Last modified: May 15, 2019

1. Introduction

Fulcrum Labs, Inc. (“Company” or “we” or “us”) respects your privacy and is committed to taking reasonable steps towards protecting your privacy online and managing your information through our compliance with this policy.  This policy describes the types of information we may collect from you or that you may provide when you visit the Company’s website at https://www.fulcrumlabs.ai and the Company’s mobile applications (collectively, the “Sites“) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to (i) the Sites; (ii) any e-mail, text and other electronic messages concerning the Company’s operations, products or services; and (iii) our marketing contacts with you, including your interactions with our advertising and applications on third-party websites (e.g., LinkedIn; Facebook and Instagram).

This policy does not apply to other websites to which we may link, or to other companies or persons who might be listed as third-party contacts, vendors or suppliers on the Sites, or to whom we may refer you if you call or write us.  We may post links on the Sites as a way of helping you locate related information and products, however, when linking to another website, you should consult that third-party website’s privacy policy, since they are not covered by this Privacy Policy and may follow different procedures. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use the Sites or provide the Company with any of your personal information. By accessing or using the Sites and/or by contacting the Company and providing any personal information, you consent to the collection and use of information by the Company in accordance with this privacy policy. We may change this policy from time to time without prior notice, except that we will notify you of any material changes to this policy.  All changes to this policy will be posted on this page and your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Children Under the Age of 13

Our Sites are not intended for children under 13 years of age. No one under age 13 is authorized to use, or provide any information to, the Sites. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not request, or knowingly collect, personal information from children under 13. If we learn of any mistaken or inadvertent collection or receipt of personal information from a child under 13 through their misuse of the Sites, we will delete that information from our records. We ask all parents and guardians to assist us in our efforts to comply with COPPA by prohibiting children under the age of 13 from providing the Company with any personal information or using the Sites without parental oversight and assistance.  If you believe we might have any information from or about a child under 13, please contact us at info@the-fulcrum.com.

3. Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Sites, including, but not limited to: first name, last name, title, company, business type, state, email address, phone, whether you are a Fulcrum Labs client, interest in our products, solutions, and/ or services, and Optional profiling information

We may collect this information from the individuals who respond to Fulcrum Labs’ marketing solicitations within the United States adaptive learning..

4. Information You Provide to Us.

The information we collect on or through our Sites may include.

• Information that you provide by filling in forms on our Sites. This includes information provided at the time of registering with our Sites, posting material or requesting further services or information.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your search queries on the Sites.

5. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Sites, we may collect certain information about you and your equipment, browsing actions and patterns, via automated technologies such as cookies and web beacons.  Such information may include:

• Details of your visits to our Sites, including traffic data, location data, logs and other communication data and the resources that you access and use on the Sites.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect analytic information about our users’ online activities over time and across third-party websites or other online services.  The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Sites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Sites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Sites.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.
• Flash Cookies. Certain features of our Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Server Logs. A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser. Certain activities that you perform on our Sites may record information in server logs, such as if you enter a search term into a search box located on the Sites. The server log may record, for example, the search terms or the link you clicked on to bring you to our Sites. The server log may also record information about your browser, such as your IP address and the cookies set on your browser. 
• Widgets. A “widget” is generally an application that can be embedded in a webpage.  Widgets can provide real-time information to the webpage.  Widgets are often provided by third-parties; we may provide widgets on our website. Widgets may enable the third parties that provide them to collect data about users visiting the Site

6. How We Use Your Information/Disclosure

All information is collected from the people who respond to the marketing solicitation for technology and services targeting the United States mortgage lending industry. The information received is maintained in marketing and sales databases associated with commercially available sales and marketing automated systems. The sole purpose of collecting this information is for future marketing and sales solicitations regarding Fulcrum Labs’ thought-leadership content, such as blogs, white papers, infographics, etc., or Fulcrum Labs’ products and services information. Your information may be shared with third party subcontractors and our affiliates. By providing this information, responder grants us permission to contact them. We will retain the responder’s information until the contact opts-out from solicitation from Fulcrum Labs.

7. Accessing and Correcting Your Information

You can review and change certain personal information that you provided us by contacting us in accordance with Section 11 below.

8. Data Security

We have implemented reasonable physical and electronic measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. However, no security measures are perfect or impenetrable. No data can be guaranteed to be totally secure and the safety and security of your information also depends on you.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites nor can we guarantee that such information will not become publicly available. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices. 

9. Users Outside of the United States

If you are visiting the Sites from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Sites may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country.  By using the Sites or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

10. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page.  The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Sites and this privacy policy to check for any changes.

11. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: Fulcrum Labs, 555 W. 5^th St, Floor 35, Los Angeles, CA 90013