Varshney Projects LLP
LLPIN ACG-9878 · GSTIN 27AAYFV4317P1Z4
bullpen.in · compliance@bullpen.in

Data Licence Agreement

Version 1.0 · Effective 15 August 2026

This is the agreement that governs your use of the data. It is accepted by ticking the acceptance box at checkout, by signing an Order Form referring to it, or by using the Service — whichever happens first.


1. Parties

This Agreement is between:

Varshney Projects LLP, LLPIN ACG-9878, registered office A 101, Gundecha Garden, Lalbaug, Mumbai 400012, Maharashtra, India, GSTIN 27AAYFV4317P1Z4 ("Licensor", "we", "us"); and

the organisation identified on the Order Form or in the account registration ("Licensee", "you").

2. Definitions

Term Meaning
Data The information made available through the Service, comprising Source Data and Computed Metrics
Source Data Entity-level factual information extracted by us from public regulatory filings, exchange disclosures and similar public documents
Computed Metrics Values we calculate from Source Data — ratios, aggregates, growth rates and similar — which are labelled as computed
Service Our data service, made available through an MCP server, an API, or both. This Agreement governs every delivery channel equally
AI Tool Any large language model, AI assistant, agent or similar system operated by you or a third party which you connect to the Service or into which you input Data
Order Form The checkout confirmation, invoice or written order recording your plan, fees and term
Plan Limits The usage limits for your plan, as set out in clause 5A and on your Order Form
Authorised Users Your employees and contractors, acting for you, to whom you give access
Business Day A day other than a Saturday, Sunday or a public holiday in Mumbai
Plan The plan stated on your Order Form — Analyst or Partner
Permitted Extract A limited quantity of Data reproduced in a client-facing document in accordance with clause 4.5
Ephemeral Grounding Supplying Data into an AI Tool's context at the moment a question is asked, where the Data is not retained after the response is generated
Persistent Embedding Storing Data, or any vector, index or numerical representation of it, in any system that can be queried after the AI Tool session has ended

3. Acceptance and eligibility

3.1 You accept this Agreement by ticking the acceptance box, signing an Order Form referring to it, or using the Service.

3.2 You confirm that you are a business or professional entity, that you are entering this Agreement for business purposes, and that the person accepting has authority to bind you.

3.3 Where the Service is offered. The Service is available to business and professional users in India and, subject to clause 3.4, elsewhere.

3.4 Excluded territories. The Service is not offered to, and must not be accessed by or made available to, any person or entity:

a. established or located in the European Union or the United Kingdom; or b. established or located in, or owned or controlled by any person in, a country or territory subject to sanctions or trade restrictions applicable to us, or any person named on an applicable sanctions list.

We do not market the Service in the European Union or the United Kingdom, and do not direct it at persons there. You confirm that you fall outside clause 3.4, and will tell us immediately if that ceases to be true. We may suspend or terminate access under clause 13 if it does.

3.5 Where the Data goes. Clause 3.3 governs who may purchase and use the Service. It does not mean the Data stays within any particular country. If you connect an AI Tool, your queries and the Data returned will be transmitted to that tool's provider, who may process them outside India and outside your own jurisdiction. Your choice of AI Tool determines this, not us.

4. Licence

4.1 Grant. Subject to your compliance with this Agreement and payment of fees, we grant you a limited, non-exclusive, non-transferable, non-sublicensable licence, revocable only in accordance with clauses 13 and 14, for the term of your subscription, to access the Data and use it internally within your own organisation for your own business purposes, together with the right to issue Permitted Extracts under clause 4.5.

4.2 This is a licence, not a sale. No ownership passes to you. All rights not expressly granted are reserved.

4.3 Authorised Users. You may permit Authorised Users to access the Data under your account. You are responsible for their acts and omissions as if they were your own.

4.4 Internal outputs. You may incorporate Data into internal reports, models and analysis used within your organisation, subject to clause 5 and clause 6.

4.5 Permitted Extracts. You may include Permitted Extracts in documents you supply to your own clients, provided that all of the following are satisfied:

a. each extract is attributed to us, and any source citation or provenance reference supplied with the Data is reproduced alongside it; b. the extract is incidental to your own analysis, commentary or advice, and is not itself the principal value of the document; c. the extract is not, and could not reasonably be used as, a substitute for a subscription to the Service — in particular it must not be systematic, recurring, bulk, machine-readable, or presented as a dataset, feed, table of records or database; d. the document is supplied to identified clients under your own engagement terms, and is not published to the public at large or made available for download by unidentified persons; and e. you do not charge separately for the Data itself.

Anything beyond a Permitted Extract — including any recurring, bulk or machine-readable supply to a third party — requires a Partner plan under clause 4.7 or a separate written redistribution licence from us.

4.6 Your own work. You own the analysis, models, screens, commentary and advice you create using the Data. We claim no right, title, interest or licence in them.

This does not extend to anything that is, in substance, a copy of the Data — a stored table, dataset, index or compilation of Data records is not your own work, however it is labelled. Nor does owning your own work give you any continuing right to the Data itself: on termination the Data is deleted and certified under clause 14.4, while your own work remains yours.

4.7 Partner redistribution. This clause applies only where your Order Form states that your Plan is Partner.

You may include Data in deliverables you supply to your own clients on a recurring basis, going beyond the limits of clause 4.5, provided that all of the following are satisfied:

a. the deliverable is human-readable — a report, note, presentation, dashboard or similar. You must not supply Data to any client as a file, extract, export, feed, dataset, database or interface, or in any other machine-readable form, whether or not for a fee; b. each client is identified by name in your records and receives the deliverable under your own written engagement terms; c. the Data is attributed to us, and any source citation or provenance reference supplied with it is reproduced alongside it; d. your engagement terms prohibit your client from redistributing the Data further, and you enforce that restriction; e. the Data is not the principal value of the deliverable — your own analysis, commentary or advice is; and f. you do not present the Data as your own proprietary dataset, and do not offer any client anything that functions as a substitute for a subscription to the Service.

You remain responsible for your clients' compliance with this clause as if their acts were your own.

On reasonable written request, no more than once in any 12 months, you will tell us the number of clients receiving Data and the form the deliverables take. We will not ask for their identities, and clause 15.2 is not needed for a request under this paragraph.

Anything outside this clause, including any machine-readable supply to a client, requires a separate written redistribution licence from us.

5. Restrictions

You must not, and must not permit anyone else to:

a. redistribute, resell, publish, syndicate, licence or otherwise make the Data available to any third party, whether or not for a fee, and whether in whole or in part, except as expressly permitted by clauses 4.5 and 4.7; b. make the Data available through any product, service, feed, dataset, application or interface accessible to third parties, other than as permitted by clauses 4.5 and 4.7; c. use the Data to build, populate, benchmark or improve any database, dataset or data product that competes with the Service; d. use the Data to train, fine-tune or otherwise improve any AI model, whether your own or a third party's, or to create any Persistent Embedding of the Data. Ephemeral Grounding is expressly permitted, and is the intended manner of use of the Service; e. exceed the company limit for your plan set out in clause 5A.1, or take steps to circumvent, mask or evade it; f. share, resell or transfer access credentials, tokens or account access; g. scrape, crawl, bulk-download, systematically extract, or create a substantial copy or replica of the Data outside the normal operation of the Service; h. reverse engineer, decompile or attempt to derive the structure, methodology or source of the Service; i. remove, obscure, alter or fail to carry through any source citation, provenance reference or attribution attached to the Data; j. use the Data in any way that breaches applicable law, including securities law; k. represent the Data as your own proprietary dataset.

Exceeding the company limit in clause 5A.1 is a breach of this Agreement, not merely a trigger for throttling. The request-rate limit in clause 5A.2 is operational only and is not a breach.

5A. Plan Limits

5A.1 Company limit. Your plan permits access to Data for up to the following number of distinct companies in each billing month:

Plan Distinct companies per billing month
Analyst 150
Partner 350

A company counts once in a billing month however many times you access it. The allowance does not carry forward — unused capacity in one month is not added to the next, on any plan or billing period.

5A.2 Request rate. We apply a technical rate limit to protect the stability of the Service for all users:

Plan Sustained Short burst
Analyst 60 requests per minute 120
Partner 180 requests per minute 360

Requests above this rate receive an error response and may be retried. Exceeding the request rate is not a breach of this Agreement. It is an operational limit only, and we will not treat it as grounds for termination.

5A.3 Exceeding the company limit in clause 5A.1 is a breach of clause 5(e), and clause 13 applies.

5A.4 Changes. We may vary Plan Limits on 30 days' written notice, effective at your next renewal. If a reduction materially affects you, you may cancel before renewal without penalty.

6. AI tools and MCP access

You will typically access the Service through an MCP server connected to an AI Tool. The following apply.

6.1 The warranty boundary. Our obligations and warranties apply only to the Data as delivered in the response from our MCP server or API. They do not extend to anything an AI Tool subsequently generates, summarises, infers, combines, restates or concludes from that Data.

6.2 AI outputs are yours. Any output produced by an AI Tool using the Data is your output and your responsibility. We are not responsible for its accuracy, completeness or fitness for any purpose, including where the AI Tool misstates, omits, invents or misattributes Data.

6.3 Citations must survive. Where Data is supplied with a source citation or provenance reference, you must configure your systems and instruct your Authorised Users so that the citation is carried through to any output where the Data is relied on or reproduced. You must not strip provenance.

6.4 Your AI Tool configuration. You must use only an AI Tool, plan and configuration under which inputs are not used to train or improve any model of the AI Tool's provider or any third party.

On request, and on each renewal, you will tell us which AI Tool and plan tier you use to access the Service. We publish a list of configurations we consider acceptable at bullpen.in. That list changes as AI providers change their terms and does not form part of this Agreement; it is guidance, and the obligation in this clause remains yours.

We have no ability to verify or control your AI Tool, and give no warranty in respect of it.

6.5 Leakage through AI tools. You acknowledge that inputting Data into a third-party AI Tool transmits it to a party we have no contract with, and that we are not responsible for that party's retention, use or disclosure of it. Any such transmission is a disclosure by you, at your risk.

7. Nature and source of the Data

7.1 Source. Source Data is extracted by us from documents that are publicly filed or publicly disclosed.

7.2 No personal data. The Data is entity-level. It does not include personal data of natural persons, and is not supplied for any purpose involving personal data.

7.3 Computed Metrics are arithmetic, not opinion. Computed Metrics are derivations from reported figures. They are labelled as computed. They are not ratings, scores of merit, rankings of investment attractiveness, opinions, or recommendations.

7.4 What this Service is, and is not. This Service supplies factual data extracted from public filings, together with labelled computed metrics. It does not supply investment advice, recommendations, ratings, target prices, opinions on merit or suitability, or research analysis within the meaning of the SEBI (Research Analysts) Regulations, 2014.

We are not registered with the Securities and Exchange Board of India in any capacity. The Service is not offered under, and does not rely on, any registration held by any other person or entity.

You are solely responsible for any decision taken using the Data, and for your own regulatory compliance.

7.5 Verify at source. Every Data point is supplied with a reference to the document it came from, so that you can verify it. You are responsible for verifying Data against the underlying source before relying on it for any material purpose.

7.6 Source terms are your responsibility too. We make no representation or warranty that your particular use of the Data complies with the terms, conditions or licensing requirements of any originating source, exchange, regulator or filing repository. You are responsible for satisfying yourself that your intended use complies with any such terms, and for obtaining any licence your use may require from the originating source.

8. Fees, taxes and payment

8.1 Fees are as stated on your Order Form, in Indian Rupees or United States Dollars.

For customers in India, fees are inclusive of GST at the rate in force on the date of your order.

For customers outside India, the supply is intended to qualify as an export of services and is zero-rated for Indian GST. Fees stated to you are exclusive of any tax payable in your own jurisdiction.

If the statutory rate of GST changes, we may adjust the total so that the amount we receive net of GST is unchanged. That is the only adjustment permitted under this clause: it is triggered only by a change in the statutory rate, and may not be used to increase our net fee. We will give you at least 30 days' written notice, and if you do not accept the adjusted total you may cancel without penalty before it takes effect. Any change may also require you to re-authorise your payment mandate.

8.2 Both Plans are available on monthly and annual billing. Subscriptions renew automatically for successive periods unless cancelled before the renewal date. There is no minimum term on any Plan — you may cancel at any time, and any refund is calculated under our Refund and Cancellation Policy.

For annual plans, we will remind you by email at least 7 days before renewal, stating the renewal price and including a cancellation link. For monthly plans, your payment provider's pre-debit notification applies.

8.3 We may revise fees on 30 days' written notice, effective at your next renewal. If you do not accept the revised fees, you may cancel before renewal.

8.4 Payment is made through our payment provider (currently Razorpay). If a payment fails or is reversed, we may suspend access until it is resolved.

8.5 Cancellation and refunds are governed by our Refund and Cancellation Policy, which forms part of this Agreement.

8.5A Invoiced sales. Where you purchase against an invoice rather than through checkout, the invoice is payable within 15 days of its date, unless your Order Form states otherwise. Amounts unpaid after the due date carry interest at 18% per annum, accruing daily from the due date until payment. Clause 13(a) runs from the due date. Nothing in this clause limits any right we have under the Micro, Small and Medium Enterprises Development Act, 2006.

8.6 You will provide accurate billing details, including a valid GSTIN where applicable, and any information we reasonably need to evidence an export of services.

8.6A Deductions under Indian law. Where Indian law requires you to deduct tax at source from a payment to us, you may deduct it. You will provide the tax deduction certificate within the statutory time so that we can claim credit for it. No gross-up applies to a deduction under this clause.

8.7 Taxes outside India. You are responsible for any tax, duty or levy imposed in your own jurisdiction. If you are required by the law of any jurisdiction outside India to withhold or deduct any amount from a payment to us, you will increase the payment so that we receive the full invoiced amount, and will promptly provide the withholding certificate or equivalent evidence.

8.8 Payment in foreign currency. Where fees are payable in a currency other than Indian Rupees, you bear any bank charge, intermediary charge or exchange difference. Payment must be made through banking channels permitted under Indian foreign exchange law.

9. Service levels

9.1 Uptime commitment. We will use commercially reasonable efforts to make the Service available 99.5% of the time, measured monthly by our monitoring systems, excluding Excluded Downtime.

9.2 Excluded Downtime means unavailability caused by: scheduled maintenance notified at least 24 hours in advance; emergency maintenance; your systems, network or AI Tool; suspension under clause 13; a force majeure event under clause 17; or any act or omission of yours or your Authorised Users.

9.3 Service credits.

Monthly uptime Credit
Below 99.5% but at or above 99.0% 5% of that month's fees
Below 99.0% but at or above 95.0% 10% of that month's fees
Below 95.0% 20% of that month's fees

For annual plans, that month's fees means one-twelfth of the annual fee.

9.4 How to claim. Claim in writing to compliance@bullpen.in within 30 days of the end of the affected month. Credits are applied against your next invoice and are not otherwise payable in cash. If your subscription ends before a credit can be applied, we refund the credit amount. Total credits in any month will not exceed 20% of that month's fees.

9.5 Sole remedy. Service credits are your sole and exclusive remedy for any failure to meet the uptime commitment or for any unavailability of the Service.

9A. Changes to coverage

9A.1 The Data is extracted from sources we do not control. A source may restrict, withdraw or change access at any time.

9A.2 We may discontinue or reduce coverage of any source, or of any company, period or field derived from it, on notice to you. Doing so is not a breach of this Agreement and does not give rise to any claim for damages.

9A.3 Where a discontinuation materially reduces the Service, you may cancel at any time, and we will not charge you beyond your current billing period.

9A.4 What this clause does and does not do. This clause removes any claim for damages arising from a change of coverage. It does not affect your ordinary right to cancel, or any refund payable under our Refund and Cancellation Policy, which continues to apply in the normal way.

9A.5 This clause is separate from clause 9. A change of coverage is not unavailability, and no service credit arises from it.

10. Warranties

10.1 Our warranties. We warrant that:

a. we have the right to enter into this Agreement; b. we will provide the Service with reasonable skill and care; c. we will use commercially reasonable efforts to extract Source Data accurately from the documents it comes from, and to compute Computed Metrics correctly from Source Data.

10.2 What we do not warrant. We do not warrant that:

a. the Data is accurate, complete, current or free of error; b. the underlying filings or disclosures from which Source Data is extracted are themselves accurate, complete or free of error, or that they have not been restated; c. the Data is fit for any particular purpose, including any investment, valuation, credit, compliance or regulatory purpose; d. the Service will be uninterrupted or error-free, save as set out in clause 9; e. any output of an AI Tool using the Data is accurate or reliable; f. your use of the Data complies with the terms of any originating source.

10.3 Exclusion. Except as expressly stated in clause 10.1, and to the fullest extent permitted by law, all warranties, conditions, representations and terms, whether express, implied or statutory — including implied warranties of merchantability, satisfactory quality, fitness for a particular purpose, accuracy and non-infringement — are excluded. The Data is otherwise supplied "as is".

10.4 Your warranties. You warrant that you will comply with clauses 5 and 6, that you will use the Data lawfully, and that you have the authority and the internal controls necessary to do so.

10.5 Security. We will maintain technical and organisational measures appropriate to the nature of the Service, including encryption of data in transit, access controls limiting access to personnel who need it, revocable access tokens, and logging of access to production systems. We will notify you without undue delay of any security incident materially affecting your account or the Data made available to you.

We publish the list of third-party providers we use to deliver the Service at bullpen.in, and will give notice before adding or changing a provider. That list does not form part of this Agreement.

We give no warranty beyond this clause in respect of security, and we do not undertake to hold any particular certification or to carry insurance.

11. Indemnity by you

You will indemnify, defend and hold us harmless against all claims, demands, proceedings, losses, liabilities, damages, penalties, costs and expenses (including reasonable legal fees) arising out of or in connection with:

a. your breach of clause 5 (Restrictions) or clause 6 (AI tools and MCP access); b. any redistribution, disclosure or publication of the Data by you or your Authorised Users; c. any decision, advice, report, output or recommendation you make or issue using the Data, and any claim by any person relying on it; d. any claim that your use of the Data breaches the terms of an originating source, exchange, regulator or filing repository; e. your breach of any applicable law, including securities law and data protection law; f. any output generated by an AI Tool from the Data; g. your breach of any other provision of this Agreement.

Limit on this indemnity. Your total liability under this clause 11 shall not exceed the total fees paid by you to us in the twelve (12) months preceding the claim, except in respect of paragraphs (b) and (d) above and any claim arising from deliberate redistribution of the Data, where your liability is uncapped.

Conduct of claims. The indemnity above operates on the following terms:

a. Notice. We will notify you in writing promptly on becoming aware of any claim to which this clause applies. A delay in notice reduces your liability only to the extent the delay itself increases the loss. b. Conduct. You may, at your own cost, assume conduct of the defence of the claim with counsel of your choosing, and we will not unreasonably withhold consent to your doing so. Where you do not assume conduct, we may defend the claim ourselves, at your reasonable cost. c. No settlement without consent. Neither party will settle, compromise or admit liability in respect of a claim to which this clause applies without the other's prior written consent, not to be unreasonably withheld. A settlement made without consent is not recoverable under this clause. d. Cooperation and mitigation. Each party will give the other reasonable assistance in relation to the claim, and we will take reasonable steps to mitigate any loss recoverable under this clause.

This indemnity survives termination.

12. Limitation of liability

12.1 What is never excluded. Nothing in this Agreement excludes or limits our liability for:

a. fraud or fraudulent misrepresentation; b. wilful misconduct; c. death or personal injury caused by our negligence; or d. any liability that cannot lawfully be excluded or limited under Indian law.

12.2 Excluded losses. Subject to clause 12.1, we are not liable, whether in contract, tort (including negligence), breach of statutory duty or otherwise, for any:

a. loss of profit, revenue, business, contracts or anticipated savings; b. loss of opportunity, goodwill or reputation; c. investment loss, trading loss, or loss arising from any decision taken using the Data; d. loss or corruption of data; e. indirect, incidental, special, punitive or consequential loss,

in each case however arising and whether or not foreseeable.

12.3 Cap. Subject to clauses 12.1 and 12.2, our total aggregate liability arising out of or in connection with this Agreement, in respect of all claims in aggregate, shall not exceed the total fees actually paid by you to us in the three (3) months immediately preceding the event giving rise to the claim.

12.4 Allocation of risk. You acknowledge that the fees have been set on the basis of the allocation of risk in clauses 10 and 12, that you have the ability to verify Data against the sources identified to you, and that these limits are reasonable in the circumstances.

12.5 No IP indemnity. We do not indemnify you against any claim that the Data infringes the rights of any third party, and clause 12.3 applies to any such claim. This reflects the fee level and the fact that the Data is drawn from public documents which you can independently verify.

12.6 One claim, one cap. The cap in clause 12.3 applies in aggregate. Multiple claims do not increase it.

13. Suspension

We may suspend your access immediately, without liability, where:

a. payment is overdue by more than 7 days; b. we reasonably suspect a breach of clause 5 or clause 6; c. your usage threatens the security, integrity or performance of the Service; d. suspension is required by law.

Where practicable we will notify you and give you an opportunity to remedy. Suspension does not suspend your payment obligations.

14. Term and termination

14.1 This Agreement runs for the term of your subscription and renews with it.

14.2 Either party may terminate for material breach if the breach is not remedied within 15 days of written notice. A breach of clause 5 (Restrictions) is deemed incapable of remedy, and we may terminate immediately.

14.3 Either party may terminate immediately if the other becomes insolvent, enters liquidation, or has a receiver or administrator appointed.

14.3A Discontinuation of the Service. We may terminate this Agreement, or discontinue any Plan, on 30 days' written notice to you.

Where we do so, we will refund the fees you have paid for the period after termination takes effect, calculated pro-rata on a daily basis. No other compensation is payable, and clause 12 applies to any claim arising from a discontinuation under this clause.

This clause is separate from clause 9A. A change of coverage is not a discontinuation, and a discontinuation is not a failure to meet the service levels in clause 9.

14.4 On termination you must:

a. stop accessing the Service immediately; b. stop all use of the Data, including issuing any new Permitted Extract after the termination date; c. delete all copies of the Data held in any system under your control, including your own caches, stores and derived datasets, except where retention is required by law or by a professional record-keeping obligation; d. instruct any AI Tool provider holding Data on your behalf to delete it, so far as their terms allow, and take reasonable steps to confirm that they have; and e. within 15 days of a written request, certify in writing, signed by an authorised signatory, that you have complied with paragraphs (a) to (d).

Permitted Extracts already supplied to your clients before the termination date may remain in those clients' hands. You are not required to recall them.

14.5 Clauses 2, 5, 6.2, 6.5, 7, 10.3, 11, 12, 14.4, 15, 16, 18 and 19 survive termination. Termination does not affect rights or obligations accrued before it takes effect, including your obligation to pay fees for any period before termination.

15. Records, logs and audit

15.1 We log all access to the Service, including the account, request, time and volume returned. These logs are our records and are the definitive record of your use.

15.2 Where we reasonably suspect a breach of clause 5, we may request in writing, giving at least 10 business days' notice and identifying the suspected breach, that you provide information about how the Data has been used, stored and disclosed within your organisation.

The request will be limited to what is reasonably necessary to investigate that suspected breach. It does not entitle us to access your systems, premises or client information. Anything you disclose to us in response is your confidential information, and we will use it only to investigate that suspected breach.

15.3 You will keep accurate records of your use of the Data for the term and for 12 months afterwards.

16. Confidentiality

Each party will keep the other's confidential information confidential, use it only for the purposes of this Agreement, and protect it with at least reasonable care. This does not apply to information that is public through no breach, independently developed, or required to be disclosed by law.

The facts contained in the Data are drawn from public documents and we do not claim them as confidential. Our confidential information consists of the selection, structure and arrangement of the Data, the provenance references attached to it, and the Computed Metrics — each of which is our own work rather than a public fact.

17. Force majeure

Neither party is liable for failure or delay caused by an event beyond its reasonable control, including act of God, natural disaster, war, terrorism, civil unrest, epidemic, government action, change in law, failure of internet or telecommunications infrastructure, or failure of a third-party hosting or cloud provider. Payment obligations are not excused.

18. General

18.1 Order of precedence. If there is a conflict: (1) the Order Form, (2) this Agreement, (3) the Refund and Cancellation Policy, (4) the Terms of Use.

18.2 Entire agreement. This Agreement, the Order Form, the Refund and Cancellation Policy and the Privacy Policy are the entire agreement between the parties and supersede all prior discussions. Neither party has relied on any statement not set out in them. Nothing limits liability for fraudulent misrepresentation.

18.3 Amendment. We may amend this Agreement on 30 days' written notice, effective at your next renewal. A change that materially and adversely affects your rights takes effect only on your positive acceptance; if you do not accept it, you may cancel before renewal without penalty and we will refund any prepaid fees for the unused period on a pro-rata basis.

18.4 Assignment. You may not assign, novate or transfer this Agreement, in whole or in part, including by change of control, without our prior written consent. We may assign on notice.

18.5 Severability. If any provision is held invalid or unenforceable, it shall be modified to the minimum extent necessary to make it enforceable, or if that is not possible, severed. The remainder continues in force.

18.6 No waiver. No failure or delay in exercising a right is a waiver of it.

18.7 Notices. Notices to us go to compliance@bullpen.in and to our registered office. Notices to you go to the email and address on your account. Email notices are deemed received on the next business day.

18.8 No partnership. Nothing creates a partnership, joint venture, agency or employment relationship.

18.9 Third party rights. No person other than the parties has any right to enforce this Agreement.

18.10 Publicity. Neither party may use the other's name or logo publicly without prior written consent.

18.11 Prior versions. We retain every prior version of this Agreement and of the policies incorporated into it, together with the record of which version you accepted and when. To obtain a copy, write to compliance@bullpen.in.

19. Governing law and jurisdiction

This Agreement, and any dispute arising out of or in connection with it (including non-contractual disputes), is governed by the laws of India.

The courts at Mumbai, Maharashtra have exclusive jurisdiction. Both parties irrevocably submit to that jurisdiction and waive any objection based on venue or inconvenient forum.

Escalation before proceedings. Before commencing proceedings, the party raising the dispute will give the other 30 days' written notice setting out the dispute, and senior representatives of both parties will attempt in good faith to resolve it within that period.

This does not prevent either party from seeking urgent injunctive relief in any court of competent jurisdiction at any time. You acknowledge that a breach of clause 5 would cause us harm that damages alone could not adequately remedy, and that we are entitled to seek an injunction to restrain it — on the basis of that breach of contract, without needing to establish that the Data is confidential. Nor does this clause delay any right of suspension under clause 13.

20. Contact

Varshney Projects LLP A 101, Gundecha Garden, Lalbaug, Mumbai 400012, Maharashtra, India All support, legal and grievance matters: compliance@bullpen.in

Grievance Officer: Gunjan Chheda, compliance@bullpen.in, at the registered office address above. We acknowledge receipt of a grievance within 48 hours, issuing a ticket number, and respond within 30 days.


Version 1.0 — 15 August 2026

Acceptance record. By ticking the acceptance box at checkout or signing an Order Form referring to this Agreement, you accept it. We record the accepting user, the version accepted, the IP address and the timestamp.

Varshney Projects LLP · A 101, Gundecha Garden, Lalbaug, Mumbai 400012, Maharashtra, India. Retained in the version archive at bullpen.in/legal/versions. This PDF corresponds to Version 1.0 as published on 15 August 2026.