Last updated: October 29, 2026
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
This Privacy Policy applies to all visitors and customers. Where you have agreed to be bound by our Terms of Use (e.g., by starting a trial or subscription), that agreement supplements—but does not reduce—your privacy rights described here.
We use Your Personal Data to provide the Service. We improve the Service using data about how it is used and how it performs, not the contents of Your Data Store. We use Your Data Store Data for anything beyond providing the Service only if You opt in. By using the Service, You acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of information in accordance with this Privacy Policy, subject to your rights to withdraw consent as described herein.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
Fulcra is dedicated to Your privacy and security. Notwithstanding anything to the contrary contained herein, under no circumstances will We share or sell Your Personal Data, Personally Identifiable Information, Usage Data or Data Store Data, or any other data collected from or about You, with any third party (other than our third party service and infrastructure providers such as Google Cloud) without Your prior explicit consent. See the section “Personal Data That Will Not Be Shared or Sold Without Your Explicit Consent” below for more detail.
In particular: We do not use the data You or Your agents store in Fulcra to target advertising, build advertising profiles, or train advertising models, and We do not provide it to anyone else for those purposes. Advertising and analytics at Fulcra operate only on account identifiers and website-visit data, never on Your context data.
The Personal Data We collect includes but is not limited to:
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission, Data Store Data, including:
We use this information to provide and customize features of Our Service for You. We do not use it to improve or develop Our Service, to train artificial-intelligence models, or to create aggregated or de-identified data unless You opt in, as described in “How We Use Data Store Data” below. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
Third party apps, devices and wearables. If You choose to connect the Context app or Your Fulcra Data store with a third-party health and fitness related application (such as Apple HealthKit) or device We will receive additional health and lifestyle data from the third-party providers of those apps or devices.
You can enable or disable access to this information at any time, through Your Device settings or within Your Fulcra Account Settings, as applicable.
Where we collect biometric identifiers or health metrics that may be considered biometric information, we will obtain your explicit written consent, store such data encrypted at rest, prohibit its sale, and delete it within three (3) years or sooner once the purpose of collection is complete.
As defined above, Data Store Data is everything You or Your agents put into Your Fulcra data store, data derived from it, and the names, labels, notes and file names You create. We use it only to provide the Service to You as You direct, to provide support You ask for, where reasonably necessary to detect, investigate or prevent security incidents, unauthorized access, fraud or misuse of the Service, and where the law requires.
We do not use Your Data Store Data, or anonymized or aggregated data derived from it, to improve or develop the Service, to train or evaluate artificial-intelligence models, or for research, unless You opt in. You can opt in only by (i) turning on a setting or accepting a dialog in the Service that describes the specific use, which is always off by default and can be turned off at any time, or (ii) creating a Data Share with Us that identifies the purpose. A Data Share with another user or a third party gives that recipient access to the data You select; it does not permit Us to use that data for any other purpose. The Service does not currently offer either way to opt in, so today We do not use Data Store Data for these purposes.
To run and improve the Service, We use Service Data instead: data about how the Service operates and is used, such as which features and integrations are used, request volumes, error rates and response times, and the number, size, type and timing of records. Service Data does not include the contents of Your Data Store, and We do not use it to reconstruct or infer those contents. If stored content appears incidentally in diagnostic records, it remains Data Store Data and these limits apply to it.
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies in this TermsFeed website article.
We use both Session and Persistent Cookies for the purposes set out below:
For more information about the cookies We use and Your choices regarding cookies, please visit the Tracking Technology and Cookies section of Our Privacy Policy.
We will only use Your Personal Data if We have a legal basis for doing so under applicable law, including but not limited to the legal bases set forth in this Privacy Policy.
The Company may use Personal Data for the following purposes:
We may share Your personal information in the following situations:
Two different kinds of data, two different rules.
Your context data (Data Store Data) — everything You or Your agents put into Fulcra, including calendar events, location history, health and fitness data, annotations, data tracks, contacts, reminders, and photos. This is never used for advertising, targeting, or profiling, by Us or by anyone else, in any circumstance. It is not sold. It is not shared for cross-context behavioural advertising. There is no opt-out to configure here, because there is nothing to opt out of. This is set out in full in “Personal Data That Will Not Be Shared or Sold Without Your Explicit Consent” below.
Account and website data — the identifiers and usage data created when You hold an account with Us or browse fulcradynamics.com. Like most companies, We use analytics and advertising tools against this data, and under California law some of that activity is classified as “sharing” for cross-context behavioural advertising. This is the only activity the opt-out below applies to, and it never touches Your context data.
| Purpose of processing | Data categories involved | GDPR / UK GDPR legal basis | CPRA basis¹ |
|---|---|---|---|
| Account creation and delivery of the core Service | Identifiers (name, e-mail, device ID), basic profile data | Contract – Art 6(1)(b) | Service Provider |
| Subscription billing & payments | Payment card details, billing address, transaction history | Contract – Art 6(1)(b) Legal obligation for tax & accounting – Art 6(1)(c) | Service Provider |
| Ingesting HealthKit, wearable, location or other health / biometric feeds you connect | Health, fitness, sleep, heart-rate, precise location | Explicit Consent – Art 9(2)(a) | Sensitive Personal Information (you may exercise the CPRA “Right to Limit”) |
| Basic analytics, Service optimisation, fraud-prevention & security logging | Usage logs, IP address, device data | Legitimate interests – Art 6(1)(f) (we balance these interests against your privacy rights) | Service Provider |
| Marketing e-mails & in-app offers | Identifiers, usage data | Consent (opt-in) or Legitimate interests (existing customers) | “Share” for cross-context behavioural ads (you may opt-out) |
| Compliance with legal duties (e.g., AML/KYC, sanctions screening) | Identifiers, transaction data | Legal obligation – Art 6(1)(c) | Service Provider |
¹ CPRA note: We do not “sell” personal information. The only row above that CPRA may classify as “sharing” for cross-context behavioural advertising is Marketing e-mails & in-app offers, and only for the identifiers and usage data named in that row. Your context data is never shared for advertising. You can opt out of the marketing-related sharing at any time — see “Do Not Sell My Personal Information” below.
“Service optimisation” in the table above uses usage logs and Service Data only. Any use of Data Store Data beyond providing the Service relies on Your opt-in consent (Art 6(1)(a) and, for health or biometric data, Art 9(2)(a)).
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located, including those locations maintained by Our service providers. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your use of the Service following notice of this Privacy Policy constitutes acknowledgment of our international data processing practices as described herein.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
When You delete Your context data, it is removed from Our live systems immediately and from Our backups within 30 days, after which it is unrecoverable. Deleting Your account deletes all of it.
One narrow exception, and nothing else: records We are legally required to keep, such as transaction records retained for tax and accounting purposes, which never include Your context data.
If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred to the successor entity. We will provide You notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
If we discover a data breach involving your Personal Data, we will notify you and the relevant supervisory authorities without undue delay and, where feasible, within 72 hours (GDPR) or in accordance with applicable U.S. state breach-notification laws.
We will not, under any circumstances, share with or sell to third parties the following types of personal information or Personal Data for any purpose other than providing Our Services without Your explicit consent:
The foregoing types of personal information and / or Personal Data will not, under any circumstances, be used for the purposes of marketing, advertising or use-based data mining, including by third parties, or any similar purpose, without Your explicit consent via an opt-in process. We do not use Data Store Data for targeted advertising, cross-context behavioral advertising or advertising profiling, and do not sell it or share it for those purposes, even if You opt in or create a Data Share.
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
If you transition from a free trial to a paid subscription or receive access via a business partner, we will continue to process billing and subscription data as described under ‘Performance of a Contract’. If a sponsoring organization ends its contract, your premium access ceases but your Personal Data remains yours and can be exported or deleted at any time.
We may process Personal Data under the following conditions:
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will respond to You within forty-five (45) days of receipt, with the option to extend by an additional forty-five (45) days when reasonably necessary, provided We notify You of such extension within the initial forty-five (45) day period.
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of Your habitual residence, place of work, or place of the alleged infringement if You believe Our processing of Your Personal Data violates applicable data protection law. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
Under CCPA, personal information does not include:
Certain features of the Fulcra Platform may collect or derive biometric information—for example, heart-rate variability, sleep-stage data, or other physiology-based metrics—when you connect wearables or health sensors.
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:
Please note that the examples provided above are illustrative and not intended to be exhaustive. Uses to monitor and improve Our Service rely on Service Data and Usage Data, not Data Store Data, unless You opt in as described in “How We Use Data Store Data.” For more details on how We use this information, please refer to the "Use of Your Personal Data" section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
As a matter of policy, and based on our obligations set forth in this Agreement, We do not and will not sell Your personal information and have not sold personal information in the preceding twelve (12) months or at any point in the past. We do not foresee any changes to this policy. In the event this policy changes in any way, We will update this Privacy Policy and provide You with notice and an opportunity to opt-out before any sale occurs.
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects Our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We do not sell personal information. Under no circumstances will We sell Your personal information without Your prior explicit consent.
We may share Your personal information identified in the above categories with the following categories of third parties:
If You initiate a “Data Share” via the Fulcra Platform, the data that You choose to share, which may be limited by category, time period, and/or duration of sharing, will be shared with those other Fulcra users with whom You choose to share that data, accessible via Context Web or via the LifeAPI. You may revoke consent and terminate any Data Share at any time through Your account settings, and We will cease sharing Your data as quickly as possible, and in any event within seventy-two (72) hours of Your revocation. Revoking and deleting are different actions. Revoking a Data Share stops further access as quickly as possible, and in any event within seventy-two (72) hours. Deleting the underlying data — or Your account — ends every Data Share covering it and removes that data from Our live systems immediately, so it is no longer accessible to anyone You shared it with. By creating a Data Share, You explicitly consent to the sharing of the data You designate for that Data Share with the Fulcra User(s) You indicate when creating that Data Share.
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that We link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
If You have reason to believe that a child under the age of 13 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:
Only You, or an authorized agent registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information. We may require the authorized agent to provide proof of their authorization and may also require You to verify Your identity directly with Us and confirm that You provided the authorized agent permission to submit the request.
Your request to Us must:
We cannot respond to Your request or provide You with the required information if We cannot:
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided We inform You of the extension within the first 45-day period and explain the reason for the extension.
For requests to know, any disclosures We provide will cover the 12-month period preceding the verifiable request's receipt, unless otherwise required or permitted by law.
For data portability requests, We will provide Your personal information in a portable and, to the extent technically feasible, readily usable format that allows You to transmit the information to another entity without hindrance.
As a matter of policy, We will assume that You have opted out of the sale of Your personal information unless You have explicitly opted in to the sale of Your personal information.
You have the right to opt-out of the sale of Your personal information, even if You have previously opted in to such sale.
Once We receive and confirm a verifiable consumer request from You, We will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
Our Service does not respond to Do Not Track signals. However, We honor opt-out preference signals in a frictionless manner as required by applicable law.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We will promptly take steps to delete that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Fulcra does not knowingly collect data from children under 13 and will delete it if discovered.
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If You'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
For material changes that affect Your rights under this Privacy Policy, We will provide You with notice via email (if You have provided an email address) and/or a prominent notice on Our Service at least 30 days prior to the change becoming effective, and We will update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If You have any questions about this Privacy Policy, You can contact Us:
Previous versions of this Privacy Policy are available upon request by contacting Us at support@fulcradynamics.com.
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