Privacy Policy

Effective date: October 17, 2026

Shift Agency™ (“Shift Agency,” “we,” “our,” or “us”) is operated by Venture AI Holdings Inc. This Privacy Policy explains how we collect, use, store, share and protect personal information through our public website and inquiries, and how to contact us about your privacy choices.

1. Scope and responsibility

This policy applies to visits to the Shift Agency website, inquiries, proposals and our own business communications. Separate signed client agreements and data-processing arrangements may govern information handled while delivering client projects. Where we process personal information solely on a client’s instructions, that client may be responsible for responding to privacy requests.

2. Information we collect

We may collect details you submit through our contact forms or business correspondence, such as your name, email address, company, selected service, project description, information you voluntarily provide in messages, and follow-up communications. Technical data necessary to operate and secure a website may include IP address, browser and device information, referring page, access times and web server logs.

Where website analytics, embedded media or optional technologies are activated, they may collect usage or cookie-related information. We do not ask visitors to submit highly sensitive personal data through general project inquiry forms.

3. How we use information

We use personal information to reply to inquiries; assess project opportunities; prepare proposals; provide requested services; maintain client and business relationships; operate, troubleshoot and secure the website; measure website effectiveness where analytics are enabled; comply with legal or accounting obligations; and prevent misuse or fraud. We use information for the purposes identified when it is collected or other purposes permitted by applicable law.

4. Consent and marketing messages

Submitting a project inquiry authorizes us to use the information to respond. We do not treat a general inquiry as automatic consent to receive unrelated marketing campaigns. Where consent is legally required for promotional electronic messages, including under Canada’s anti-spam legislation, we will seek or rely on an appropriate lawful basis. You may withdraw marketing consent using the unsubscribe mechanism in a message or by contacting us.

5. Cookies, analytics and third-party technologies

Our website may use strictly necessary cookies or similar mechanisms for security, basic site operation and user preferences. Optional analytics, audience-measurement or embedded content technologies may be enabled as the website evolves. Where applicable law requires consent for non-essential technologies, we will obtain it before use. Browser controls may allow you to block or remove cookies, although certain website functions could be affected.

Embedded videos, maps, external links or social platforms may apply their own privacy practices when you interact with them. This section constitutes the site’s cookie and tracking notice; no separate cookie-policy page is maintained.

6. Disclosures and service providers

We may engage hosting, email delivery, cybersecurity, website analytics, cloud storage, development, payment processing and other professional providers in order to operate our business. Providers may receive only the information reasonably needed for their services and may process it under their own applicable contractual and legal obligations. We may disclose information if required by law, to protect rights or security, or as part of a legitimate business transaction. We do not sell personal information to data brokers.

7. International transfers

Service providers or hosting infrastructure may be located outside your province or Canada. When data is handled in another jurisdiction, it may be subject to that jurisdiction’s laws, including lawful access requests. We assess cross-border handling in light of applicable contractual, technical and organizational safeguards.

8. Retention and protection

We retain business inquiries and related information only as reasonably needed for correspondence, service delivery, operational requirements, applicable limitation periods and legal obligations. We apply appropriate administrative, technical and organizational security measures, but no website or electronic transmission is completely risk-free.

9. Access, correction and other rights

Depending on applicable law, including federal or provincial Canadian privacy legislation, you may request access to or correction of personal information and ask questions about our practices. You may withdraw consent where permitted by law, subject to contractual, legal and operational limitations. We may need to verify identity and may be required to retain some information under applicable law.

10. Children

Shift Agency’s public business services are directed toward organizations and their authorized representatives rather than children. Please do not submit information about children through a project inquiry form unless it is appropriate and you have lawful authority to do so.

11. Changes to this policy

We may revise this policy to reflect changes to the website, services or legal requirements. We will update the effective date when changes are made. Material changes will be communicated where required by law.

12. Contact and privacy requests

For access requests, corrections, consent withdrawal, complaints or privacy questions, contact the person responsible for privacy matters through the Shift Agency contact page and identify the request as a privacy inquiry. We will respond in accordance with applicable law. For questions about website use, see the Terms of Use.