Viravo Agency Privacy Policy

Last updated: Sep 18, 2026

1. Who We Are

Viravo Agency ("Viravo," "we," "us," or "our") is a sole proprietorship registered in the Province of Ontario, Canada, operating an email and SMS retention marketing practice for direct-to-consumer ecommerce brands.

Our website and services are designed for businesses and are not intended for personal, family, or household use. We treat personal information covered by this policy as relating to individuals acting as business representatives rather than in a personal capacity. This does not limit any rights you have under applicable privacy law.

This policy explains how we handle personal information collected through viravo.agency and in the course of providing our services. We are responsible for personal information under our control and have designated a privacy contact accountable for our compliance with this policy.

Privacy contact: marya.choudhri@viravo.agency

2. What We Collect

From website visitors. When you visit viravo.agency, our hosting provider and analytics tools automatically collect technical information including IP address, browser type, device type, referring page, pages viewed, and time spent on the site.

When you book a call. Our scheduling is handled through Google Calendar Appointment Scheduling. When you book, we collect your name, email address, and the responses you provide to our intake questions, which may include information about your business such as monthly revenue range, email list size, and current marketing platform.

When you contact us directly. If you email us, we receive your email address and whatever information you choose to include in your message.

When you message us on social media. If you contact us through LinkedIn, Instagram, or another social platform, we receive your profile name, handle, and the contents of your message. These platforms operate under their own privacy policies and we do not control what they collect about you.

From clients. In the course of an engagement we receive business contact details, billing information, and access credentials to your marketing platforms.

We do not knowingly collect personal information from anyone under the age of 16.

3. Why We Collect It

We use personal information to respond to enquiries, schedule and conduct consultations, assess whether our services are a fit for your business, deliver contracted services, issue invoices and process payments, meet our legal and tax obligations, and, where you have consented, send you marketing communications about our services.

We do not sell personal information. We do not share it with third parties for their own marketing purposes.

Aggregated and de-identified information. We may aggregate or de-identify information so that it no longer identifies any individual, and use that information without restriction for our own business purposes, including benchmarking, performance analysis, case studies, and marketing materials describing our work. Where we publish results from client engagements, we do so in aggregate or anonymized form and only as permitted by our agreement with the client. We do not attempt to re-identify de-identified information.

4. Cookies & Tracking

We use cookies and similar technologies on viravo.agency. These fall into two categories:

‍Strictly necessary. Set by our website platform to make the site function, page delivery, security, and load balancing. These do not require your consent.

‍Analytics and advertising. We use Google Analytics to understand how visitors find and use our site, and advertising pixels from Meta and LinkedIn that allow us to measure campaign performance and show our ads to people who have visited our site. These technologies require your consent and will not load until you provide it.

You can accept or decline non-essential cookies through the consent banner shown on your first visit, and change your choice at any time through the cookie settings link in our footer. You can also configure your browser to refuse cookies, though some parts of the site may not work as intended.

Our site does not currently respond to Do Not Track browser signals.

5. Service Providers & Where Your Data Is Stored

We use third-party service providers to operate our business. These currently include our website platform, Google (scheduling, email, and analytics), Meta and LinkedIn (advertising measurement), and our payment and bookkeeping providers.

‍Cross-border transfers. Several of these providers store and process data on servers located outside Canada, primarily in the United States. This means your personal information may be accessible to the courts, law enforcement, and national security authorities of those jurisdictions under their applicable laws. We select providers that maintain comparable protections through contractual and technical safeguards, but we cannot guarantee that foreign law will offer protection identical to Canadian law. By using our site and services, you acknowledge this transfer.

If you would like more information about our practices regarding service providers outside Canada, contact us at marya.choudhri@viravo.agency.

‍Disclosure required by law. We may disclose personal information without your consent where we are legally required or permitted to do so, for example, in response to a court order, subpoena, warrant, lawful demand from a government authority or regulator, or where disclosure is necessary to establish or defend a legal claim, or to investigate suspected fraud or a breach of our agreements.

‍Business transfers. If our business is sold, merged, reorganized, or transferred in whole or in part, personal information may be transferred to the acquiring party as part of that transaction. Any recipient would remain bound to handle the information in a manner consistent with this policy, and we will notify you of any change in the party accountable for your information.

‍Links to other sites. Our website, emails, and social media profiles may contain links to third-party websites and services, including client sites and platforms we work with. We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policy of any site you visit through a link from ours.

6. Client Customer Data

When we provide retention marketing services, we access and process personal information belonging to our clients' customers, typically email addresses, phone numbers, purchase history, and engagement data held in platforms such as Klaviyo and Shopify.

In relation to that information, our client is the organization accountable for it and we act solely as a service provider on their behalf. We process it only on our client's documented instructions and only for the purpose of delivering contracted services. We do not use client customer data for our own purposes, do not combine it across clients, and do not retain it after an engagement ends except where required by law.

If you are a customer of one of our clients and wish to access, correct, or delete your information, or to unsubscribe from messages, please contact that brand directly, they control the data and are best placed to action your request. If you contact us instead, we will forward your request to the appropriate client.

Clients and customers outside Canada. We work with clients based outside Canada, including in the United States, the United Kingdom, the European Union, the United Arab Emirates, and India, and we process information about their customers who may be located anywhere in the world. Privacy obligations generally follow the location of the individual rather than the location of our business, so the law applicable to a given customer's information may be the law of their own jurisdiction, for example the UK or EU GDPR, a United States state privacy statute, or the applicable data protection law of another country.

Where we act as a service provider, processor, or sub-processor for a client, our handling of that information is governed by our written agreement with that client, including any data processing terms, standard contractual clauses, or international transfer mechanisms it requires. We process such information only on the client's documented instructions and apply the same safeguards described in this policy regardless of where the individual is located. Individuals should direct requests about their information to the brand that collected it.

7. Marketing Communications

We send commercial electronic messages only to recipients who have given express or implied consent as defined under Canada's Anti-Spam Legislation (CASL). Every commercial message we send identifies us, includes our contact information, and contains a working unsubscribe mechanism. We action unsubscribe requests within ten business days.

Booking a consultation does not automatically subscribe you to marketing. You may withdraw consent at any time.

8. How Long We Keep It

We retain personal information only as long as necessary for the purposes it was collected, or as required by law.

- Enquiries that do not become clients: up to 24 months from last contact
- Client records and contracts: 7 years after the engagement ends, to meet CRA record-keeping requirements
- Client customer data: deleted or returned within 90 days of an engagement ending, unless the client instructs otherwise
- Analytics data: per the retention period configured in our analytics tools

9. Security

We protect personal information with safeguards appropriate to its sensitivity, including encrypted storage and transmission, multi-factor authentication on all business accounts, access limited to those who need it to do the work, and unique credentials for each platform.

No method of transmission or storage is completely secure. If a breach occurs that creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA.

10. Your Rights

Under Canadian privacy law you have the right to:

- Access the personal information we hold about you and be told how it has been used and to whom it has been disclosed
- Correct information that is inaccurate or incomplete
- Withdraw consent to our collection, use, or disclosure, subject to legal and contractual restrictions and reasonable notice
- Complain about our handling of your information

To exercise any of these, email marya.choudhri@viravo.agency. We will respond within 30 days. We may ask you to verify your identity before releasing information. Access is provided at no cost in most cases; where a request requires substantial effort we will advise you of any fee in advance and give you the chance to withdraw the request.

‍Quebec residents. If you are located in Quebec, Law 25 gives you additional rights including data portability and the right to object to certain automated processing. Contact us at the address above to exercise them.

‍If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca, or with the Commission d'accès à l'information du Québec if you are a Quebec resident.

11. Changes To This Policy

We may update this policy as our practices or the law change. The date at the top reflects the most recent revision. Material changes will be flagged on our website. Continued use of the site after an update constitutes acceptance of the revised policy.

12. Contact

Questions, requests, or complaints about privacy:

‍Viravo Agency
marya.choudhri@viravo.agency
Oakville, Ontario, Canada