Privacy and Cookie Policy

Introduction

At Fulkrum, clarity and safety guide our products and the way we handle your information. This Privacy Policy explains what we collect, how we use it, how we protect it, and the choices you have, so you can focus on your child knowing your data is treated with the same care.

Fulkrum Health LLC is the data controller responsible for processing your personal data.

Address: Fulkrum Health LLC, 30 N Gould St, Ste R, Sheridan, WY 82801, United States

Email: privacy@fulkrum.health

Information We Collect

We collect only what is necessary:

Information you provide. When you place an order, download an ebook, join our community, or contact us. This includes your name, billing and shipping address, email address, phone number, and payment details handled by our payment processor.

Information about your baby. When you join the Fulkrum community, we ask for your baby's date of birth or due date. You provide this on behalf of your child as their parent or legal guardian. We use it only to deliver content appropriate to your baby's developmental stage. We do not collect any other information about your child. Given the context in which it is provided, we treat this information with extra care and apply additional safeguards to its storage and access.

Device and usage information. Browser type, device identifiers, IP address, and how you interact with our site, so we can keep the site secure and working properly.

Cookies and similar technologies. Used with your consent to support site functionality and to understand how the site is used. See the Cookie Policy below.

Information collected during digital purchases. Email address and download activity, so we can deliver your purchase and prevent fraud.

How We Use Your Information

We process personal data only where there is a clear lawful basis:

To fulfill our contract with you. Processing orders, delivering digital products, providing community access.

With your consent. Sending newsletters or marketing communications, and using non-essential cookies including analytics and advertising cookies. You can withdraw consent at any time.

To comply with legal obligations. Accounting, tax, product safety, and consumer protection requirements.

For our legitimate interests. Keeping the site secure, preventing fraud, understanding how parents use our content, and improving our educational resources.

Sharing of Information

We do not sell your personal data for money. Under some US state privacy laws, including the California Consumer Privacy Act, the use of advertising and analytics cookies to deliver targeted advertising can be classified as a "sale" or "share" of personal information. We use Meta (Facebook and Instagram) and Google advertising and analytics tools, which may involve sharing limited information with these providers for cross-context behavioral advertising. You can opt out of these cookies through our cookie banner or by following the instructions in the US State Privacy Rights section below.

We share personal data with the following categories of recipients only where necessary and proportionate:

Payment processing. Fulkrum Health LLC is the merchant of record for all purchases. Payments are processed on our behalf by Shopify (United States) using Shopify Payments, and for subscription products, by Recharge (United States) through Shopify. Fulkrum does not collect or store your full payment card information; this is handled by our payment processors. Tax calculation and invoicing is managed by Quaderno (Spain, with infrastructure in the EU).

Email and marketing. Klaviyo (United States) for transactional emails, marketing emails, and customer engagement flows.

Community platform. Circle (CircleCo, Inc., United States) hosts the Fulkrum community. Account and profile information you provide is processed by Circle on our behalf. Circle also maintains its own Privacy Policy governing platform-level data it collects independently (such as login telemetry and security logs), available at https://circle.so/privacy. By joining the Fulkrum Community, you acknowledge that both this Privacy Policy and Circle’s Privacy Policy apply to your use of the platform.

Analytics and advertising. Google (United States) for analytics and advertising, and Meta (United States) for advertising on Facebook and Instagram. These cookies fire only with your consent.

Tax compliance. Quaderno (Spain, with infrastructure in the EU) for global tax calculation and invoicing.

Shipping and fulfillment. Logistics partners in the markets we ship to, who process your name and shipping address to deliver your order.

Legal authorities. Where required by law, or to protect our rights or the safety of others.

A full list of our sub-processors and their processing locations is available on request at privacy@fulkrum.health.

International Transfers

Fulkrum and its providers operate globally. Your information may be stored or processed in the United States, the European Economic Area, the United Kingdom, Malaysia, Australia, New Zealand, Singapore, and other regions where we operate.

For transfers from the EU and UK to the United States, our key US-based processors (Shopify, Klaviyo, Circle, Meta, Google) are certified under the EU-US Data Privacy Framework and its UK Extension, which the European Commission and UK government recognize as providing an adequate level of data protection.

For transfers to countries that are not covered by an adequacy decision, we rely on the European Commission's Standard Contractual Clauses together with the UK Addendum or the UK International Data Transfer Agreement, supported by technical and organizational measures to keep your data secure in transit and at rest.

Data Retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this Policy.

• Order and transaction records: 7 years, to meet tax and accounting requirements.
• Marketing contact information: Until you withdraw consent, and then up to 12 months for suppression-list purposes to ensure we do not contact you again.
• Community account information: While your account is active, and for 24 months after account closure to handle disputes, refund requests, and meet legal obligations. After 24 months, accounts are deleted or anonymized.
• Baby date of birth or due date: Deleted within 30 days of account closure, or earlier on request.
• Customer support correspondence: 3 years from the date of the last contact.
• Cookie data: Retained per the durations set out in our cookie banner, typically between the duration of your session and 13 months for analytics cookies.

Your Rights

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

• Access, correct, or delete your personal data.
• Withdraw consent for marketing communications at any time.
• Object to or restrict certain processing.
• Request portability of your data (EU/UK).
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, contact us at privacy@fulkrum.health, or use the GDPR portal listed below if you are in the EU or UK. We respond to all requests within one month, or sooner where required by law.

Children's Privacy

Our website and products are intended for parents and caregivers, not children. We do not knowingly collect personal data from children under 13 in the United States, or under 16 in the EU and UK, without verified parental consent.

The only information we hold about a child is the date of birth or due date that you, as the parent or legal guardian, choose to provide when joining the Fulkrum community. This is used solely to deliver content appropriate to your baby's developmental stage and is not shared, sold, or used for marketing. You can ask us to delete this information at any time by contacting privacy@fulkrum.health.

US State Privacy Rights

If you are a resident of California or another US state with comprehensive consumer privacy laws, you have rights including the right to know what personal information we collect about you, the right to request deletion, the right to correct inaccurate information, and the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising.

To opt out of the use of advertising and analytics cookies, use the cookie banner on our website or the Cookie Settings link in the footer. To exercise other rights, email privacy@fulkrum.health with your request. We may need to verify your identity before responding.

Security and Data Breaches

We apply technical and organizational measures consistent with international standards to protect your information against unauthorized access, loss, or misuse. No system is perfectly secure, and we continuously assess and strengthen our safeguards.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours where required by law, and notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

EU and UK GDPR Representatives (Article 27)

If you are located in the EU or the UK and have questions or concerns regarding your personal data, you may contact our appointed GDPR representative.

EU Representative

Euverify Ltd (Ireland)

Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23 AT2P, Ireland

Email: gdpr@euverify.com

UK Representative

Euverify Ltd (UK)

3rd Floor, 86-90 Paul Street, London, EC2A 4NE, United Kingdom

Email: gdpr@euverify.com

To submit a Data Subject Access Request (DSAR), data deletion request, or any other GDPR-related inquiry, please use our secure portal:

https://gdpr.euverify.com/verify/dfe9c3c3-cdb1-4d63-a76e-70d898299115

This link allows you to verify our appointed representative and submit GDPR requests directly. Requests submitted through this portal are logged and tracked to ensure a timely response and compliance.

Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with the revised effective date. Significant changes will be communicated directly when required by law.

Contact Us

For privacy questions or to exercise your rights, contact us at:

Fulkrum Health LLC

30 N Gould St, Ste R, Sheridan, WY 82801, United States

Email: privacy@fulkrum.health