Welcome to Varto!

Thank you for choosing Varto, where our mission is to empower lives through reliable financial services that connect communities across borders.

This Customer Agreement (“Agreement”) is a legally binding contract between you and Zuger-see Financial LLC (™ Varto). It outlines the terms and conditions governing your use of:

1. Our website at www.varto.app and any of its subdomains;
2. Any mobile application(s) we provide that are governed by this Agreement (each referred to as a “VartoApp”);
3. All services, content, and features made available through our website or VartoApp (collectively referred to as the “Services”).

Please note: This Customer Agreement applies exclusively to users with Varto accounts based in the United States.

By registering for or using a Varto Account—or by otherwise accessing or using our Services—you agree to be bound by this Customer Agreement. You also consent to receive all communications related to your Varto Account and the Services in electronic form, as detailed in the Electronic communication (E-sign agreement) , which includes important disclosures and your consent to use electronic signatures (E-Sign Consent).

By agreeing to this Customer Agreement, you confirm that you are at least eighteen (18) years old and legally capable of entering into a binding contract.

In addition, you agree to comply with the following policies and any other applicable agreements:

• Our Privacy Policy, which outlines how we collect, use, and protect your personal data. By using the Services, you consent to this data processing and confirm that the information you provide is accurate and complete.
• Our Acceptable Use Policy, which defines the acceptable and prohibited uses of the Services.
• Our Cookie Policy which defines what cookies are and why they are used, such as enhancing user experience, analytics, or marketing purposes.
• Our Frequently Asked Questions (FAQs), which provide helpful information on using our Services and are incorporated by reference into this Customer Agreement.

Please review all the terms of this Customer Agreement, along with the associated policies and any other applicable agreements, carefully. This Agreement consists 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 this Customer Agreement 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 Agreement.

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

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 the terms of this Agreement, you must not use any Varto Service.

About Us

We are ZUGER-SEE FINANCIAL LLC (™ Varto), a money service business company incorporated under the laws of Washington State, United States of America and having its corporate office at: 1633 SE 84th CT, Vancouver, WA 98664 USA. We are licensed as a money transmitter in Washington state. We offer our Services only in U.S. states where we are either licensed or where no licensing is currently required to provide such Services. In other U.S. states, our Services are offered exclusively in partnership with financial institutions.

Using Our Service

To access certain Services, you must first register for an account (a “Varto Account”) through the Varto App. During the registration process, you will be required to provide your phone number, email address, and create a secure passcode.

Your access to the Varto Account and the ability to use the Service is subject to the successful completion of our identity verification process, as required by applicable laws and regulations. Once verified, you will be able to use your Varto Account to initiate money transfers, view your transaction history, and access other available features.

Your Varto account

The Varto account-a Service enables registered Customers to send international money transfers from the United States to recipients (“Recipients”) located in countries where Varto currently has Payout partners. A full list of supported destination countries is available on our website and in the Varto App. Please note that Varto may, at its discretion and without prior notice, suspend or discontinue money transfer services to any country - either temporarily or permanently.

For clarity, a Varto Account is not a stored value account or a balance-holding account. You cannot store or maintain funds in a Varto Account.

Should you choose to terminate this Agreement after opening a Varto Account, you may do so at any time by closing your Varto Account.

Within the context of the Service:

• A "Sender" is a user who initiates a money transfer.
• A "Recipient" is the individual who receives the funds sent through the Service.
• A "Transaction" is a request submitted by a Sender directing us to transmit funds to a Recipient.
• The "Transaction Amount" is the amount of U.S. dollars the Sender provides for transmission.
• The "Payout Amount" is the amount received by the Recipient, which may vary due to exchange rates and applicable fees.

Important: The Service is intended for personal use only and should be used to 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, or individuals you do not trust.

We strongly encourage you to remain vigilant against fraud. Be especially cautious of unsolicited offers, high-pressure situations, or deals that seem too good to be true. If in doubt, pause and verify before sending money.

Getting Started

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

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

• A valid mobile phone number.
• A valid email address.
• A secure passcode, which you will use to log in to your account.

As part of our security measures, Varto requires the verification of your phone number and email address to confirm their validity and ownership. This process is essential for authenticating your identity and ensuring 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 regarding your transfers and account activity.

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

Identity verification

As a regulated financial institution, Varto is obligated to comply with applicable legal and regulatory requirements, including those related to anti-money laundering (AML) and fraud prevention. Verifying your identity is a critical part of these efforts and helps us protect your account, ensure transaction security, and comply with our regulatory obligations.

When Verification May Be Required

We may request identity verification from you in various circumstances, including but not limited to:

• When you initiate your first money transfer.
• When you request an increase to your sending limit.
• When a transaction is flagged for review by one of our payout partners.
• When we detect unusual or suspicious activity associated with your account

How Verification Is Conducted

To provide a secure and efficient verification process, we may engage trusted third-party technology providers, such as Plaid, to assist with identity confirmation. Depending on the specific situation, you may be asked to:

• Answer identity verification questions.
• Submit a photo of yourself and a valid government-issued identification document.
• Upload official documents or other proof of identity.

Your personal information is collected and handled in accordance with our Privacy policy and data security laws. We are committed to protecting your information and maintaining the confidentiality and integrity of your data at all times.

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, but is not limited to, verifying your identity through third-party databases 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 your 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 money transfers 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.

Processing Your Transaction

By submitting a Transfer, you are authorizing Varto to process the Transaction on your behalf. To do so, you must provide a valid Payment Instrument to fund the Transaction. If we are unable to process the Transaction using the selected Payment Instrument, we will notify you and may request that you provide an alternative Payment Instrument to complete the Transaction.

Varto reserves the right, at its sole discretion, to accept or reject any Transaction request submitted through your Varto Account, including in cases where you are in breach of this Agreement or applicable law. We are under no obligation to process any Transaction that does not comply with our requirements or that we deem potentially unlawful, fraudulent, or high-risk.

Bank Account Payment Authorization

If you choose to fund a Transaction or pay any applicable service fees using your bank account, you authorize Varto to initiate Automated Clearing House (ACH) debit or credit entries to and from your account, based on the instructions you provide. This includes credits to your account for any refunds, cancellations, or returned Transactions.

Apple Pay and Google Pay Authorization

If you choose to fund a Transaction or pay any applicable fees using Apple Pay or Google Pay (each, a “Digital Wallet”), you authorize Varto to initiate a charge to the Payment Instrument linked to your Digital Wallet in the amount specified by you, including any applicable service fees.

By using a Digital Wallet:

• You confirm that you are authorized to use the selected Payment Instrument associated with the Digital Wallet.
• You grant Varto and its payment processors permission to initiate payment requests and process transactions via the Digital Wallet in accordance with your instructions.
• You acknowledge and agree that the terms and conditions of your Digital Wallet provider (Apple or Google) also apply to your use of their service in connection with Varto.
• You may withdraw your authorization by removing the Digital Wallet as a payment method from your Varto Account. If a payment attempt fails, you authorize us to retry the charge using the same Digital Wallet, to the extent permitted by law and subject to the rules of the applicable provider.

Use of Apple Pay or Google Pay may be subject to transaction limits, verification requirements, or restrictions imposed by the wallet provider, card issuer, or Varto.

Accuracy of Transaction Information

You are solely responsible for ensuring that all information provided in connection with a Transaction, including the Recipient’s name, payment details, and contact information - is complete and accurate. Once a Transaction 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 Transaction details.

Varto’s Limitation of Liability

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

• The payment instructions provided by you are incomplete, incorrect, or contain errors;
• The Payment Instrument you have selected does not have sufficient funds or is otherwise invalid;
• We are unable to verify your identity or the legitimacy of the Transaction;
• Processing the Transaction would violate this Agreement or applicable laws and regulations.

Service Fees

In exchange for your use of the Service, you agree to pay a service fee (the "Service Fee") for each Transaction you initiate, in addition to the principal amount of the Transaction (the "Transaction Amount"). The specific Service Fee applicable to each Transaction will be clearly disclosed to you within the Varto mobile application or website prior to your authorization of the Transaction.

Service Fees are payable in U.S. dollars at the time the Transaction is submitted and may vary based on factors such as the Recipient's country and method of delivery. Service Fees are subject to change at our discretion.

Other Charges

Varto is not responsible for any additional fees that may be assessed by financial institutions associated with your chosen Payment Instrument. For example:

• Some credit card issuers may treat your Transaction as a “cash advance,” which could result in additional interest charges or fees.
• Your bank may charge non-sufficient funds fees (“NSF Fees”), overdraft fees, or chargeback fees if your Payment Instrument lacks adequate funds or is used improperly.

If your use of the Service results in Varto being charged a fee or penalty due to issues with your Payment Instrument (e.g., insufficient funds or unauthorized use), we will inform you of the charge, and you agree to reimburse us for the full amount.

Foreign Currency Exchange

If your Transaction 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 rate provided to you. The applicable exchange rate will be displayed to you prior to your confirmation of the Transaction. Exchange rates may vary depending on the destination country and are subject to change without notice.

Third-Party Fees

You are solely responsible for any additional fees or charges incurred from third parties in connection with your use of the Service. These may include fees from your:

• Bank or card issuer.
• Mobile service provider.
• Internet service provider.

Such charges may include data fees, text message fees, or international transaction charges. Please consult your agreements with these providers for more information about their applicable terms and fees.

Receiving a Remittance

Payout Providers

Varto partners with local banks, financial institutions, and third-party agents (“Payout Providers”) to disburse funds to Recipients in supported countries. While we strive to provide up-to-date and accurate information regarding the locations, availability, and operating hours of these Payout Providers on our website and mobile application, such information may change without prior notice. Varto does not assume liability for any outdated, inaccurate, or incomplete information posted on our platforms regarding Payout Providers.

Recipient Verification

To ensure secure delivery of funds and compliance with applicable regulations, Recipients may be required to verify their identity with the Payout Provider prior to receiving funds. Verification requirements may include, but are not limited to:

• Presentation of a valid, government-issued photo ID.
• Submission of a reference number or unique Transaction identifier.
• Completion of additional security or verification steps as required by local regulations or Payout Providers.

Failure to satisfy the verification requirements may delay or prevent disbursement of funds.

Expired Transactions

Transactions designated for cash pick-up that are not claimed within 60 calendar days of being made available will be considered expired and canceled. In such cases, Varto will make commercially reasonable efforts to refund the full Transaction Amount, applicable taxes, and any Service Fees to the original Payment Instrument.

If the refund cannot be completed within the legally required timeframe, unclaimed funds will be escheated to the appropriate U.S. state authority in accordance with applicable unclaimed property laws.

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 Transaction. 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, or regulatory obligations.
• Manage Transaction volume and system integrity.
• Enforce our internal policies or risk controls.

We may impose transaction limits on a per-transaction or aggregate basis, and such limits may apply to individual Varto Accounts or specific Payment Instruments. We may also modify or discontinue any aspect of the Service, in whole or in part, at any time and without prior notice.

Delays in Processing

We may delay the processing of a Transaction for reasons including, but not limited to:

• Verifying your identity or your Payment Instrument.
• Managing fraud risk or suspicious activity.
• Complying with legal or regulatory requirements

Where legally permissible, we will attempt to notify you of any such delay. You may be entitled to a refund or other remedies as required by law in the event of a delay.

Transfer Speed

Estimated delivery times provided via the Varto App or website are for informational purposes only and are not guaranteed. Delivery times may vary due to factors including the chosen payment and delivery method, transaction review, partner and Payout Provider availability, and system performance. We will provide a specific estimated delivery date and time prior to your authorization of a Transaction.

Commercial Transactions Disclaimer

Varto does not assume responsibility for the quality, safety, legality, or delivery of any goods or services paid for using the Service. Any such payments are made at your own risk.

Eligibility and Sanctions Compliance

We may restrict Transactions to or from individuals or entities that appear on sanctions or restricted parties lists issued by regulatory bodies, including but not limited to the U.S. Office of Foreign Assets Control (OFAC). We reserve the right to reject Transactions involving restricted countries, territories, or individuals to comply with applicable laws and international sanctions programs.

Finality of Transactions

Once submitted, a Transaction generally cannot be modified. It is your responsibility to ensure the accuracy of all Transaction details before submission. Varto is not liable for errors or losses resulting from incorrect information you provide, subject to your rights under applicable law to cancel or report errors.

Prohibited Activities

You agree not to use the Service to engage in, or facilitate, any of the following ("Prohibited Activities"):

• Violations of this Agreement or any applicable law or regulation.
• Fraud, money laundering, terrorist financing, or other criminal activities.
• Payments related to sexually explicit material, gambling, tobacco, firearms, prescription drugs, or other restricted goods or services.
• Providing false, misleading, or incomplete information.
• Attempting unauthorized cash advances from credit cards.
• Using anonymizing technologies or devices (e.g., proxies) to obscure identity.
• Engaging in chargeback abuse or multiple refund claims.
• Scraping, copying, or modifying any proprietary content or intellectual property of Varto.

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 Transactions.
• Suspend or close your Varto Account.
• Limit your access to specific features or Payment Instruments.
• Report your activity to regulators, law enforcement, financial partners, or other authorities.
• Refuse to process or post any content or payment instructions associated with the activity.

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

Cancellations

You may request to cancel your transaction at any time if it hasn’t been processed yet and while the “Cancel” button is still visible in the Varto App. Our money transfer process is fast, so sometimes it may be too late to cancel.

If the transaction has not been processed, we will cancel it and issue a refund of the full Transaction Amount and any Service Fees charged. Please note, if the transaction is already complete, the Transaction Amount is non-refundable.

Undeliverable Transactions

If we determine, or are informed by our Payout Providers, that your transaction cannot be completed due to an error or issue with the information you provided, we will notify you and request that you correct the issue and resubmit the transaction. If you do not take corrective action within 72 hours, we reserve the right to cancel the transaction.

In such cases, you will receive a refund of the full Transaction Amount and the Service Fees associated with the transaction.

You think you might be a victim of fraud

If you suspect fraud and the cancel button is still visible, cancel the transfer immediately through the Varto app.

We strongly advise that you only send money to people you know and trust.

While we can’t intervene in disputes between senders and recipients, we take fraud seriously and will investigate any claims in cooperation with our partners.

You entered the wrong recipient details

You can cancel the transfer if the cancel button is still available.

If the recipient’s details are incorrect (e.g., mismatched name and account number), many banks will automatically reject the transfer and return the funds to us, but this depends on the receiving bank’s policies.

We’ll contact you if this happens. If you haven’t heard from us within 7 days, please get in touch with our support team.

You sent money to the wrong person

You can cancel the transfer if it hasn’t been processed yet and the cancel button is still available.

If the money has already been delivered, you’ll need to reach out to the recipient directly to request a return. Unfortunately, we cannot reverse transfers that have already been completed.

Refunds

All refunds will be issued to the same Payment Instrument used to fund the original Transaction. Refunds are processed in U.S. dollars only and will not be adjusted for any fluctuations in exchange rates that may have occurred between the time the Transaction was submitted and the time of refund.

If the original Payment Instrument is no longer valid, and we are unable to identify a mutually acceptable alternative, the processing of your refund may be delayed until a commercially reasonable solution can be arranged.

Complaints and Dispute Resolution

We strive to provide a high-quality service, but if you are dissatisfied with your experience, you have the right to submit a complaint. Varto is committed to addressing complaints promptly, fairly, and transparently.

Before Submitting a Formal Complaint

Many issues can be resolved quickly by reaching out to our Customer Support team:

• Email Support: Contact our team for assistance. Most concerns can be addressed without needing to initiate a formal complaint process.
• Via the Varto App, using the Contact Support screen.

What to Expect After You Submit a Complaint

Once your complaint is received, we will:

1. Acknowledge receipt of your complaint via email.
2. Request additional information if necessary.
3. Conduct a thorough investigation, referring to the relevant terms in our agreement.
4. Provide a final written response explaining the outcome and any corrective action taken.

Response Timelines

• We aim to acknowledge receipt of your complaint within 24 hours.
• A final response will be provided within 15 calendar days.
• If more time is needed due to exceptional circumstances, we may extend our response time to 35 calendar days. You will be notified of any such delay by email.

If You Are Not Satisfied with Our Response

If you are not satisfied with the final outcome, you may escalate your complaint to the appropriate regulatory authority:

• In the United States:
  • Consumer Financial Protection Bureau (CFPB): Submit a complaint.
  • Washington state financial regulator: contact DFI at (360) 902-8700 or visit www.dfi.wa.gov.

If you need help submitting a complaint, our Support team is available to assist you.

Third-Party Materials

Certain features or functionalities of the Varto website or mobile application (the “Service”) may provide you with access to or facilitate the transmission of information, products, services, and other content made available by third parties (“Third-Party Materials”), including through hyperlinks or integrations.

By using these features, you acknowledge and agree that:

• You are instructing us to access, route, or transmit such Third-Party Materials to you.
• Varto does not control, endorse, or assume any responsibility for any Third-Party Materials, including their accuracy, completeness, reliability, legality, safety, or any intellectual property rights contained therein.
• Third-Party Materials may be outdated, misleading, deceptive, or otherwise objectionable. Accessing or relying on such materials is done at your own risk.

We make no representations or warranties of any kind regarding Third-Party Materials. The inclusion or availability of such materials does not imply any endorsement, affiliation, or partnership between Varto and any third-party provider.

We are under no obligation to monitor or review Third-Party Materials and reserve the right to remove, block, or disable access to any such materials at our sole discretion and without notice.

Your use of Third-Party Materials is subject to the terms, conditions, and policies imposed by the respective third-party providers (such as their terms of service or privacy policies), and you agree to comply with them.

Language

This Agreement is drafted in the English language. While translations of this Agreement may be provided in other languages for your convenience, you acknowledge and agree that the English version shall prevail and control in the event of any conflict, discrepancy, or inconsistency between the English version and any translated version. In any dispute relating to the interpretation or enforcement of this Agreement, the English version shall govern.

Dispute Resolution and Agreement to Arbitrate

Please read this section carefully, as it affects your legal rights

Informal Dispute Resolution

Before initiating arbitration or filing a claim in small-claims court, you and Varto agree to first attempt to resolve any Claim informally for a period of sixty (60) days.

• This 60-day period begins when either party sends a written notice of the Claim (“Claim Notice”) to the other party.
• The Claim Notice must include:
  • A brief description of the Claim; and
  • The relevant facts and legal basis supporting the Claim.

You agree to send your Claim Notice to:

Attn: CEO and President

ZUGER-SEE FINANCIAL LLC, 1633 SE 84th CT, Vancouver, WA 98664 USA.

If Varto has a Claim against you, it will send the Claim Notice to the email address listed in your Varto Account profile.

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

Prerequisite to Arbitration or Legal Action

If the parties are unable to resolve the Claim within the 60-day period:

• The party asserting the Claim may commence arbitration or file a small-claims court action, as outlined in the applicable sections of this Agreement.

Sending a valid Claim Notice and completing the informal resolution process is a required condition before initiating arbitration or small-claims action. Failure to comply with this requirement may result in dismissal of the claim.

Term and Termination

Duration of the Agreement

This Agreement becomes effective when you accept it (as described in the Preamble) and remains in force until it is terminated in accordance with the terms set forth below.

Termination by You

You may terminate this Agreement at any time and for any reason by closing your Varto Account in your Varto App.

Termination by Varto

We may terminate this Agreement:

• For convenience, by providing you with at least 15 days’ advance notice; or
• Immediately and without prior notice, if you violate this Agreement, any applicable policies, or engage in any Prohibited Activities as defined herein.

Effect of Account Closure or Termination

Upon termination of this Agreement or closure of your Varto Account:

• You must immediately cease using the Service;
• We may retain your information and transaction data as required by applicable law but otherwise reserve the right to delete your data;
• We are not liable to you or any third party for the termination of access to the Service or for any resulting deletion of data.

Outstanding Fees

Termination does not relieve you of your responsibility to pay any Service Fees or other charges incurred before the date of termination.

Survival

Any provision of this Agreement that, by its nature, should survive termination -including, but not limited to, provisions relating to dispute resolution, limitations of liability, indemnification, and recordkeeping obligations - will remain in full force and effect even after this Agreement is terminated.