terms. Varto does not control blockchain networks and does not guarantee their performance, availability, security, or finality.

Right to Limit or Refuse Service

Varto reserves the right, in its sole discretion and in accordance with applicable laws and regulations, to limit, delay, or refuse to process any transfer. We may take such actions when we reasonably believe it is necessary to:

• protect you or Varto from fraud, unauthorized activity, or financial risk;
• comply with applicable laws, regulations, court orders, or regulatory obligations;
• manage transfer volume, compliance requirements, or system integrity;
• enforce our internal policies, risk controls, or partner requirements.

We may impose transfer limits on either a per-transfer basis or as an aggregate limit over a period of time. Limits may be applied to your Varto Account, your identity profile, or specific transaction types. Varto may modify, suspend, or discontinue any aspect of the Service at any time and without prior notice.

Transfer Speed

Estimated delivery times displayed in the Varto App are for informational purposes only and are not guaranteed.

Delivery times may vary depending on:

• the payout method;
• transfer review requirements;
• availability and hours of Payout Providers;
• system performance or network delays.

We will provide an estimated delivery date and time prior to your authorization of a transfer.

Eligibility and Sanctions Compliance

Varto may restrict or reject transfer to or from individuals that appear on sanctions, watchlists, or restricted-party lists issued by regulatory bodies, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

We may also restrict transfer involving:

• specific recipients or counterparties;
• activities inconsistent with sanctions programs or partner requirements.

We reserve the right to block or delay transfer deemed to violate, or pose a risk of violating, sanctions, AML, CFT, or other applicable laws.

Prohibited Activities

You agree not to use the Service to engage in, or facilitate, any of the following (“Prohibited Activities”): unlawful or abusive activity, fraud, unlawful gambling, intellectual property infringement, investment or credit services, check cashing, bail bonds, collections agencies, counterfeit or unauthorized goods, drugs and drug paraphernalia (including pseudo pharmaceuticals), substances designed to mimic illegal drugs, adult content and services, multi-level marketing, unfair, predatory or deceptive practices, operating a money services business for third parties and any business that Varto believes poses elevated financial risk, legal liability, or violate card network rules or bank policies. Varto may update this Prohibited Activities List at any time upon notice to you.

Enforcement Actions

If Varto determines, in its sole discretion, that you have engaged in a Prohibited Activity, we may take one or more of the following actions:

• delay, cancel, reverse, or amend any pending transfer;
• suspend or terminate your Varto Account;
• restrict your access to certain Services;
• report your activity to law enforcement, regulators, financial institutions, or partners;
• refuse to process instructions or content associated with the activity.

Where permitted by law, we will make reasonable efforts to notify you of any such action.

Undeliverable Transactions

If Varto or its partner determines that a transfer cannot be completed due to incorrect or incomplete information, you will be notified and asked to provide corrected or additional details.

If you do not provide corrected information within 72 hours, Varto may cancel the transfer.

In such cases, you will receive a refund of the full transfer amount and applicable Service Fees.

Complaints and Dispute Resolution

Submitting a Complaint

We are committed to providing a high-quality Service. If you are dissatisfied with your experience, you have the right to submit a complaint.

In most cases, issues can be resolved quickly by contacting Customer Support through one of the following channels:

• Email: support@varto.app
• Varto App: Contact Support section

If your concern cannot be resolved through Customer Support, you may submit a formal complaint as described below.

What to Expect After You Submit a Complaint

After receiving your complaint, Varto will:

• acknowledge receipt of your complaint by email;
• request additional information if necessary to understand the issue;
• conduct a review and investigation in accordance with these Terms and applicable law; and
• provide a written response explaining the outcome and any corrective actions taken, if applicable.

Response Timelines

We aim to:

• acknowledge receipt of your complaint within 24 hours; and
• provide a final written response within 15 calendar days.

If exceptional circumstances require additional time, we may extend the response period up to 35 calendar days. You will be notified by email if an extension is required.

Scope of Disputes

Please read this section carefully. It affects your legal rights.

For purposes of these Terms, a “Claim” means any past, present, or future dispute, claim, or controversy arising out of or relating to these Terms, your use of the Services, or any activities or relationships resulting from these Terms.

Informal Dispute Resolution

Before initiating arbitration or filing an action in small claims court, you and Varto agree to first attempt to resolve any Claim informally.

The informal dispute resolution process requires a sixty (60) day period, which begins when either party sends a written notice of the Claim (a “Claim Notice”) to the other party.

A Claim Notice must include:

• a brief description of the Claim; and
• the relevant facts and legal basis supporting the Claim.

You must send your Claim Notice to:

Attn: CEO and President

Zuger-See Financial LLC

1633 SE 84th CT

Vancouver, WA 98664

USA

If Varto sends a Claim Notice to you, it will be sent to the email address associated with your Varto Account.

During the informal resolution period, any applicable statute of limitations will be tolled.

Requirement to Complete Informal Process

Completion of the informal dispute resolution process is a mandatory condition precedent to initiating arbitration or filing a small claims court action.

If the Claim is not resolved within the sixty (60) day informal resolution period, either you or Varto may proceed with arbitration or a small claims court action, as permitted under these Terms.

Failure to provide a valid Claim Notice or to complete the informal resolution process may result in dismissal of the Claim.

Arbitration; Class Action Waiver. If a Claim is not resolved through the informal dispute resolution process, you and Varto agree that any Claim will be resolved by binding arbitration administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules, rather than in court, except that either party may bring an individual action in small claims court if the claim qualifies. Arbitration will be conducted on an individual basis only; class actions and class arbitrations are not permitted. You and Varto waive any right to a jury trial. We will pay arbitration fees as required by the AAA Consumer Arbitration Rules.

Opt-out. You may opt out of this arbitration agreement by sending written notice to support@varto.app within 30 days of first accepting these Terms, including your name and the email address and/or phone number associated with your account.

Safety and Security of Your Devices

You are responsible for maintaining the safety and security of any device you use to access the Varto application and the Services, including protecting your device, login credentials, and any authentication methods associated with your account.

Varto implements reasonable administrative, technical, and physical safeguards designed to protect the security and integrity of the Services. In addition, certain security controls related to custodial wallet services are implemented by Bridge Ventures LLC (“Bridge”) and other third-party service providers involved in processing transactions and safeguarding digital assets.

While we take steps to help protect the Services, Varto does not control the security of your personal devices or networks and is not responsible for any loss, damage, or interruption caused by malware, viruses, unauthorized access, phishing, spoofing, or other malicious activities that may affect your device or credentials. You are responsible for keeping your device software and applications up to date.

If you become aware of or reasonably suspect (i) the loss, theft, or compromise of your device, login credentials, or authentication methods; (ii) any unauthorized access to or use of your Varto Account; or (iii) any fraudulent or suspicious activity, you must notify Varto promptly through the support channels made available in the Varto application.

Term and Termination

Duration of the Terms

These Terms become effective when you accept them, as described in the Preamble, and remain in effect until terminated in accordance with this section.

Termination by You

You may terminate these Terms at any time by closing your Varto Account through the Varto App, subject to the completion of any pending transactions and payment of any outstanding fees.

Termination by Varto

Varto may terminate these Terms or suspend or close your Varto Account:

• for convenience, by providing at least fifteen (15) days’ prior notice; or
• immediately and without prior notice, if you violate these Terms, any applicable policies, or engage in any Prohibited Activities, or if required by applicable law or regulation.

Effect of Account Closure or Termination

Upon termination of these Terms or closure of your Varto Account:

• you must immediately stop using the Services;
• Varto may retain your personal information and transaction data as required or permitted by applicable law;
• Varto may delete your data where permitted by law and in accordance with its Privacy Policy; and
• Varto will not be liable for any loss of access to the Services or any resulting deletion of data, to the extent permitted by law.

Outstanding Fees

Termination of these Terms does not relieve you of any obligation to pay Service Fees or other charges incurred prior to the effective date of termination.

Survival

Any provisio