TABLE OF CONTENTS

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your information?
4. When and with whom do we share your personal information?
5. Do we offer artificial intelligence-based products?
6. Is your information transferred internationally?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Do United States residents have specific privacy rights?
12. Do we make updates to this notice?
13. How can you contact us about this notice?
14. How can you review, update, or delete the data we collect from you?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include: names, email addresses, usernames, passwords, and contact preferences.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process health data (emotional and psychological data derived from EQ practice sessions).

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Stripe, Apple, and Google. You may find their privacy notices here: https://stripe.com/privacy, https://www.apple.com/legal/privacy/, and https://policies.google.com/privacy.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information includes log and usage data, device data, and information about how and when you use our Services.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. Specifically, we process your information to:

• Facilitate account creation and authentication
• Deliver and facilitate delivery of services to you
• Respond to your inquiries and offer support
• Send administrative information to you
• Request feedback
• Protect our Services
• Identify usage trends
• Save or protect an individual's vital interest

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we have a valid legal reason to do so under applicable law — including your consent, to comply with laws, to provide you with services, to fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

EU/UK users: We rely on Consent, Performance of a Contract, Legitimate Interests, Legal Obligations, and Vital Interests as our legal bases under GDPR.

Canadian users: We process your information with your express or implied consent, or as otherwise permitted by applicable law.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information with third-party vendors and service providers that perform services for us. The categories of third parties we may share personal information with include: Cloud Computing Services, Data Analytics Services, Data Storage Service Providers, Payment Processors, Performance Monitoring Tools, Testing Tools, and User Account Registration & Authentication Services.

We may also share your personal information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies. Our AI Products are designed for AI applications — specifically, brittAlgo, our proprietary personalization engine that analyzes your EQ response patterns to personalize your ForgeEQ experience.

All personal information processed using our AI Products is handled in line with this Privacy Notice. To opt out of AI-based personalization, you may log in to your account settings and update your preferences, or contact us at info@shftexperience.com.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in the United States. We have implemented the European Commission's Standard Contractual Clauses to protect your personal information during international transfers.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as you have an account with us, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If you become aware of any data we may have collected from children under age 18, please contact us at info@shftexperience.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your location, you may have rights to access, correct, delete, or restrict the processing of your personal information. You may review, change, or terminate your account at any time by logging into your account settings or contacting us at info@shftexperience.com.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your local data protection authority.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to, correct, or delete your personal information. To exercise these rights, contact us at info@shftexperience.com.

12. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We will notify you of any material changes by prominently posting a notice or by sending you a notification directly.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@shftexperience.com or contact us by post at:

SHFT LLC
Washington D.C. Metro Area
United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, correct inaccuracies, or delete your personal information. To submit a request, contact us at info@shftexperience.com.