PRIVACY POLICY

Effective Date: January 8, 2026

1. INTRODUCTION

The Fulcrum ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, participate in our community, or communicate with us via SMS, email, or other channels.

By accessing or using our services, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our services.

2. INFORMATION WE COLLECT

Personal Information You Provide

We collect information that you voluntarily provide to us, including:

• Contact Information: Name, email address, phone number, mailing address

• Account Information: Username, password, profile information

• Payment Information: Billing address, payment card details (processed securely through third-party payment processors)

• Communication Data: Information you provide when contacting us, participating in webinars, forums, or community discussions

• Professional Information: Real estate license information, business details, professional background

• Survey and Feedback: Responses to surveys, testimonials, or feedback you provide

• Consent Records: Records of your consent to receive electronic communications, including timestamp, IP address, and method of consent

Information Collected Automatically

When you access our website or services, we may automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers

• Usage Data: Pages visited, time spent on pages, links clicked, referring website

• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to collect information about your browsing activities (see Section 8 for more details)

Information from Third Parties

We may receive information about you from third parties, such as:

Social media platforms (if you connect your account)

Payment processors

Marketing and analytics partners

Public databases and real estate licensing boards

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

• Provide Services: Deliver educational content, community access, webinars, and membership benefits

• Electronic Communications: Send emails and SMS messages as described in Section 9, including appointment confirmations, reminders, program updates, educational content, newsletters, and follow-up messages

• Process Payments: Handle billing, subscriptions, and refund requests

• Improve Services: Analyze usage patterns, optimize our platform, and develop new features

• Marketing: Send promotional materials about our services, events, and opportunities (with your consent as outlined in our Terms and Conditions)

• Legal Compliance: Comply with legal obligations, including maintaining records of consent for electronic communications as required by the Telephone Consumer Protection Act (TCPA) and CAN-SPAM Act

• Security: Detect, prevent, and address fraud, security issues, and technical problems

• Customer Support: Respond to your inquiries and provide assistance

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Payment processors

Email service providers (ESP) and SMS communication platforms

Web hosting and cloud storage providers

Customer relationship management (CRM) systems

Analytics and marketing platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

Business Transfers

If we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, or to:

Comply with legal obligations

Protect our rights, property, or safety

Protect the rights, property, or safety of our users or the public

Enforce our Terms and Conditions

With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

Community Features

Information you share in public forums, community discussions, webinars, or testimonials may be visible to other members and the public.

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• Consent Records: Records of your consent to receive electronic communications (email and SMS) are retained for at least 4 years as required by federal regulations

• Account Information: Retained for the duration of your membership and for a reasonable period thereafter

• Payment Information: Retained as required for accounting, tax, and legal purposes

• Communication Records: Email and SMS records retained in accordance with applicable laws

When we no longer need your information, we will securely delete or anonymize it.

6. YOUR PRIVACY RIGHTS

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you

• Correction: Request correction of inaccurate or incomplete information

• Deletion: Request deletion of your personal information (subject to legal obligations and legitimate business purposes)

• Opt-Out of Marketing: Unsubscribe from marketing emails or SMS messages at any time (see Section 9)

• Data Portability: Request a copy of your data in a portable format

• Restrict Processing: Request that we limit how we use your information

• Object to Processing: Object to our processing of your information for certain purposes

To exercise these rights, contact us at [email protected].

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

The right to know what personal information we collect, use, disclose, and sell

The right to delete your personal information

The right to opt-out of the sale of your information (note: we do not sell personal information)

The right to non-discrimination for exercising your CCPA rights

To exercise your CCPA rights, contact us at [email protected].

7. SECURITY

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption of data in transit using SSL/TLS

Secure storage of personal information

Access controls and authentication

Regular security assessments

Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us:

Remember your preferences and settings

Understand how you use our website

Deliver targeted advertising

Analyze website traffic and performance

Maintain your login session

Types of Cookies We Use:

• Essential Cookies: Necessary for the website to function properly (e.g., login authentication, security)

• Performance Cookies: Help us understand how visitors interact with our website through analytics

• Functional Cookies: Remember your preferences and settings

• Marketing Cookies: Deliver relevant advertisements and track campaign effectiveness

Your Cookie Choices:

You can control cookies through your browser settings. Most browsers allow you to:

View what cookies are stored and delete them individually

Block third-party cookies

Block all cookies

Delete all cookies when you close your browser

However, disabling cookies may limit your ability to use certain features of our website.

9. ELECTRONIC COMMUNICATIONS

Email Communications

By providing your email address and agreeing to our Terms and Conditions, you consent to receive email communications from us, including:

Membership confirmations and account updates

Program announcements and educational content

Webinar invitations and event notifications

Newsletters and community updates

Promotional materials about our services

Important service updates and policy changes

How to Opt-Out of Marketing Emails:

Click the "unsubscribe" link at the bottom of any marketing email

Contact us at [email protected]

Update your communication preferences in your account settings

Note: Even if you opt-out of marketing emails, we may still send you transactional emails related to your account, membership, payments, and important service updates.

SMS/Text Message Communications

By providing your phone number and agreeing to our Terms and Conditions, you consent to receive SMS messages from us, including:

Appointment confirmations and reminders

Program updates and announcements

Follow-up messages related to your membership

Educational content and resources

SMS Terms:

• Message Frequency: Varies based on your membership activity and program participation

• Message and Data Rates: Standard message and data rates may apply as determined by your mobile carrier

• Opt-Out: Reply STOP to any message to unsubscribe. You will receive a confirmation message.

• Help: Reply HELP for assistance or contact [email protected]

• Supported Carriers: All major U.S. carriers are supported

• No Purchase Required: Your consent to receive SMS is not a condition of purchasing goods or services

Your SMS Privacy:

We do not share your phone number with third parties for their marketing purposes without your explicit consent

We maintain records of your SMS consent including timestamp, opt-in method, and IP address for compliance with the Telephone Consumer Protection Act (TCPA)

Your phone number is stored securely and protected in accordance with this Privacy Policy

10. THIRD-PARTY LINKS

Our website and communications may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete that information promptly.

12. INTERNATIONAL USERS

Our services are operated 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, and processed in the United States, where data protection laws may differ from those in your country.

By using our services, you consent to the transfer of your information to the United States and the processing of your information in accordance with this Privacy Policy and U.S. law.

13. DO NOT TRACK SIGNALS

Some web browsers have a "Do Not Track" feature that signals to websites that you do not want your online activities tracked. Our website does not currently respond to Do Not Track signals.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

Posting the updated policy on our website

Updating the "Effective Date" at the top of this policy

Sending you an email notification (for significant changes)

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

15. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

The Fulcrum
Email: [email protected]

For questions specifically about:

• SMS Communications: Reply HELP to any text message or email [email protected]

• Email Communications: Use the unsubscribe link in any email or email [email protected]

• Privacy Rights Requests: Email [email protected] with "Privacy Rights Request" in the subject line

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.


Last Updated: January 8, 2026