Privacy Policy

FULCRUM TECHNOLOGIES PTE. LTD.

FULCRUM TECHNOLOGIES PTE. LTD. is a company registered in Singapore.

fulcrum, together with the other members of its group ("we/us/our"), are committed to safeguarding the privacy of third parties with whom we interact, including our clients, third parties who visit our websites (including our online content portal) ("websites") and/or to who we provide services to or otherwise engage with ("you/your").

This Privacy Policy sets out our personal information collection and sharing practices for our websites and through the other channels described below. If you use our websites or provide your information to us (either via this website, in person, over the phone or by email (or by other means of electronic communication)), you agree to the processing set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your personal information, together with the ability to opt in or out of selected uses may also be provided to you when we collect personal information from you.

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the applicable Data Protection Legislation. We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it.

By using or accessing our websites or the services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy.

This Privacy Policy is intended to explain our privacy practices and covers the following areas:

(a) What personal information about you we may collect

(b) How we may use your personal information

(d) How we protect your personal information

(e) Contacting us and your rights to prevent marketing and to access and update your personal information

(f) Our Cookies Policy

(g) Your right to make a complaint

(h) How changes to this Privacy Policy will be made

2. Information We May Collect About You

Generally

2.1 We may collect personal information about you from the following sources:

(a) Our correspondence: if you contact us by post, telephone, live chat, email or other electronic means we may keep a record of that correspondence;

(b) Information you provide to us: personal information that you provide to us, such as during the registration process to access and use the websites or otherwise interact with us, including your name, title, position, contact details, username or similar identifier;

(c) Your transactions: details of transactions you carry out through our websites or through other channels and of the fulfilment of the services we provide;

(d) Website and communication usage: details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access; and

(e) Survey information: we may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey.

2.2 We may also collect the following personal data:

(a) Profile data including your username and password, reservations made by you, your interests, preferences, feedback and survey responses;

(b) Usage data including information about how you use our website and services;

(c) Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences;

(d) Cookies Data — we use "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the Cookies section below for information about cookies and how we use them; and

(e) Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the websites, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our websites and internet usage.

Experts

2.3 fulcrum is a primary research company and part of our business activities involve the identification of industry experts ("Experts") and the introduction of them to our clients, for the purposes of consultations and other interactions and the publishing of transcripts and recordings of interviews on our content portal ("Engagements"), to assist our clients in making informed business decisions.

We may collect and process the following personal information about you if you are an Expert:

(a) Information we may collect on you: we may collect information about you which may include your name and your academic and professional background and employment history, including the identities of your current and former employers and job titles/positions, from publicly available sources such as information that can be found using search engines, on corporate websites and information which you have clearly decided to make public (such as information you have made available on business networking platforms and social media); and

(b) Information you provide to us: personal information that you provide to us including your name, address, telephone numbers, email address(es) and other contact details, detailed information in respect of your academic and professional background and employment history (and other information typically contained in a detailed CV/resume).

If you participate in an Engagement through us, we may request your bank account details to be able to make payment to you. We may also be required to perform a background check on you in accordance with our compliance policies. You consent to us performing such checks in order for us to adhere to industry best practices, to ensure that your identity and financial data is a match in order to prevent fraud, to check that you are not on a sanctions, regulatory or law enforcement list, or have a criminal record and that you pass negative media screening.

Clients and Prospective Clients

2.4 If you are a client (or a prospective client), in addition to the information referred to in paragraph 2.1, we may collect personal information on you in the ordinary course of our business relationship with you i.e. the provision of our services to you.

2.5 If you are a Client accessing our content portal, we use third party analytics software to evaluate your use of the content portal, compile reports on activity, analyse performance metrics, and collect and evaluate other information relating to Client user usage.

3. Uses Made of Your Personal Information

We may use your personal information in the following ways. For each use, we note the grounds we use to justify each use of your personal information.

3.1 Generally

(a) For research and development purposes: to analyse it in order to better understand your and our clients' service requirements, to better understand our business and develop our products and services. Use justification: legitimate interests (to allow us to improve our services).

(b) To record and monitor certain activities: to record and monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud. Use justifications: legal obligations, legal claims, legitimate interests (to ensure the quality and legality of our services).

(c) To inform you of changes: to notify you about changes to our services and products. Use justification: contract performance.

(d) To ensure website content is relevant: to ensure that content from our websites is presented in the most effective manner for you and for your device. Use justification: consent, contract performance, legitimate interests.

(e) To reorganise or make changes to our business: in the event that we are subject to negotiations for the sale of our business or part thereof, sold to a third party, or undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party as part of any due diligence process. Use justification: contract performance, legal obligations.

(f) In connection with legal or regulatory obligations: we may process your personal information to comply with our regulatory requirements or dialogue with regulators as applicable. Use justification: legal obligations, legal claims, legitimate interests.

3.2 Experts

If you are an Expert:

(a) To provide our services effectively to our clients: we gather the personal information described above in order to be able to identify Experts and to introduce them to our clients. We use and analyse the information which we collect about you in order to identify Engagements which may be within your field of expertise and of interest to you. We may disclose biographical information about you to clients who may wish to consult with you. We may summarise your biographical information using artificial intelligence, but such summaries shall not be shared with our clients or any other third party without your consent. Use justification: consent; legitimate interests.

(b) To ensure that you are paid: to ensure that you are paid for the services which you have provided. Use justification: contract performance, legal claims, legitimate interests.

3.3 Clients and Prospective Clients

If you are a Client or a prospective client:

(a) To provide our services effectively to you and conduct our business: to administer our services, including to carry out our obligations arising from any agreements entered into between you and us, and to prevent any unauthorised access. Use justification: consent, contract performance, legitimate interests.

(b) To ensure that we are paid: to recover any payments due to us and where necessary to enforce such recovery. Use justification: contract performance, legal claims, legitimate interests.

3.4 Marketing

To provide you with updates, where you have chosen to receive these. We may also use your information for marketing our products and services to you by post, email, phone (including text) and other electronic means and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us. Use justification: consent, legitimate interests.

4. Transmission, Storage and Security of Your Personal Information

Data security is of great importance to us, and to protect your data we have put in place suitable procedures to safeguard and secure data collected through our websites. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

4.1 No data transmission over the internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable measures to protect your personal information.

4.2 All information you provide to us is stored on our or our subcontractors' secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

4.3 Any payments made by you will be encrypted.

Storage Limits

4.4 We will retain your personal information for as long as is necessary for the processing purpose(s) for which they were collected and any other permitted linked purpose. We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either anonymised (and the anonymised information may be retained) or securely destroyed.

5. Disclosure of Information

5.1 We are allowed to disclose your information in the following cases:

5.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer;

5.1.2 We can disclose it to other businesses in our group;

5.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights;

5.1.4 We can exchange information with others to protect against fraud, money laundering, bribery, insider trading or credit risks.

5.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, background checks, advertising and marketing. In some cases, the third parties may require access to some or all of your personal information that we hold.

5.3 If you are an Expert, by registering and agreeing to this Privacy Policy, you consent to fulcrum sharing your employment history and details of your current occupation/role with our clients in relation to proposed Engagements. Should you agree to participate in a consultation with a client, you consent to us sharing your name and contact details with that client for the purposes of your participation in that consultation.

5.4 Where any of your data is required to be shared with a third party, we will take reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under Data Protection Legislation.

6. Your Rights and Contacting Us

Marketing

6.1 You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us as set out in paragraph 6.5 below.

Your Rights

6.2 Under Data Privacy Legislation, under certain conditions, you may have the right to require us to:

(a) provide you with further details on the way we use your personal information;

(b) provide you with a copy of personal information that you have provided to us;

(d) delete any personal information that we no longer have a lawful ground to use;

(e) where processing is based on consent, to withdraw your consent so that we stop that particular processing;

(f) object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;

(g) restrict how we use your information whilst a complaint is being investigated; and

(h) deactivate your account.

6.3 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

Updating Information

6.4 We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by contacting us as set out in paragraph 6.5 below.

Contacting Us

6.5 If you have any questions in relation to this policy, please contact us.

7. Cookies Policy

7.1 We use cookies to help us understand user behaviour. The cookies are stored on a user's web browser and they let us know a user's activities on our website. We analyse users' behaviour in order to better serve the users and to make improvements to our website.

7.2 We do not collect any personally identifiable information from the user unless the information is explicitly provided to us by the user through submission forms on our website. We do not sell any personally identifiable information to any third parties. We use Google Analytics to keep track of our website traffic, which may use cookies for this purpose.

8. Your Right to Make a Complaint

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

8a. Browser Extension

Data handling practices specific to the Fulcrum AM Tools Chrome extension are described in a dedicated extension privacy policy. That page covers what the extension reads, what it transmits to the Fulcrum backend, and what it stores locally on the user's device.

9. Changes to Our Privacy Policy

We may change the content of our websites and how we use cookies without notice, and consequently our Privacy Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website from time to time to stay informed of how we are using personal information.

10. Your Agreement

By using our websites and by way of acknowledgment, you agree to our Privacy Policy.

11. Dispute Resolution

11.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

11.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.

11.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Singapore and the courts of Singapore are the only place where disputes or claims relating to or connected with this Privacy Policy may be decided.

This Privacy Policy was last updated in March 2026.