Privacy Policy

Last Updated May 7, 2025

This privacy policy applies to the personal information that Shift Financial and Accounting Insights Inc. ("Shift", "we", "us", or "our") collects, uses, and discloses in connection with your access to and use our services including Lighthouse software, FixYourProfit.com, Client Portal, Reconciliation Buddy app, and How's My Bookkeeper app (our "Apps") and our website at https://www.shiftfinancial.co/ (our "Website" and together with our Apps, our "Services"). This privacy policy describes the personal information we collect when you access and use our Services, how we use and disclose that information, and describes your rights with respect to your personal information under our control.

This privacy policy is effective as of the effective date written above. We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make material changes to this privacy policy we will notify you, including by posting the new policy on our Website.

This Policy is currently in effect and was last updated on May 7, 2025.

  1. PERSONAL INFORMATION WE COLLECT

    When you use our Services, you may be required to provide personal information If you fail to provide your personal information, we may be unable to deliver our Services to you.

    We may collect the following personal information:

    (a) Identity and contact information. This may include your name, nationality, your address and contact details and photographs and other images;

    (b) Use of our Services. Information such as the types of Services you use and how you use them, as well as feedback about your experiences and your use of our App and/or Website;

    (c) Accounting information. This may include information gathered through granting of user licenses on your accounting software, approved API connections to your accounting software, access to other software required for accounting purposes, hard copies of information provided and verbal communication of accounting related matters;

    (d) Personal interests, preferences and opinions. Information about your interests, preferences and opinions such as products you are interested in;

    (e) Our interactions with you. A record of any interactions and correspondence between us, such as calls made to us, any interactions you have with our staff or representatives (whether online, on the phone, or in person) and any interactions with us or posts that refer to us on social media;

    (f) Survey information. Your responses to surveys conducted by us or on our behalf; and

    (g) Use of Website, Apps and social media platforms. Details of your App usage, visits to our Website, your use of social media platforms and other information collected through cookies and other tracking technology including information that you look at (additional details below), the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other diagnostic data.

    We do not store or collect your payment details such as credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information. Payments are processed through third-party payment processors (such as Stipe, QuickBooks Marketplace in-App Payments, Apple Store in-App Payments, and Google Play in-App Payments) whose use of your personal information is governed by their privacy policies.

    Method of Collection

    We will collect personal information from you directly to the greatest extent possible. However, we may also collect personal information from other third parties including:

    (a) other persons that interact with us on your behalf;

    (h) through the use of cookies and similar tracking technologies, as described below;

    (i) our service providers and agents who provide customer service;

    Tracking Technologies

    As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

    Some information is also collected automatically every time you visit our Website (e.g., through cookies and conversion beacons). We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Website, tracking users' movements around the Website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

    Cookies

    Our Website may use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This means we will continue to show ads to you across the Internet, specifically on the Google Content Network (" GCN"). This could be in the form of an advertisement on the Google search results page, or a site in the GCN.

    Any data that is collected will be used in accordance with our own privacy policy and Google's privacy policy.

    Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. We currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track", please visit https://allaboutdnt.com for more information.

    We may also partner with other third parties from time to time to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other sites to provide you advertising based upon your browsing activities and interests.

    Conversion Beacons

    We may also use Conversion Beacons (small, simple snippet of HTML code) inserted in the source of the designated website pages. Conversion Beacon technology works by leveraging industry standard browser-based cookie technology and simple standard html coding. Email recipients who receive a Conversion Beacon enabled email message will receive a small unique cookie that is stored in their browser session. This unique cookie is later used to connect the email recipient with the subsequent recipient activity on the client website. The purpose of tracking the activity is to better understand the email flow of our subscribers and to measure the effectiveness of ads. For this reason our Conversion Beacons are tied to personally identifiable information (email address). You can control our use of conversion beacons by unsubscribing from our email messages.

  2. USE OF PERSONAL INFORMATION

    We may use your personal information for the following purposes:

    (a) Provide products and services. To provide our Services to you and to send you Service-related communications, to deliver of benefits and Services associated with your Services, to identify and verify your identity in connection with the Services we provide, or to provide or facilitate any special arrangements you may have asked for;

    (b) Customer support. For customer support purposes such as responding to your enquiries and requests, providing assistance to you in relation to provision of our Services;

    (c) Marketing purposes. For providing you with certain marketing communications (as explained in more detail below);

    (d) Social interactions. To administer campaigns, contests and sweepstakes conducted by us when you choose to participate in them, including disclosing the winners of any such contest;

    (e) Product and service improvement. For the purposes of improving our products and services for the benefit of our customers generally, including to ensure that our App, Website and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances;

    (f) Special discounts. We offer special discounts and promotions from time to time. To assess your eligibility and ensure that your order is correctly processed we may need to record additional information at the time of ordering; and

    (g) Legal and administrative purposes. For legal and administrative purposes such as verifying payment, screening against fraud, screening against abusive orders, money laundering and other criminal or unlawful activities, accounting and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.

    Marketing

    We may use personal information for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies and third parties) (ii) for sending or showing you joint marketing offers about our services and packages, contests and sweepstakes, and ancillary services; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our Website.

    We may also use personal information to analyze our customers' preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to our customers. This may involve us combining personal information that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends.

    We may communicate marketing and promotions to you online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your personal information.

    You have the right to ask us not to process your personal information for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your personal information. You can also exercise the right at any time after we have collected and used your personal information for direct marketing purposes by following the opt-out instructions contained in the relevant communications or updating your email subscriptions.

    We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us at our e-mail address set out below. Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about your orders with us and any other services that we provide to you. Where you are an account holder, you will also continue to receive administrative emails, account and/or order summaries and updates to our services.

    Children's Privacy

    Our Services are not addressed to anyone under the age of majority in the jurisdiction where they reside ("Children"). We do not knowingly collect personal information from Children. If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us. If we become aware that we have collected personal information from Children we will take steps to delete that personal information from our systems.

    WHEN PERSONAL INFORMATION MAY BE DISCLOSED

    We do not sell your personal information to third parties.

    In certain circumstances, we may disclose your personal information to third parties as follows:

    (h) Our service providers. We will permit our third party service providers, including agents and contractors and our affiliates, to use your personal information on our behalf for the purposes set out in this privacy policy. Examples of such third parties include operators of our IT systems, other services relating to information technology, marketing, data processing and storage, research, conducting surveys and customer relations. We use contractual and other means to ensure that your personal information is afforded protection that meets the requirements of privacy legislation whenever one of our third party service providers is used to perform services on our behalf. In some cases, our third party service providers are located outside Canada. As such, your personal information may be processed or stored in other countries. In certain circumstances, our third party service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries.

    (i) We may disclose your personal information to third parties in order to facilitate any special arrangements that you may have requested;

    (j) Third parties to facilitate Services. In order to facilitate and administer the Services provided to you, we may transfer your personal information to third parties such as other persons who interact with us on your behalf;

    (k) Our third party partners, for marketing purposes. We may disclose your personal information to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services. Subject to us having obtained appropriate consent from you, we may also disclose your personal information to our third party marketing partners in order that they may market their products and services to you. Customers who do not wish to be contacted for research, marketing or survey purposes should advise us by contacting us at the e-mail address provided below; and

    (l) Government and regulatory bodies and other individuals, bodies and organizations. We may disclose your personal information to governments and regulatory authorities and bodies and to other individuals, bodies and organizations such as law enforcement bodies, legal advisers, and other individuals, bodies and organizations for the purposes of complying with our legal obligations. We may also disclose your personal information as required by law when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

    (m) Business Transactions. We may share your personal information with parties in connection with an actual or proposed merger, acquisition, or sale involving all or a portion of our business or assets. You will be notified via email and/or a prominent notice on our Website of any change in control of your personal information.

    (n) We may also disclose your personal information for reasons of safety and security, to enable us to provide our products and services to you, and otherwise for legal and administrative purposes.

  3. Information Retention

    We have policies and procedures in place regarding the retention of personal information. We will retain your personal information for as long as is necessary for the purpose(s) for which it was collected and any other permitted related purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    Our retention periods may vary depending on the purposes for which your personal information was collected. Once your personal information is no longer needed, it is either irreversibly anonymized (and the anonymized personal information will be retained) or securely destroyed.

  4. USE OF ARTIFICIAL INTELLIGENCE (AI)

    As part of our commitment to providing exceptional services, we may use artificial intelligence (AI) tools to assist in processing and analyzing data, improving operational efficiency, and delivering insights. These tools operate strictly within the scope of this Privacy Policy, ensuring that any data processed aligns with our outlined purposes, including service delivery, personalization, and product enhancement. By using our Services, including the Apps and Website, you acknowledge and consent to our use of Al tools in accordance with this Policy. If you have any concerns or questions regarding the use of AI, please contact us at the details provided below.

  5. SAFEGUARDS

    No data transmission over the internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, organizational and technological safeguards to protect your personal information in accordance with the requirements of data protection legislation. We use several security techniques including secure servers, firewalls and encryption, as well as physical safeguard of the locations where data is stored. If you have any questions about the security of your personal information, you can contact us at our e-mail address set out below.

    All personal information we collect about you is stored on our or our subcontractors' secure servers. We comply with our security policies and standards when accessing or using personal information and restrict access to your personal information to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you should not share that password with anyone.

    Personal information is encrypted as it travels over the internet. Depending on your web browser you may see a secure webpage indicator. The use of Secure Socket Layer protocol (SSL) allows all personal information, such as your payment card number, to be encrypted as it travels from your computer to our order system. Once received, the information is unencrypted and processed in the same way as a payment card transaction placed via the telephone.

  6. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION AND CONTACTING US

    Should you have any questions regarding this Policy or complaints with respect to our handling of personal information, you may contact our [Privacy Officer] at:

    Shift Financial and Accounting Insights Inc.

    Attention: Spencer Sheinin

    Telephone: (778) 808-6863

    Email: spencer@shiftfinanical.co

    With certain limited exceptions, you have a right to access your personal information that we hold, to request information about how we have used or disclosed your personal information, and to request correction of personal information that is inaccurate or incomplete. To make such a request, please contact us in writing at our e-mail address provided above. We will endeavour to provide any help that you need to prepare a request in respect of your personal information. Part of this process may involve us requesting you to supply enough information to enable us to account for the existence, use and disclosure of the personal information.

    We will respond to your request within a reasonable timeframe and will notify you if we are unable to respond to your request within the time period provided by law. If we are unable to provide you with your personal information, we will explain our reasons for refusing access. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.