Terms of Service

Terms of Service

These Terms are the agreement between you and Varuna's operator (named below, and called "we" or "us") for using Varuna at varunarecords.com. You accept them by ticking the box and pressing Accept. Please read them, in particular the sections on payment, "What Varuna is not", "No warranty", "Limits on our liability" and "Disagreements". Our privacy notice and the document reader page explain how we handle your information; they are part of how we keep these Terms.

Who we are

Varuna is operated by John Barlow, an individual doing business as Varuna, 2677 Stone Lane, Placerville, CA 95667. Telephone: (801) 824-4232. Email: john@stubbornfact.com for anything, and support@stubbornfact.com for refunds and billing questions.

Notices to us go to that address or email. Notices to you go to the email address on your account and appear in the app. You agree that we may give you notices, receipts and these Terms electronically.

California residents: you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.

Who may use Varuna

You must be 18 or older and in the United States to use Varuna. Give us true information about yourself, keep your sign-in private, and tell us if you think someone else has used it. You are responsible for what is done with your account.

If you accept these Terms for a practice, you confirm that you are allowed to bind it, and the practice is responsible for the seats it buys.

What Varuna is

Varuna keeps your continuing-education and credential records, and tells you what the rules we have recorded say about them, with a citation for every line. Course providers can run courses through Varuna and issue certificates that anyone can check at a public verification address.

What Varuna is not

Varuna is informational. Everything the product tells you about your compliance is a citation-backed opinion, based on the requirements we have recorded and on the records you gave us. It is not legal advice, and it is not advice from, or approved by, any licensing board, approval body or employer. Varuna is not connected with any of them.

Varuna does not guarantee that any board, employer or approval body will accept anything, that the rules we have recorded are complete or current, or that a reminder will reach you. Boards change their rules, and we may record a rule wrongly or late. Every line carries its citation so that you can check the source yourself.

Ultimately you are responsible for your own license, your own renewal, and anything you submit to a regulator. If Varuna and your board disagree, your board is right.

Where the product cannot tell, it says it cannot tell ("cannot verify yet"). That is not a "no", and it is not permission to assume the answer is yes.

What you pay for

• Membership is billed once a year, in full, in advance. The price shown is the price for the whole year.
• Modules (the CE Educator Module, the Supervisor Module and the Modality Instructor Module) are billed monthly. You can add a module only while you have a membership: your own, a practice seat, free access from us, or a free trial. A module cannot be bought on its own, and it stops when your membership does (see "Stopping, withdrawing and cancelling").
• Practice seats are billed once a year per seat, to the practice.

The current prices are shown on the start screen before you save a card, and on the Authorize screen before any charge. Prices are in US dollars and do not include sales tax. Where tax is owed, it is calculated by our payment processor, and the Authorize screen shows it as a separate line and the total before you press Authorize. The total is what is charged.

When you start your free trial you choose a plan (a membership, or seats for a group practice) and any modules. Before you save a card, the start screen shows each price, before sales tax, and what your first charge would be if you authorize it. For a group practice, the seats are charged to the practice's card and the Lead's own modules to the Lead's own card.

Your free trial

Your first 30 days are free. The 30 days start when you first enter the app after accepting these Terms and saving a card, not when you create your login, and the app shows how many days are left. The trial includes the modules you chose when you started it. A module you add on its own later during the trial is not free: it is charged from the day you add it, and the Authorize screen says so before you press it. A module you authorize together with your first payment starts with that payment (see "We never charge you without your say-so"). People given a seat from a practice's free trial get the membership; the Lead's modules are the Lead's own.

There is one free trial per person and per email address. A trial is not available if you have already had your own trial or your own paid membership; having had a practice seat or free access from us does not count against you. See the privacy notice for how we check this. But if you are on your own free trial when a practice gives you a seat, your trial ends then and counts as your one free trial.

A practice's Lead can instead start one free trial for the whole practice, for 2 to 500 seats (the Lead's own included). The practice's card is saved, and nothing is charged. Starting it uses the Lead's own free trial, so a Lead who could not start a free trial of their own cannot start one for a practice. A practice has one free trial only, and none if it has paid for seats before. The Lead takes a seat at once and can give the others to people who accept an invitation. Every seat from the trial ends when the trial ends, however late it was given, unless the Lead has authorized the practice's seats by then. The Lead can authorize them at any time during the trial: they are charged on the day the trial ends (see "We never charge you without your say-so"), and once that payment goes through, as many of the trial's seats as the Lead paid for carry on as paid seats, the Lead's own first and then in the order they were given; any others end. While that payment is being taken, and for 7 days if it fails, seat holders keep access as described in "If a payment fails".

To start the trial you save a payment card (for a practice's free trial, the practice's card) on our payment processor's page. SAVING A CARD DOES NOT CHARGE IT. Your bank may briefly show a $0 or $1 "pending" check while it confirms the card is valid. That is not a charge, and it disappears on its own, usually within a few days.

When the trial ends, nothing is charged unless you have authorized it (see below). If you have not, the trial simply ends: your access stops and your records stay.

We never charge you without your say-so

We charge your card only for what you have authorized on our Authorize screen. That screen shows what you are buying, the amount including tax, how often it repeats, the date it will be charged, the card, and how to stop it. Having a card on file is not permission to charge it. After you authorize, we email you a confirmation with the same details.

• First payment during your trial. You can authorize at any time during your trial without losing trial days. Your paid year starts when your trial ends, and the charge is taken on that day, not when you press Authorize. Until it is taken you can withdraw your authorization in one click from Membership & billing, and nothing is charged. The same applies when a Lead authorizes a practice's first seats during its free trial.
• First payment with no trial. If you are not on a trial, the Authorize screen says the charge is taken today, and your year starts when it is paid. If that payment does not go through, your membership does not start; you can finish paying with the same card from Membership & billing within 7 days, and after that the unpaid bill is cancelled and nothing is owed.
• Yearly renewal. A membership year does not renew by itself. Each new year needs your authorization, which you can give at any time before your year ends. The renewal is charged on the day your year ends, and until then you can withdraw it in one click. If you do not authorize a renewal, your membership ends at the end of the year you paid for and nothing is charged.
• Modules. A module is a monthly subscription that continues until you stop it. When you add one, the Authorize screen shows its monthly price, that it is charged every month until you stop it, the card it is charged to, and how to stop it. That one authorization covers each monthly charge of the same amount, on the same card, until you stop the module. You can stop it at any time, in one click, from Membership & billing (see "Stopping, withdrawing and cancelling"). You can also authorize modules on the same screen, and with the same press, as your first membership payment (or, for a Lead, the practice's first seats). The screen then lists each module with its monthly price and a Remove link, and you tick a box agreeing to their monthly charges; the button states what is charged on the first day and each month after. Each of those modules starts, and is first charged, on the day that membership or seat payment goes through, and then on the same day each month. It never starts if that payment does not go through. If you withdraw that membership or seat authorization before it is charged, the modules authorized with it are withdrawn too, and nothing is charged for them. A Lead's own modules are charged to the Lead's own card, not the practice's.
• Practice seats. A practice's Lead authorizes and pays for its seats, including each yearly renewal. You are never charged for a seat someone else pays for, and your account and records stay yours if the seat ends. A Lead's own modules are the Lead's and are charged to the Lead's own card.

If a charge would be higher than the amount you authorized (for example, because tax changed), we hold it and ask you to confirm the new amount first. We never take a charge that no authorization covers. We will not change the price of a period you have already authorized. If we ever change a module's price for people already paying it, we will tell you at least 7 and no more than 30 days before, and the new price applies only after you agree to it on the Authorize screen; if you do not agree, nothing at the new price is charged and you can stop the module at the end of the month you have paid for.

Reminders before we charge

We send these by email and show them in the app. They are about your money, so you cannot switch them off.

• While you are on a trial: 7 days and 2 days before it ends, and on its last day. If you have authorized your first payment (or, for a Lead, the practice's first seats), they tell you the amount and date, including any modules charged that day, and how to withdraw. If you have not, they tell you nothing will be charged.
• Before your membership year or a practice's seats end: about 30 days, 7 days and 2 days before, with the amount, the date, and how to authorize or withdraw a renewal.
• For a module: once a year, a reminder of the monthly amount and how to stop it.

Stopping, withdrawing and cancelling

You can do each of these at any time, in one click from Membership & billing, with no phone call and no need to contact us:

• Withdraw an authorization for a future charge that has not been taken yet (a first payment after your trial, a practice's first seats, a yearly renewal, a practice's seat renewal, or a module authorized with a first payment or a practice's first seats that has not started yet). Nothing is charged.
• Stop a module. No further monthly charge is taken, and you keep the module until the end of the month you have paid for. A module whose current month is unpaid or overdue stops at once.
• When your membership ends and you do not have one another way (your own membership, a practice seat, free access from us, or a free trial), your modules stop. That is so however it ends: a year that was not renewed, a trial that ended without a payment, a seat that ended, or a refund or a dispute. No further monthly charge is taken. A module cannot be used without a membership, so it stops working when your membership ends, and the rest of a module month you have already paid for is not refunded (except under "Refunds").

A yearly membership needs no cancelling: if you do not authorize a renewal, it ends at the end of the year you paid for. Any modules stop with it (see above). Paid time is not refunded in part when you stop (but see "Refunds").

Refunds

You can have a full refund of any charge, whether it is a first payment, a renewal, a module month or a practice's seats, if you ask within 14 days of the charge by emailing support@stubbornfact.com from your account's email address. When we refund a charge, the period it paid for ends at once; your records stay. Practice seats are refunded to the practice that paid, and a Lead's modules to the Lead's card. Except where the law requires otherwise, or where these Terms say so ("Changes to Varuna", "If we suspend or close an account"), we do not refund part of a period you have already paid for.

If a payment fails

If an authorized charge fails, we tell you. You keep access for 7 days from the end of the period you last paid for (or from the end of your trial, if it was your first payment after a trial). During those 7 days our payment processor may try the same charge again, for the same amount, on the same card, up to a few times. You can also retry it yourself with that card from Membership & billing. To pay that charge with a different card, write to us and we will help; we never charge a different card without your confirmation. If the charge is not paid within the 7 days, your access ends, nothing more is charged, and your records stay.

If you dispute a charge with your bank

When you open a dispute (a "chargeback"), the access that charge paid for ends while it is open. If the dispute is decided in your favor, that period stays ended, as if it had been refunded. If it is decided in ours and the period you paid for has not run out, your access returns for the rest of it (a practice's Lead reassigns any seats). Modules stopped while the dispute was open do not restart by themselves; you can add them again. Disputing a charge never affects your records or the always-free actions below. Please write to us first: a refund within 14 days is quicker than a dispute.

When your access ends

When your membership, trial or seat ends, signing in takes you to one page. It offers to pay or update your payment and to export all of your saved documents. Nothing is deleted, and if you come back, your account is exactly as you left it. You can export your documents by yourself for 12 months after your access ends; after that we still keep them, and customer support reopens your export for you when you ask.

Some things never depend on payment, whether or not you have access:

• exporting everything you have stored with us, at any size, by yourself for 12 months after your access ends or you close your account, and after that when customer support reopens your export for you;
• for course providers, exporting your training records, course records and accreditation packets;
• finishing a course you enrolled in, its evaluation, and downloading any certificate issued to you;
• anyone checking a certificate at its verification address;
• making your public profile private, withdrawing a connection, blocking someone, leaving a practice, or accepting or declining a practice invitation;
• reading your notices and changing which emails we send;
• paying what is owed, authorizing a return, or seeing your receipts;
• closing your account, or deleting everything.

If you run courses and your CE Educator Module ends, courses you published stay open to people who already enrolled, so they can finish the course and the evaluation, and certificates you already issued stay valid, downloadable and verifiable. You cannot create or change courses, or issue, reissue or revoke certificates, until your access returns. That includes certificates for attendees who finish after your access ends, so tell your attendees if you are stopping, and remember that your duties to your attendees and to your approval bodies continue whatever your Varuna access.

If you ticked the box for it when you started, we may email you the renewal dates of licenses you recorded after your access ends, with a link to rejoin. These emails never include your compliance status, each has a one-click stop link, and they stop when you close your account.

Your records are yours

Your records and documents remain yours. You can export everything you have given us by yourself, at any time while you have access and for 12 months after your access ends or you close your account. After that we keep it, and customer support reopens your export for you when you ask, free of charge.

You give us permission to store, copy, process and display your records and documents only as needed to provide Varuna to you and to the people you choose to share with, including sending a document to the document reader when you put it in the drop area. While your account is closed, we use them only to keep them, to let you export them or rejoin, to reopen your export through customer support when you ask, and to keep showing what you already shared with others until you stop sharing it. This permission ends when you delete them or delete everything, except for what the privacy notice says is kept and why.

You confirm that you have the right to upload what you upload and to send what you send through Varuna.

Certificates

A certificate issued through Varuna cannot be edited once issued. A mistake is corrected by revoking the certificate and issuing a corrected one; both stay on record, and the verification page shows which is current. This is what lets a board trust a Varuna verification page.

If you issue certificates, you are the provider of the course and you are responsible for it: for the accuracy of every certificate you issue, for holding any approval you name on it, and for keeping the records your approval bodies require. Varuna is the tool you use; it does not approve, accredit or vouch for any course or provider. Varuna keeps your course records for at least as long as your approval bodies' recorded rules require, and disposing of them is your decision; disposal never removes an attendee's certificate or its verification page.

Certificates issued to you, and their verification pages, stay after your account or the provider's account closes, because a certificate a board can check is not ours to withdraw and is not only about you.

The document reader

The document reader uses an AI model, provided by Anthropic, to suggest what a document says. Its suggestions can be wrong. Nothing it reads is saved to your records until you check it and press save, and you are responsible for what you save. The document reader page explains what is sent and how Social Security numbers are blacked out first.

Social Security numbers

We do not ask you for a Social Security number. If a document you upload shows one, we keep the document intact and store it privately, where only you can open it. Before a document is sent to an outside company to be read (the document reader), we check it for a number shaped like one and black out any we find, and if we cannot check a document, we do not send it. The document reader page explains how the check works. Varuna never puts the number in our logs, error reports, emails or search, and never shows your documents to anyone else. If you choose to export a document or send it to someone yourself, it goes as it is.

Client information and HIPAA

Varuna is for your own professional records. It is not designed or offered to hold protected health information, and we do not sign business associate agreements. Do not upload, type or share anything that identifies your clients or patients or describes their care, such as session notes, or supervision logs or case write-ups that name clients. If a document you need to keep shows client details, black them out before you upload it. If client information reaches Varuna anyway, tell us and we will help you remove it.

What you may not do

• Do not upload, issue or sign anything you know to be false, altered or not yours. That includes certificates, hours, licenses, and statements about someone else's training or supervision.
• Do not upload clients' or patients' information (see above).
• Do not upload anything you do not have the right to upload, or anything unlawful, or that infringes someone else's rights.
• Only enter another person's email address if you have a real reason to contact them through Varuna, such as a signing or verification request.
• Do not try to get into another person's records or account, test or get around our security, or disrupt the service.
• Do not copy the rulebook or the site by automated means (scraping, crawling or bulk downloading), or use them to build a competing product.
• Do not resell, rent or share your access.
• Do not use Varuna to send spam or to harass anyone.

Copyright complaints

If you believe something on Varuna infringes your copyright, send us a notice that meets the Digital Millennium Copyright Act (17 U.S.C. 512(c)(3)): identify the work, identify the material and where it is, give your contact details, include a statement of good-faith belief and a statement, under penalty of perjury, that your notice is accurate and that you are the owner or authorized to act for the owner, and sign it. Send it to John Barlow, 2677 Stone Lane, Placerville, CA 95667, or john@stubbornfact.com. We remove material that is the subject of a valid notice, tell the person who posted it, and accept counter-notices as the law provides. We close the accounts of repeat infringers.

The software, the rulebook, the site and its content, and the Varuna name belong to us (or to those who license them to us). These Terms give you the right to use Varuna for its purpose, and no other right in them.

If we suspend or close an account

We may suspend or close an account that breaks these Terms, puts others at risk, or where the law requires it. Unless the law or someone's safety prevents it, we tell you why first and give you 30 days to export your records. After that, the account is closed (you can still sign in and export your records as described in "Closing your account", but not rejoin), or deleted as described there for Delete everything now, unless the law requires something else. If we close or delete an account on our own initiative for any reason other than a breach of these Terms, we refund the unused part of any period you paid for. Certificates issued through Varuna stay verifiable, unless a certificate was issued falsely, in which case it may be revoked and its verification page will say so.

Closing your account

You can close your account at any time from your account settings. Closing keeps your account and your records. For 12 months after you close, you can sign in and export all of your documents by yourself; after that we still keep them, and customer support reopens your export for you when you ask. You can sign in and rejoin at any time. While your account is closed, nothing more is charged, we send you no reminders (only notices about a payment, a refund or your card), and you do not appear when people search for others by name. Closing also takes you out of any practice you are a member of (your seat goes back to the practice) and turns off your public profile; rejoining does not bring either back. Anything you already shared with a supervisor or a connection stays shared, and they can still send you messages (you can read them if you rejoin), until you stop sharing or withdraw the connection. While your account is closed you cannot authorize a payment, join a practice, make anything public or start sharing with someone new; rejoin first (one click). Closing does not refund a period you already paid for, except under "Refunds"; if you rejoin before that period ends, you have the rest of it.

You can instead delete everything now, from the same place. That deletes your account and records at once and permanently, except what the privacy notice lists as kept and why. Export first: once deleted, we cannot give your records back.

You cannot close your account or delete everything while a module has not been stopped or an authorization is waiting to be charged, including your practice's if you are its Lead. Stop or withdraw it first from Membership & billing (one click each); closing then takes no further charge. You also cannot close your account or delete everything while you lead a practice that still has other members: remove them from the practice first. And you cannot delete everything while you are the only owner of a course provider on Varuna, because its certificates must stay reissuable: add another owner first.

Changes to Varuna

We may improve, change or remove features. If we remove something central to what you paid for during a period you have already paid for, you may end that period and receive a refund of the unused part.

If Varuna shuts down or is sold

If Varuna ever winds down, we will tell you, and your exports will stay available to everyone, however long ago their access ended, for at least twelve months from that notice. If Varuna is sold or merged, we will tell you first, and these Terms and your records move to the new owner, who must keep the promises in these Terms and the privacy notice.

No warranty

TO THE FULLEST EXTENT THE LAW ALLOWS, VARUNA IS PROVIDED "AS IS" AND "AS AVAILABLE". WE DISCLAIM ALL WARRANTIES NOT STATED IN THESE TERMS, WHETHER EXPRESS OR IMPLIED, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, AND NON-INFRINGEMENT. WE DO NOT PROMISE THAT VARUNA WILL BE UNINTERRUPTED OR ERROR-FREE, THAT THE RULES WE HAVE RECORDED ARE COMPLETE OR CURRENT, THAT ANY REMINDER WILL ARRIVE, OR THAT ANY BOARD, EMPLOYER OR APPROVAL BODY WILL ACCEPT ANYTHING. Some states do not allow these exclusions, so some of them may not apply to you.

This does not take away the specific promises these Terms make to you, such as never charging you without your authorization, letting you export everything, and refunds.

Limits on our liability

TO THE FULLEST EXTENT THE LAW ALLOWS:

• WE ARE NOT LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR FOR LOST PROFITS, LOST INCOME OR LOST DATA, INCLUDING ANY LOSS THAT COMES FROM A LICENSE OR CERTIFICATION LAPSING, BEING DENIED OR BEING DISCIPLINED, OR FROM AN AUDIT, EVEN IF WE WERE TOLD IT COULD HAPPEN.
• OUR TOTAL LIABILITY FOR ALL CLAIMS ABOUT VARUNA OR THESE TERMS IS LIMITED TO THE GREATER OF THE AMOUNT YOU PAID US IN THE 12 MONTHS BEFORE THE EVENT THAT CAUSED THE CLAIM, OR US $100.

These limits do not apply to liability that the law does not allow to be limited, such as liability for fraud, for gross negligence or wilful misconduct, or for death or personal injury caused by negligence. Some states do not allow these limits, so some of them may not apply to you.

Your responsibility to us

If someone makes a claim against us because of something you uploaded, issued or signed through Varuna, or because you broke "What you may not do", you will cover our reasonable costs of that claim, to the extent the law allows. We will tell you about the claim promptly and let you take part in defending it.

Disagreements

If you have a problem with Varuna, please email us first. Most things can be fixed quickly. Both of us agree to try for 30 days to settle a disagreement informally before going to court.

These Terms are governed by the laws of the State of California, without regard to its conflict-of-laws rules. Nothing here takes away a protection the law of the state where you live gives you and does not allow to be waived.

Either of us may bring a claim in small-claims court in the county where you live or in El Dorado County, California, if it qualifies. Otherwise, claims go to the state or federal courts for El Dorado County, California, and both of us agree to those courts' jurisdiction. There is no arbitration clause in these Terms.

Changes to these Terms

When these Terms change, we publish a new version, keep the old one, and tell you in the app, and by email before any change to how you are charged takes effect. We record which exact text you accepted and when, not just its name. If a change matters to you, the app asks you to accept the new version the next time you sign in.

If you do not accept a new version, you can keep using the always-free actions, including exporting everything; any period you already paid for continues under the version you accepted until it ends, and we will not take a further charge under the new version until you accept it. A change to these Terms never authorizes a charge: only you do that.

The rest of the agreement

• These Terms, the privacy notice, the document reader page, and what the Authorize screen showed you for each charge are the whole agreement between you and us about Varuna. If they conflict about a charge, what the Authorize screen showed you wins.
• If a court finds part of these Terms unenforceable, that part is changed only as much as needed to make it enforceable, and the rest stays in force.
• If we do not enforce a part of these Terms at once, we can still enforce it later.
• You may not transfer these Terms to someone else without our agreement. We may transfer them only as part of a sale or merger of Varuna (see "If Varuna shuts down or is sold").
• We are not responsible for a delay or failure caused by something outside our reasonable control, such as an outage at a provider we rely on; we will tell you and do what we reasonably can.
• The sections on what Varuna is not, certificates, warranties, liability, your responsibility to us, disagreements, and what is kept after you close your account or delete everything continue after your account ends.