1.1    We are committed to safeguarding the privacy of our website visitors, service users and suppliers.

1.2    This notice applies where we are acting as a data controller with respect to the personal data of our website visitors, service users and suppliers; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    If you are a research respondent, please refer to our Respondent Privacy Notice for relevant information regarding our processing of your data.

1.4    If you choose to visit our website, you should be aware that we use cookies on the site. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website: https://www.fulcrumresearchgroup.com

1.5    In this notice, “we”, “us” and “our” refer to Fulcrum Research Group LLC. For more information about us, see Section 12.

1.6    This notice was last updated on July 7, 2022.

2.1    In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing (if applicable).
2.2    We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, demographic information, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. If you are based in the European Union, the legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

Sections 2.3 through 2.7 apply to our US based service users:
2.3    We may process your account data (“account data”). The account data may include your name, job title or role, employer and your contact details, including but not limited to, your business mailing address, telephone numbers and your business email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

2.4    We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include details related to specific research project engagements. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, ensuring the security of our services, maintaining back-ups of our databases and communicating with you.
2.5    We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details including but not limited to, your business mailing address, telephone numbers, business email address and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
2.6    We may process information relating to transactions, including purchases of products and services, that you enter into with us (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
2.7    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
Section 2.8 applies to our suppliers:
2.8    If you engage with us as a supplier or contractor, we may process your information included in your supplier account (“supplier data”). The supplier data may include your name, job title, company name, address, telephone numbers, email address and banking details. The supplier data may be processed for the purposes of engaging your services to assist with our research projects. If you are based in the European Union, the legal basis for this processing is your consent or the performance of a contract between you and us and/or taking steps to enter into such a contract.

Additional uses:
2.9    We may process information contained in any inquiry you submit to us regarding products and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you, or employment applications that you submit via the “Careers” inquiry form on our site. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.10    We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. If you are based in the European Union, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. If you are based in the European Union, the legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. If you are based in the European Union, the legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.13    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.14    Please do not supply any other person’s personal data to us, unless we prompt you to do so. If you do supply any other person’s personal data to us at our prompting, please do not do so unless you have obtained their explicit consent to do so for the purposes set forth in this Privacy Notice, and please provide us written evidence of such consent.

3.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2    We may disclose your personal data to or professional advisers insofar as reasonably necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3    If you are a service user, we may disclose your personal data including your name, job title or role, employer and your contact details, including but not limited to, your business mailing address, telephone numbers and your business email address to our suppliers insofar as reasonably necessary for the execution of specific research project engagements we are conducting on your behalf.
3.4    Financial transactions relating to our suppliers are handled by our payment services provider, Bill.com. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about Bill.com’s privacy policies and practices at https://www.bill.com/privacy/.
3.5    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.6    We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, or restructuring of all or part of our business operations, bankruptcy, or similar event, including in negotiations, due diligence, and integrations related to such transactions.

4.1    In this Section 4, we provide information about the circumstances in which your personal data may be transmitted or transferred to countries outside the European Economic Area (EEA).
4.2    We have offices and facilities in the United States. When you transmit personal data directly to us, your data will be protected by appropriate technical and organizational measures.
4.3    The hosting facilities for our website are situated in the United States. Transfers to this country will be protected by appropriate safeguards.
4.4    Our research suppliers who assist us with our global research projects may be situated outside of your home country, and may transfer your data to us or to our third-party service providers in the United States and other countries.
4.5    Regarding transfers of personal data from the European Union between us and a third party, the parties shall assure adequate protection for the personal data using one of the following: (i) EU Standard Contractual Clauses; (ii) Binding Corporate Rules or (iii) your explicit consent.

5.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3    We will retain your personal data as is outlined in our Data Retention Policy, a copy of which can be requested by contacting privacy@fulcrumresearchgroup.com.
5.4    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.1    We may update this notice from time to time by publishing a new version on our website.
6.2    You should check this page occasionally to ensure you are happy with any changes to this notice.
6.3    We may notify you of changes to this notice via an announcement on our website.

7.1    In this Section 7, we have summarized the rights that EU persons have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2    Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10    To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11    If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12    To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13    You may exercise any of your rights in relation to your personal data by written notice, via email or via phone as per the contact details noted in Section 12.

8.1    Although Fulcrum Research Group LLC may not be subject to the thresholds set forth in the California Consumer Privacy Act (CCPA), we nonetheless endeavor to provide California residents with the rights set forth in the CCPA. This Section 8 describes the applicable notices as set forth in the CCPA.
8.2    Information we collect: We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (as used in this Section 8, “personal information”). Personal information does not include (a) publicly available information from government records, or (b) deidentified or aggregated consumer information. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

8.3    Use of Personal Information: We may use the personal information we collect for the purposes set forth in Section 2 and may disclose the personal information as set forth in Section 3.
8.4    Sharing of Personal Information: We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has or may have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below:

8.5    Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Section 8.7), we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

1. Sales, identifying the personal information categories that each category of recipient purchased; and
   o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
2. The specific pieces of personal information we collected about you (also called a data portability request).
   We do not provide a right to know or data portability disclosure for B2B personal information.

8.6    Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Section 8.7), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. We do not provide these deletion rights for B2B personal information.
8.7    Exercising Your Rights to Know or Delete: To exercise your rights to know or delete described above, please submit a request by contacting us using one of the methods set forth in Section 9.3. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
8.8    Response Timing and Format: We will confirm receipt of your request within 10 business days. We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
8.9    Personal Information Sales Opt-Out and Opt-in Rights: If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing: privacy@fulcrumresearchgroup.com with the subject [“Do Not Sell My Personal Information”]. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us as set forth in Section 9.3. We will only use personal information provided in an opt-out request to review and comply with the request.
8.10    Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.1    We use cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website, as you navigate our website and to help us to determine if you are logged into our website. Cookies used for this purpose are: Z, _gid, _gat,AMP_TOKEN,_gac_<property-id>, _utma, _utmt, _umtb, _utmz, _utmv
(b) optimize browser configuration – in addition to third-party cookies, we use our own cookies to optimize the website for your browser configuration. Cookies used for this purpose are: has.js.
(c) analysis – we use cookies to help us to analyze the use and performance of our website and services. Cookies used for this purpose are: gtag.js and analytics.js

• (i) We also use a third party software performance analytics software, New Relic, that monitors our website and delivers real-time and trending data about our website’s performance. This includes downtime, server resource usage, bandwidth, page load times, and other important performance data. The script does not collect personal data. Cookies used for this purpose are: JSESSIONID, NREUM, NRAGENT, TSNGUID, ajs_user_id, ajs_group_id, ajs_anonymous_id, intercom_id-<id>.

11.1    We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: gtag.js and analytics.js.

12.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac and https://support.apple.com/en-us/HT201265  (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2    Blocking all cookies will have a negative impact upon the usability of many websites.

12.3    If you block cookies, you will not be able to use all the features on our website.

13.1    This website is owned and operated by Fulcrum Research Group LLC.

13.2    Our principal place of business is at 200 West Street, 2nd Floor,  Waltham, MA  02451, United States.

13.3    You can contact us:

(a)  by mail, to the postal address given above;

(b)  by telephone, at (781) 209-5327;

(c)  by email, using privacy@fulcrumresearchgroup.com.