Effective: November 4, 2019


Fulcrum Equity Partners (“Fulcrum,” “we,” or “us”) values your privacy. Fulcrum is an Atlanta-based growth equity firm focused on providing expansion capital to rapidly growing companies.

In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information about users of our website, https://www.fulcrumep.com and the investor portal powered by Alta Return (“Investor Portal”), (collectively, the “Sites”) and the products or services available through our Sites (collectively, the “Services”).

By visiting the Sites or using any of our Services, you agree that your information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy.

Collection of Information
Use of Information
Disclosure of Information
Cookies and Other Tracking Mechanisms
Third-Party Sites and Services
Security
Your Choices
Children
Changes to this Policy
Contact Us

Collection of Information

We collect information directly from you, from other sources, and by automated means as set out below. The type of information that we collect from you depends on your particular interaction with our Services, but generally includes the below information.

Registration. For investors and potential investors, you may be invited via email to register to access our Investor Portal; in order to register, we collect your name, email address and password.  In addition, if you subscribe to receive emails from us, we collect your name and email address, and may also collect additional information about your preferences and current role, so that we can send you news, newsletters and other information we think may interest you.

Investments and Activities. The Services allow our investors and potential investors to invest in Fulcrum funds which, in turn, make process driven equity investments in smaller growth companies located primarily east of the Rocky Mountains. When you submit information about potential new investment opportunities to us, we collect information such as information about the company, contact person, and key managers. We may collect information about your activities, such as active investments and materials downloaded from our Investor Portal. We also maintain records of customer service and other communications with investors and potential investors, as well as any information you otherwise submit to us via the Services.

Usage Data. We automatically collect information about your use of our Sites and our Services through cookies, local storage, analytics tools and other technologies, such as your log files, IP address, device ID, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services and perform certain activities; device name and model; operating system type, name, and version; the length of time that you are logged into or using our Services, and the links you click and your other activities within the Services (“Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Use of Information

We use your information, including personal information, as set forth below:

Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; and for other customer service and support purposes.

Marketing and Communications. To communicate with you about your account and use of our Services via email, including to send you updates and investment opportunities; to respond to your inquiries; to provide you with news and newsletters and other information we think may interest you, and for other informational purposes. Please see the Your Choices section for more information about how to change your communications preferences.

Research and Analytics. To better understand how users access and use our Services, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.

Protecting Rights and Interests. To protect the safety, rights, property, or security of Fulcrum Equity Partners, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or our Terms of Use.

Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

General Business Operations. Where necessary for the administration of our general business, accounting, recordkeeping and legal functions. As part of our routine business administration, such as employee training, compliance auditing and similar internal activities.

Disclosure of Information

In general, we may share your information, including personal information, as follows:

Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.

Service Providers. We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf.

Business Transfers. We may disclose your information to another entity in connection with an investment, acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.

Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of Fulcrum Equity Partners, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity which we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or Terms of Use.

Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.

Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies, pixels, java script, and other tracking mechanisms to track information about your use of our Sites. We or our third-party service providers may combine this information with other information, including personal information, we collect from you.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Sites. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Sites.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Sites, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Sites to, among other things, track the activities of visitors of Sites, help us manage content, and compile statistics about Sites usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Analytics Performed by Service Providers. We may use non-affiliated analytics companies, for example Google Analytics (see privacy policy and opt-out), to evaluate use of our Sites. We use these tools to help us understand use of, and to improve, our Sites, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Third-Party Sites and Services

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-parties websites.

Security

We have implemented precautions to protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

Your Choices

We may send newsletters and other emails to you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at IR@Fulcrumep.com. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Children

Our Sites and Services are not designed for children under 13 and we do not intentionally collect information on our Sites and Services from those we actually know are under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as via email or prominent notice on the Sites.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at IR@Fulcrumep.com.

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