cltr;shft

Privacy Policy
Effective Date: November 3, 2026

1. Introduction

Welcome to cltr;shft.

cltr;shft is a fractional executive shop for content, audience growth and culture strategy, operating through separately registered business entities in New York and California.

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website, subscribe to our communications, request our services, book a consultation, or otherwise interact with us.

For the purposes of this policy, “cltr;shft,” “we,” “us,” and “our” refer to the cltr;shft business entity or entities responsible for the relevant website activity or client relationship.

Our operating entities are:

• cltr;shft New York: CLTR;SHFT LLC
• cltr;shft Los Angeles: CLTR;SHFT LLC

Our website serves as a shared digital presence for both businesses. Client contracts, invoicing, and payments are administered by the applicable contracting entity.

2. Information We Collect

We may collect the following categories of personal information:

Information you provide directly

• Name and email address
• Company or organization name
• Professional title and business affiliation
• Telephone number, if voluntarily provided
• Consultation booking information
• Marketing preferences and newsletter subscriptions
• Project details, service interests, budgets, and other information submitted through inquiry forms
• Communications you send to us

Information collected through website technology

Depending on the functionality enabled on our website, we and our service providers may collect:

• IP address and approximate geographic location
• Browser type, device information, and operating system
• Pages visited and interactions with our website
• Referring websites and marketing campaign information
• Cookie identifiers and related technical data

Booking and payment information

When you schedule a consultation or purchase a service or digital product (such as a playbook or course), our scheduling and payment providers may process the information required to complete your booking and payment.

We do not intend to collect or store complete payment card numbers directly through our website. Payment card information is handled by the applicable payment service provider.

3. How We Use Your Information

We use personal information for legitimate business purposes, including to:

• Respond to inquiries and service requests
• Schedule and administer consultations
• Provide marketing, brand strategy, and consulting services
• Process transactions and maintain appropriate business records
• Send newsletters, industry insights, and promotional communications when you have subscribed or otherwise authorized them
• Understand and improve website performance and user experience
• Manage client and prospective client relationships
• Protect our website and business operations
• Comply with applicable legal and regulatory obligations

We do not treat submitting a service inquiry as automatic consent to receive unrelated promotional emails.

4. Email Marketing and Communications

Visitors may voluntarily subscribe to receive cltr;shft communications, including industry insights, marketing strategies, company updates, and information about our services.

We use HubSpot to help manage subscriber information, communication preferences, and customer relationships.

Where consent is required, we send marketing communications only after obtaining the appropriate permission.

Marketing emails will provide an unsubscribe mechanism. You may also request to change your communication preferences by contacting us using the details at the end of this policy.

Unsubscribing from promotional communications does not necessarily prevent us from sending necessary transactional or service-related communications.

5. Third-Party Service Providers

We use external technology providers to operate our website and deliver services.

Depending on the tools enabled, these providers may include:

• Framer: Website development, hosting, website functionality, and visitor analytics
• HubSpot: Contact management, inquiry forms, email subscriptions, and customer relationship management
• Cal.com: Appointment scheduling and consultation management
• Stripe: Payment processing and associated transaction services

These providers may process personal information on our behalf or, in certain circumstances, as independent service providers or controllers under their own privacy terms.

We may also disclose information to professional advisers, authorized contractors, and governmental authorities when necessary or legally required.

Information may be shared between the cltr;shft New York and California entities as reasonably necessary to respond to inquiries, coordinate client engagements, and operate our shared brand.

We do not disclose personal information to third parties for their independent advertising purposes unless we provide the necessary disclosures and comply with applicable legal requirements.

6. Cookies and Website Tracking

Our website and service providers may use cookies and similar technologies to support essential website functions, maintain security, understand traffic, and measure the effectiveness of our website or marketing activities.

At launch, we do not plan to independently deploy Google Analytics or Meta Pixel.

HubSpot website tracking may be enabled to understand how visitors interact with our website and how they arrive through different channels.

If we introduce additional advertising, analytics, or retargeting technologies, we will update this policy and review applicable consent and opt-out requirements before using them.

You can manage certain cookies through your browser settings. Disabling cookies may affect parts of the website.

Browser privacy signals: Our website does not currently respond to Do Not Track signals. We do not sell personal information or share it for cross-context behavioral advertising.

7. How Long We Retain Information

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including managing subscriptions, responding to inquiries, providing services, maintaining business records, resolving disputes, and complying with legal obligations.

Retention periods may differ depending on the type of information and the reason it was collected.

When information is no longer required, we will take reasonable steps to delete it or otherwise handle it in accordance with applicable law and our retention practices.

8. Data Security

We take reasonable administrative and organizational measures to protect personal information against unauthorized access, disclosure, alteration, and loss.

We also rely on the security measures of our service providers.

No internet-based transmission or electronic storage system can be guaranteed to be completely secure.

9. Your Privacy Choices and Rights

Depending on your location and applicable law, you may have the right to:

• Request information about the personal information we maintain about you
• Request access to or correction of certain personal information
• Request deletion of personal information, subject to applicable exceptions
• Withdraw consent to certain communications
• Opt out of particular uses or disclosures of information, where applicable

To submit a privacy request, contact us using the information below.

We may need to verify your identity before fulfilling certain requests. We will review and respond in accordance with applicable law.

We will not unlawfully discriminate against individuals for exercising applicable privacy rights.

10. International Visitors

cltr;shft operates in the United States. If you access our website from outside the United States, your information may be processed or stored in the United States or other jurisdictions where our service providers operate.

Where international privacy laws apply, we will take any additional measures required by those laws.

11. Children’s Privacy

Our website and consulting services are intended for business and professional audiences and are not directed to children under 13.

We do not knowingly solicit personal information directly from children under 13 through our website. If we learn that we have collected such information in violation of applicable law, we will take appropriate action.

cltr;shft EDU sessions are offered to high school and college students, including students under 18. For participants under 18, a parent or guardian must manage booking and payment and provide consent. We collect only the information needed to schedule and deliver the session, and a parent or guardian may contact us to review or request deletion of their child’s information.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our business operations, website functionality, service providers, or applicable legal requirements.

When we make changes, we will update the effective date at the top of this page and provide additional notice when required by law.

13. Contact Us

If you have questions about this Privacy Policy, our data practices, or your personal information, please contact:

cltr;shft — New York

cltr;shft — Los Angeles

For general website privacy inquiries, you may contact either address. We will direct your inquiry to the appropriate business entity as necessary.

© 2026 cltr;shft. All rights reserved.