Variabl
Variabl

Terms and Conditions

TERMS OF USE

Last Updated: July 27, 2026

This Terms of Use Agreement (the "Agreement" or "Terms") is a legally binding contract between you ("User", "you", or "your") and Variabl Financial Technologies Private Limited (referred to as "Variabl", "Company", "we", "us", or "our"), a company incorporated under the Companies Act, 2013, having its registered office at No. 731, 7th Cross Rd, 3 Block, Koramangala, Bengaluru, Karnataka 560034.

The Company has a wholly owned subsidiary, Variabl Investment Adviser Private Limited, which is in the process of applying for a SEBI Registration as a Registered Investment Adviser.

These Terms govern your use of and access to the website www.variabl.in, mobile applications, and any related services (collectively, the "Platform"). By accessing, browsing, or using the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy.

These Terms are an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and amended from time to time. This electronic record is generated by a computer system and does not require any physical or digital signatures.

If you do not agree to these Terms, please do not access or use the Platform. Your continued use of the Platform constitutes your acceptance of these Terms and any modifications thereto.

How these Terms are organised

These Terms are divided into two parts:

  • Part A: General Terms (Sections 1–18) apply to all users and to all Services on the Platform.
  • Part B: International Accounts (Sections 19–26) contain additional terms that apply only if you open or use an International Account for cross-border collection. Part B supplements Part A; where a provision of Part B conflicts with Part A, Part B prevails for International Accounts.

Section 27 (Grievance Redressal) and the Acknowledgment apply to all Services.

Part A: General Terms

1. About the Platform and Services

1.1 Overview

Variabl is a comprehensive financial operating system designed specifically for India's independent professionals, including freelancers, creators, consultants, gig workers, and solopreneurs. The Platform provides integrated solutions for financial management, compliance, and growth.

1.2 Services Offered

The Platform provides the following services (collectively, "Services"):

  • Income tracking and management across multiple clients and payment sources
  • GST compliance and return filing assistance
  • Tax planning and Income Tax Return (ITR) filing services
  • Invoice generation and management with GST compliance
  • Expense tracking and categorization
  • Financial reporting and analytics
  • Client and contract management tools
  • Payment collection and reconciliation
  • TDS tracking and compliance
  • Cross-border collection through International Accounts, which enable you to receive export payments for goods or services from parties outside India (subject to the additional terms in Part B)
  • Any other services as may be introduced on the Platform from time to time

1.3 Third-Party Services

Certain services on the Platform may be provided through third-party partners, including but not limited to payment gateways, banking partners, cross-border payment providers, GST Suvidha Providers (GSPs), and other service providers. Your use of such third-party services is subject to their respective terms and conditions.

2. Eligibility

You are eligible to use the Platform if:

  • You are at least 18 years of age. If acting as a guardian on behalf of a minor, you have the necessary authority to register and transact on their behalf
  • You are of legal age to form a binding contract and are not barred from receiving services under applicable Indian laws
  • You are competent to enter into legally binding contracts under the Indian Contract Act, 1872
  • You provide true, accurate, current, and complete information during registration
  • You agree to abide by these Terms and all applicable laws and regulations

The Company reserves the right to refuse access to the Platform to new users, or suspend/terminate existing users who have violated these Terms or applicable laws.

You confirm that any funds you invest or transact through the Platform are from your own legitimate sources and are remitted through approved banking channels.

Additional eligibility conditions apply to International Accounts and are set out in Section 20.1.

3. License and Permitted Use

Subject to your compliance with these Terms and payment of applicable fees, Variabl grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Platform and Services for your personal or professional financial management purposes.

This License permits you to:

  • Access the Platform via www.variabl.in or authorized mobile applications
  • Use the Services for preparing and filing your tax returns
  • Generate invoices, track income and expenses, and manage your financial records

The Services may not be used for providing financial, tax, or investment advisory services to third parties unless you are separately authorized and registered to do so under applicable laws.

4. Restrictions

You are prohibited from, directly or indirectly:

  • Redistributing, selling, renting, loaning, or transferring the Platform or Services to any third party
  • Using the Platform for any purpose other than its intended use or for the benefit of unauthorized third parties
  • Making the Platform available on an application service provider, outsourcing, or service bureau basis
  • Duplicating, copying, or reproducing the Platform through any means
  • Removing any proprietary notices, labels, or marks from the Platform
  • Attempting to derive source code, reverse engineer, decompile, or disassemble the Platform
  • Disabling or circumventing any access controls or security features
  • Using automated scripts, bots, or similar tools to access the Platform
  • Uploading viruses, malware, or any malicious code
  • Interfering with the Platform's security or operation
  • Using the Platform for any illegal activity or to violate any laws
  • Impersonating any person or entity or misrepresenting your affiliation
  • Collecting personal information of other users without authorization

Any breach of these restrictions shall be your responsibility, and Variabl reserves all rights not expressly granted herein.

5. User Account and Security

5.1 Account Registration

To access certain Services, you must create an account by providing accurate information including but not limited to:

  • Full legal name and contact details
  • Permanent Account Number (PAN)
  • GST Identification Number (GSTIN), if applicable
  • Bank account details
  • KYC documents as required by applicable regulations
  • Any other information necessary for service provision

5.2 Account Security

You are responsible for:

  • Maintaining the confidentiality of your login credentials
  • All activities that occur under your account
  • Notifying us immediately of any unauthorized access or security breach
  • Implementing reasonable security precautions for your devices and networks

Variabl shall not be liable for any loss arising from unauthorized use of your account due to your failure to maintain security.

6. GST Suvidha Provider Services

The Platform may provide access to GST System through authorized GST Suvidha Providers (GSPs). By using these services, you agree that:

  • You will be subject to the terms and conditions of GSTN
  • GSTN has sole discretion to accept or reject data transmitted through the Platform
  • You will comply with all GSTN guidelines and GST portal terms
  • Neither Variabl nor GSTN shall be liable for any failure or delay caused by network issues, system failures, or other technical errors
  • GSTN authorities have the right to audit your records
  • The Company will maintain transaction records as required by applicable laws

7. Tax Filing Services

7.1 User Responsibilities

You are responsible for:

  • Providing accurate and complete data for ITR filing
  • Reviewing and confirming the summary before filing
  • Verifying information in AIS, TIS, and Form 26AS
  • Retaining acknowledgment and confirmation details

7.2 Limitations

Variabl is not liable for:

  • Errors resulting from incorrect or incomplete data provided by you
  • Demands resulting from changes in CBDT rules and guidelines
  • Discrepancies between filed returns and government records if you have not verified this information
  • Penalties arising from data omitted or incorrectly provided by you

Our liability is limited to re-filing, revising, or submitting rectification requests within CBDT timelines, where applicable.

7.3 DIY Plans

Self-service (DIY) plans do not include manual review or professional verification. Expert-assisted plans must be purchased separately for such services.

8. Fees and Payments

The Company reserves the right to charge fees for Services. Fee details are available on the Platform and may be modified with reasonable notice.

  • All fees are exclusive of applicable taxes unless stated otherwise
  • Non-payment may result in suspension or termination of Services
  • Refunds are subject to our Refund Policy as published on the Platform

Fees, foreign-exchange charges, deductions and tax treatment specific to International Accounts are set out in Section 23.

8.1 Payment Processing

Payments are processed through authorized payment gateways. We shall not be liable for any loss arising from declined transactions, technical failures, or issues with third-party payment processors.

9. Refund Policy

9.1 Tax Filing Services

Once our team has reviewed your tax summary and provided assisted advice through any communication channel (call, email, chat, or otherwise), a refund will not be granted.

9.2 Subscription Services

Subscription fees are non-refundable unless otherwise specified in the specific subscription terms.

10. Intellectual Property Rights

Variabl and its licensors own all rights, title, and interest in the Platform, including all intellectual property rights. This includes but is not limited to:

  • Trademarks, service marks, logos, and trade names
  • Copyrighted content, software, and code
  • Patents and trade secrets
  • Design elements and user interfaces

Your use of the Platform does not grant you any ownership interest. You may not:

  • Copy, modify, or create derivative works
  • Decompile, reverse engineer, or attempt to derive source code
  • Use our trademarks without prior written consent
  • Remove or alter any proprietary notices

11. Privacy and Data Protection

Your use of the Platform is subject to our Privacy Policy, available on the Platform. By using the Platform, you consent to:

  • Collection and processing of your personal and financial information
  • Sharing of information with regulatory authorities, tax departments, and authorized third parties
  • Storage of your data in accordance with applicable laws
  • Use of your data to improve our Services

You grant us the right to use, process, and store your data for providing Services, complying with legal requirements, and improving our Platform. Additional data-handling terms for International Accounts are set out in Section 26.1 and in our Privacy Policy.

12. Communication Policy

By using the Platform, you consent to receive communications from us through:

  • Email notifications
  • SMS alerts
  • WhatsApp messages
  • Push notifications
  • Phone calls

These communications may include service updates, promotional offers, compliance reminders, and other relevant information.

You grant Variabl permission to contact you even if your number is registered on DND/NDNC. You will not hold Variabl liable under TRAI regulations for such communications.

13. Disclaimer of Warranties

THE PLATFORM AND SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. TO THE MAXIMUM EXTENT PERMITTED BY LAW, VARIABL DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING:

  • Warranties of merchantability and fitness for a particular purpose
  • Warranties of non-infringement
  • Warranties regarding accuracy, reliability, or completeness of information
  • Warranties regarding uninterrupted or error-free service

We do not warrant that:

  • The Platform will meet your specific requirements
  • The Platform will be available at all times without interruption
  • Any errors will be corrected
  • The Platform is free from viruses or harmful components

The Services are general tools to assist with your financial management and do not replace your obligation to exercise independent judgment or seek professional advice where appropriate.

14. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, VARIABL SHALL NOT BE LIABLE FOR:

  • Any indirect, incidental, special, consequential, or punitive damages
  • Loss of profits, revenue, data, or business opportunities
  • Damages arising from unauthorized access to your account
  • Damages arising from third-party services or content
  • Damages arising from system failures, downtime, or technical errors
  • Damages arising from government portal failures or regulatory delays

Our total liability for any claims arising from or related to these Terms or your use of the Platform shall not exceed the fees paid by you to us in the twelve (12) months preceding the claim.

These limitations apply regardless of the legal theory on which the claim is based, and are subject to the additional and modified provisions for International Accounts set out in Section 25.2.

15. Indemnification

You agree to indemnify, defend, and hold harmless Variabl and its officers, directors, employees, agents, affiliates, and licensors from and against any claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising from or related to:

  • Your breach of these Terms
  • Your violation of any applicable laws or regulations
  • Your misuse of the Platform or Services
  • Any inaccurate or false information provided by you
  • Your infringement of third-party rights
  • Any claims by third parties arising from your use of the Platform

Additional indemnities apply to International Accounts and are set out in Section 25.1.

16. Termination

Variabl may suspend or terminate your access to the Platform:

  • If you breach these Terms
  • If required by law or regulatory authorities
  • For extended periods of account inactivity
  • At our sole discretion with reasonable notice

Upon termination:

  • Your license to use the Platform is immediately revoked
  • You must cease all use of the Platform
  • Provisions that by their nature should survive will remain in effect
  • You remain liable for any obligations incurred prior to termination

Additional termination, suspension and dormancy provisions apply to International Accounts and are set out in Section 26.4.

17. Dispute Resolution

17.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of India.

17.2 Arbitration

Any disputes arising from these Terms shall be resolved through arbitration in accordance with the Arbitration and Conciliation Act, 1996. The arbitration shall:

  • Be conducted in Bengaluru, India
  • Be presided over by a sole arbitrator appointed by Variabl
  • Be conducted in English
  • Be kept confidential by both parties

The arbitrator's decision shall be final and binding.

17.3 Jurisdiction

Subject to the arbitration clause above, courts in Bengaluru, India shall have exclusive jurisdiction over any matters arising from these Terms.

17.4 Limitation on Claims

In case of disputes related to tax filing services, Variabl's liability for compensation shall be strictly limited to the amount paid for the specific service in question.

18. General Provisions

18.1 Entire Agreement

These Terms, together with the Privacy Policy and any service-specific terms, constitute the entire agreement between you and Variabl regarding the Platform and Services.

18.2 Amendments

We reserve the right to modify these Terms at any time. Changes will be effective upon posting on the Platform. Your continued use after such changes constitutes acceptance of the modified Terms.

18.3 Severability

If any provision of these Terms is found invalid or unenforceable, the remaining provisions shall continue in full force and effect.

18.4 Waiver

Our failure to enforce any provision shall not constitute a waiver of our right to enforce that provision in the future.

18.5 Assignment

You may not assign your rights under these Terms without our prior written consent. We may assign our rights to any affiliate or successor entity.

18.6 Force Majeure

Neither party shall be liable for delays or failures due to circumstances beyond reasonable control, including acts of God, natural disasters, war, terrorism, riots, government actions, pandemics, or failures of third-party systems.

18.7 Relationship

Nothing in these Terms creates an employment, agency, partnership, or joint venture relationship between you and Variabl.

Part B: International Accounts (Cross-Border Collection)

The following Sections 19 to 26 apply only if you open or use an International Account. They supplement the General Terms in Part A. Where these Sections conflict with Part A, these Sections prevail for International Accounts.

19. International Accounts: Overview and How These Terms Apply

19.1 Scope and precedence

An "International Account" is a multi-currency collection account that lets you receive export payments for goods or services from parties outside India, provided on the rail of our cross-border payments partner. These Sections supplement the General Terms; where they conflict with Part A, these Sections prevail for International Accounts. By enabling an International Account, you agree to these Sections.

19.2 Nature of the service and the Payments Partner

Variabl provides the technology interface for International Accounts. Variabl does not itself hold, transmit or convert your funds. Collection, currency conversion, holding and settlement are performed by the Payments Partner and its regulated banking partners under the Reserve Bank of India's Authorised Dealer framework and the laws of the relevant jurisdictions. The rights, liabilities and settlement of each Transaction sit directly between you and the Payments Partner under the Xflow Connected User Agreement; Variabl acts as your interface and authorised agent.

19.3 Required acceptances and authorisations

International Accounts run on the Payments Partner's rail. As a condition of enabling and using an International Account, you must separately and by explicit affirmative action accept:

  • (a) these International Accounts terms;
  • (b) the Xflow Connected User Agreement, together with Xflow's applicable website terms of use and privacy policy (collectively, the "Xflow Account Terms"), being your direct terms with the Payments Partner for the collection and settlement of your export payments; and
  • (c) the Connected User Authorisation, by which you authorise Variabl and the Payments Partner to operate your account on your behalf.

Variabl will keep records of these acceptances and will notify you of, and require your acceptance of, material updates to the Xflow Account Terms.

You authorise Variabl (and, through Variabl, the Payments Partner) to: create and operate your account and submit Transaction Requests on your behalf; view and download your Transaction documents (including invoices and inward-remittance certificates); share your account and Transaction information with the Payments Partner, its banking partners, service providers and Regulators as needed to provide the Services and meet legal obligations; set off, withhold or retain amounts, and convert and remit abandoned funds, in accordance with these Sections; and take other steps reasonably necessary to provide the Services. These authorisations continue while you use International Accounts, and Variabl's and the Payments Partner's rights to recover amounts from you and to assist in recovery survive termination.

19.4 Definitions for International Accounts

In these Sections:

  • "Payments Partner" means Variabl's cross-border payments provider (currently Xflow, comprising Xflow Payments India Private Limited, Xflow Payments Inc and Xflow Payments Canada Ltd) and its banking and settlement partners.
  • "Balance" means funds received for you and shown in your account for information only.
  • "Beneficiary" / "Payor" / "Buyer" have their ordinary meaning in a cross-border trade payment.
  • "Transaction" means a cross-border collection routed through the Services.
  • "Sanctions" means restrictions imposed by the UN, OFAC (US), HM Treasury (UK), the EU or any other competent authority.
  • "Purpose Code" means the RBI purpose code applicable to an inward remittance.
  • "FIRA / eFIRC" means the Foreign Inward Remittance Advice / Certificate.
  • "Prohibited Business" means any activity Variabl or the Payments Partner restricts, or that is barred under applicable law.
  • "Xflow Connected User Agreement" means the direct agreement between you and the Payments Partner governing the collection and settlement of your export payments.
  • "Xflow Account Terms" means, collectively, the Xflow Connected User Agreement and Xflow's applicable website terms of use and privacy policy, as updated from time to time.

20. Eligibility, Due Diligence and Screening

20.1 Additional eligibility for International Accounts

In addition to the eligibility conditions in Section 2, you may open and use an International Account only if you: (a) are 18 or older with legal capacity to contract; (b) are not insolvent; (c) complete Variabl's and the Payments Partner's identity verification and due diligence; and (d) use the account solely for your own legitimate business, for bona fide export of goods or services. International Accounts are not available for personal, consumer or third-party use.

20.2 Enhanced due diligence, KYC, AML and sanctions screening

You agree to provide, at onboarding and at any time on request, all information and documents Variabl or the Payments Partner require, including business registration, beneficial-ownership, director and authorised-representative details, bank account details and Transaction information. You authorise screening of you and associated persons against sanctions, politically-exposed-person (PEP) and adverse-media databases, and verification that you do not operate a Prohibited Business. You will keep this information current and promptly notify changes to your ownership, control or business activities. Account opening or any Transaction may be delayed, suspended or refused if you do not cooperate or if screening raises concerns.

21. Collections, Settlement and Balance

21.1 Export-collection structure (payment agent)

International Accounts operate on an export-collection basis. Under the Xflow Connected User Agreement, the Payments Partner acts as your limited collection agent to receive, hold and settle payments owed to you by Buyers outside India. Payment received by the collection agent from your Buyer discharges the Buyer's payment obligation to you; if settlement fails, your recourse is against the Payments Partner, not the Buyer. The Services do not transmit money on behalf of payors. You will not use the Services to send money to any payor except as genuine settlement for goods or services you have supplied, and will not use them for round-tripping or to disguise a remittance as an export receipt.

21.2 Transaction requests, settlement and foreign exchange

You submit collection and payout requests through the Services. Variabl or the Payments Partner may decline, delay or not complete any Transaction, without liability, for risk, fraud, sanctions or legal reasons, or where circumstances beyond their control prevent execution. Where a Transaction cannot be completed, you will be notified as soon as reasonably possible, normally by the next Business Day, with the reason unless disclosure is legally prohibited. Settlement timeframes are indicative and subject to the banking partners' screening. Currency conversion is applied at the rate shown at the time of conversion, inclusive of an all-in foreign-exchange markup of 0.50% (or as otherwise disclosed on the Platform). Variabl or the Payments Partner may cancel, reverse, withhold or adjust a Transaction to correct an error, where payment is not received in full, or on other legitimate grounds.

21.3 Balance and settlement of funds

Your Balance is displayed for information only and is not a deposit with, or obligation of, Variabl. Funds are held by the Payments Partner's banking partners, separately from Variabl's funds. You have no ownership, withdrawal or interest entitlement over funds until they are settled to your designated Indian bank account, and you may not assign or charge any rights to them. Funds inactive for 365 consecutive days without instructions may be treated as abandoned; the Payments Partner may then convert them (less amounts owed) to the base currency and remit them to your bank account on record, after which the related obligations are discharged. You authorise this conversion and remittance and will not hold Variabl or the Payments Partner liable for it.

22. Holds, Reserves and Recovery

22.1 Account holds

Variabl or the Payments Partner may place a full or partial hold on your account or any Transaction where: fraudulent, suspicious or unusual activity is detected; information you provided is incorrect, incomplete or misleading; you or your Transaction is flagged for sanctions, money-laundering, terrorism-financing or other illegality; a Regulator or banking partner so directs; or you fail to provide requested information. While a hold is in effect you may be unable to submit new Transactions or access held funds, and you may not open another account to circumvent it. Reasonable efforts will be made to tell you the reason and what is needed, except where law or the integrity of an investigation prevents disclosure.

22.2 Reserves

Where Variabl or the Payments Partner reasonably anticipates losses from chargebacks, disputes, reversals, fraud or penalties relating to your Transactions, a portion of your Transaction amounts may be withheld as a reserve. The amount, percentage and release conditions are set at reasonable discretion based on risk, and you will be notified unless notice would undermine the reserve's purpose.

22.3 Set-off, recovery of losses and shortfall

To recover any amount you owe Variabl under these Terms (including Buyer disputes, chargebacks, reversals, penalties, fees and reserve shortfalls), Variabl may, and may instruct the Payments Partner to: (a) withhold, set off or deduct the amount from your incoming or pending collections and settlements; (b) apply any reserve held in respect of you; and (c) require you to pay any remaining shortfall immediately on demand. Because your funds are collected and held by the Payments Partner and settled to you directly, you authorise Variabl to instruct the Payments Partner to withhold or set off against your collections to satisfy amounts you owe Variabl. Variabl's right to recover from you, and to assist the Payments Partner in recovering amounts due, survives suspension or termination of your account.

23. Fees, Deductions and Taxes (International Accounts)

23.1 Fees and deductions

Fees for International Accounts are as set out in the applicable Fee Schedule and may change with reasonable notice. Variabl or the Payments Partner may deduct fees, chargebacks, reversals, penalties and other amounts owed from your Balance or settlement proceeds. All amounts you pay are paid in full without set-off.

23.2 Tax gross-up

If applicable law requires you to withhold tax from any amount payable by you under these Sections, you will pay such additional amounts as are necessary to ensure that the recipient receives the amount it would have received had no withholding been required.

24. Your Obligations and Warranties (International Accounts)

24.1 Obligations: FEMA, AML and permitted use

You must use International Accounts in compliance with the Foreign Exchange Management Act, 1999, RBI regulations and all other applicable law. You will not use the Services for money laundering, terrorism financing, round-tripping, sanctions evasion, dealings with sanctioned persons, personal remittances, Prohibited Business, or any purpose other than bona fide business or export receipts. You are responsible for the accuracy of Purpose Codes and for providing the invoices and trade documents needed to issue FIRA/eFIRC and to satisfy Authorised Dealer bank requirements. You are fully responsible for the acts of any authorised users on your account, and will cooperate with, and provide records for, any investigation, enforcement or recovery relating to your account.

24.2 Representations and warranties

You represent, warrant and undertake that: (a) all information you provide is accurate, complete and either owned by you or provided with authority; (b) each Transaction reflects a genuine underlying trade in goods or services and complies with applicable law; (c) you do not operate any Prohibited Business; and (d) you remain bound by these Sections even if your authorised signatories change, for as long as you use the Services.

25. Indemnity, Liability and Disputes (International Accounts)

25.1 Your indemnity (back-to-back)

In addition to Section 15, you agree to indemnify, defend and hold harmless Variabl, its Payments Partner and their affiliates, officers, directors and agents from all losses, claims, damages, costs, penalties and expenses (including reasonable legal fees) arising from or in connection with:

  • (a) any Buyer dispute, chargeback, reversal or refund relating to your Transactions, including any debit, penalty or fine imposed on Variabl, the Payments Partner or their banking partners as a result;
  • (b) any use of the Services through your account or credentials that is inconsistent with these Terms, whether or not authorised by you;
  • (c) any instruction or Transaction Request that is unauthorised, inaccurate, fraudulent or exceeds your authority;
  • (d) your breach of these Terms or of FEMA, AML, sanctions, tax or other applicable law; and
  • (e) your failure to provide accurate information or to cooperate with due diligence.

This indemnity is uncapped.

25.2 Limitation of liability for International Accounts

In addition to Section 14, Variabl is not liable for delays, failures, foreign-exchange movements, settlement issues or losses caused by the Payments Partner, banking partners, Regulators or other third parties, or by circumstances beyond its reasonable control. Notwithstanding any liability cap in these Terms, that cap does not limit your liability to Variabl or the Payments Partner for chargebacks, disputes, reversals, penalties or your indemnity obligations under Section 25.1, or for your fraud, wilful misconduct or breach of applicable law, all of which are payable in full.

25.3 Commercial disputes

You will not involve Variabl or the Payments Partner in any dispute, claim or litigation between you and your Buyers or counterparties concerning the underlying goods or services, including their quality, quantity, delivery or specification. Variabl has no responsibility for the sale, delivery, non-delivery or delay of any goods or services.

26. Data, Availability, Termination and Governing Law (International Accounts)

26.1 Data and privacy (cross-border)

Processing of personal data for International Accounts is governed by our Privacy Policy, including its International Accounts provisions and the data-localisation requirements for Payments-Partner data. You are responsible for obtaining any consents needed for Variabl and the Payments Partner to collect and use your data and to disclose it to service providers, banking partners and Regulators, in India and other jurisdictions, for the Services and for AML, sanctions and regulatory purposes. Where you provide personal information relating to any other person (including any director, partner, authorised representative or beneficial owner of your business), you represent that you have obtained all consents necessary for that information to be collected, used, disclosed and transferred as described in these Terms and our Privacy Policy.

26.2 Geographic restrictions and third-party reliance

Variabl or the Payments Partner may restrict access to International Accounts from certain locations. Variabl does not guarantee uninterrupted or error-free availability and is not liable for errors, delays, disputes, refunds, chargebacks or reversals caused by banking institutions, payment service providers or other third parties, or by transmission over telecommunications networks or the internet.

26.3 Confidentiality

Each party will keep confidential the other's non-public business, technical and customer information, use it only as permitted under these Terms, and disclose it only to personnel or contractors with a need to know who are bound by equivalent obligations. This does not apply to information that is public through no fault of the recipient, already lawfully known, independently developed, or required to be disclosed by law (with reasonable notice where permitted).

26.4 Termination, suspension and dormancy

In addition to Section 16, Variabl or the Payments Partner may immediately suspend or terminate an International Account if you fail ongoing due diligence, no longer meet eligibility, operate a Prohibited Business, or the account is used for fraud, money laundering, terrorism financing, tax evasion or other crime, or is assessed as high-risk. On termination, you will be given a reasonable period (typically up to 30 days) to withdraw remaining funds to a bank account in your name; thereafter remaining funds (less amounts owed) may be converted to the base currency and remitted to your bank account on record. Both parties will cooperate with Regulator inquiries after termination, and clauses that by their nature should survive (including your indemnity, Variabl's recovery rights, and Variabl's obligation to assist the Payments Partner in recovery) will do so.

26.5 Governing law for international legs

These Sections are governed by the laws of India, with Bengaluru courts and the arbitration provisions of Section 17 applying, save that specific Transaction legs handled by the Payments Partner or its offshore entities may be subject to that partner's own terms and governing law, which you accept for those legs. No person who is not a party has any right to enforce these Sections. You may not assign your rights; Variabl may assign or novate to an affiliate or successor.

27. Grievance Redressal

For any grievances, complaints, or questions regarding these Terms or our Services (including International Accounts), please contact:

Grievance Officer - Name: Pranay Gupta - Address: No. 731, 7th Cross Rd, 3 Block, Koramangala, Bengaluru, Karnataka 560034 - Email: grievance@variabl.in - Phone: +91 8884044446

We will acknowledge your grievance within 48 hours and endeavor to resolve it within 30 days of receipt.

Acknowledgment

By clicking "I Agree" or by accessing and using the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use and our Privacy Policy.

You further acknowledge that:

  • You have the legal capacity to enter into this Agreement
  • You are not relying on any representations not contained in these Terms
  • You have had the opportunity to seek independent legal advice
  • These Terms constitute a valid and binding agreement

© 2026 Variabl Financial Technologies Private Limited.