Privacy Policy

Fulcrum Plan (“Fulcrum”) is operated by Fulcrum Solutions, Inc., a Delaware corporation (“we,” “us,” or “our”). This policy describes how we collect, use, disclose, and protect personal information when you visit fulcrumplan.com, create an account, link financial accounts, or otherwise use our services (collectively, the “Services”).

By using the Services, you also agree to our Terms of Service. If you do not agree with this policy, do not use the Services.

Information you provide.

• Account information: your name, email address, and sign-in credentials. If you sign in with Google or Apple, we receive the basic profile information they share, such as your name and email address. If you receive verification codes by text message, we also collect your phone number.
• Household and plan inputs: information you enter to configure your plan, such as income, corrections to account details (for example, a balance, interest rate, minimum payment, or loan term), goals, preferences, and notes.
• Communications: the content of messages you send us when you contact support or respond to our messages.

Information from the financial accounts you link. When you link an account through Plaid (see Linking your financial accounts), we receive:

• account details, such as the institution name, account name, account type, the last few digits of the account number, balances, and credit limits;
• loan and credit card details, such as interest rates, minimum payments, due dates, and loan terms;
• up to 24 months of transaction history, including dates, amounts, merchant names, categories, and, where your institution provides it, transaction location.

We never receive or store your online banking username or password.

Information we derive. From the information above, we derive analyses, reports, and plans, such as cash flow, debt payoff schedules, projections, and the optimized plan itself. We also derive estimates of your financial patterns (for example, how closely your spending aligns with a plan) and of how you engage with your plan.

Payment information. Payments are processed by Stripe. We do not receive or store your full card number. We receive your billing email address, a customer reference, your subscription status, and payment results.

Information collected automatically. When you use the Services, we collect technical information such as your IP address, browser type, device and operating system type, pages visited, referring page, approximate location derived from your IP address, and security and error logs. When you are signed in, we also collect information about how you use the Services, such as the pages and features you use, the actions you take (for example, what you select or click), and how long you spend on them, and we associate this information with your account.

We use personal information to:

• provide the Services, including organizing your finances and calculating your plan;
• keep your linked accounts up to date while they remain linked;
• create and secure your account, including verifying your identity when you sign in;
• process payments and manage your subscription;
• send you messages about your account, security, billing, report or connection expiration, and changes to the Services;
• respond to your requests and provide support;
• maintain, test, improve, and develop the Services, including the accuracy of our calculations, as described in Improving Fulcrum;
• understand how you use the Services and how you are following your plan, and tailor reminders, messages, and features to your progress;
• detect, prevent, and investigate security incidents, fraud, and abuse;
• comply with applicable law and enforce our Terms of Service.

Improving Fulcrum. We may use the information we collect, including your financial information, to operate, improve, and develop Fulcrum, including by building and training our own statistical and machine-learning models, as described in Model training and de-identified information. Where practical, we use de-identified or aggregated information for these purposes. We do not sell your information, and we do not permit others to use it to train their models.

We do not use your financial information for advertising, and we do not build advertising profiles about you.

We use Plaid Inc. (“Plaid”) to link your financial accounts. When you choose to link an account, Plaid’s secure window asks you to sign in to your financial institution and to authorize the connection. Plaid then provides us with the information described in Information we collect. Plaid’s handling of your information is governed by the Plaid End User Privacy Policy.

Before you link an account, we tell you what information we will request and why. We request only the information we need to calculate your plan. You may disconnect a linked account at any time in the Services. Once you do, we revoke our access through Plaid and receive no further information from that account. Information we have already received remains in your account until you delete it or delete your account.

We calculate your plan using our own optimization model. We use artificial intelligence (AI) language models to explain your plan and its results in plain language.

For each explanation, we send the AI provider only the financial values it requires, such as balances, interest rates, payment amounts, and the calculated payment schedule. Before sending, we remove your name, the names of your accounts and financial institutions, and your account numbers.

When we request an explanation of your plan from an AI provider, the provider processes the information solely to return that explanation to us. We select providers and configurations under which the provider agrees not to use the information we send to train its own models, and to retain it no longer than necessary to provide the service and meet its own safety and legal obligations. We rely on these contractual commitments; we do not operate the providers’ systems.

AI-generated text can be inaccurate or incomplete. Always verify it against the figures in your plan and your own records.

Training our models. We may build statistical and machine-learning models that learn from information across our customers to improve our estimates, calculations, and explanations. Where practical, we use de-identified information for this purpose. Some training may use pseudonymized information, which retains your exact financial values but removes your name, email address, account numbers, and other details that directly identify you. Pseudonymized information remains your personal information: we protect it accordingly and delete it when you request deletion of your information. However, a model trained before your request may continue to reflect that information, and we cannot guarantee its complete removal from such a model. If a service provider trains a model on our behalf, it may use the information solely for that purpose.

De-identified information. De-identified information is information that cannot reasonably be linked to you or your household. We take reasonable measures to maintain it in that form, and we commit not to attempt to re-identify it. Should we share de-identified information with a third party, we will contractually require that party to make the same commitments.

Fulcrum organizes your financial information and applies mathematical optimization to calculate a plan. The plan is the result of a calculation based on the information available to it. It is not financial, investment, tax, or legal advice; it does not recommend any security; and it may not be perfect. Any decision to act on it is yours, and we encourage you to verify it yourself or with a financial professional of your choice.

We do not use your information to make decisions that produce legal or similarly significant effects concerning you, such as decisions about credit, employment, housing, or insurance, and we do not provide your information to others for those purposes.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only as follows.

Service providers. Companies that operate parts of the Services on our behalf, under contracts that limit their use of your information to providing those services:

• Plaid, which links your financial accounts (privacy policy);
• Stripe, which processes payments (privacy policy);
• Clerk, which provides sign-in and account security (privacy policy);
• Amazon Web Services, which hosts our servers, databases, and email delivery (privacy notice);
• Vercel, which hosts our website and provides website analytics (privacy policy);
• AI model providers, which may include Anthropic and providers accessed through OpenRouter, which receive the limited information described in How we use artificial intelligence and, if a provider trains a model on our behalf, the training information described in Model training and de-identified information (Anthropic, OpenRouter);
• a product analytics provider, if we use one, which analyzes how signed-in users use the Services on our behalf, as described in Cookies, online tracking, and Do Not Track;
• Microsoft, which hosts our email, including support correspondence (privacy statement).

At your direction. When you direct us to share information, for example by linking an account or exporting your data.

Legal and safety. When we believe in good faith that disclosure is required by law, subpoena, or court order, or is necessary to protect the rights, property, or safety of you, us, or others, or to investigate fraud or security incidents.

Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. It would remain subject to this policy, and we will notify you before it becomes subject to a different policy.

Cookies and similar technologies. We use cookies set by Clerk that are necessary to keep you signed in and to secure your account. We also store a small number of display preferences in your browser’s local storage. If we use a product analytics provider, it may set cookies or similar technologies on our website, as described below. We do not use advertising cookies or similar advertising technologies.

Website analytics. We use Vercel Web Analytics and Speed Insights to understand how our website is used and how quickly it loads. Vercel states that Web Analytics does not use cookies and identifies visits with a hash that resets every 24 hours. We exclude or remove financial information and personal identifiers from the data these tools receive.

Product analytics. When you are signed in, we analyze how you use the Services, including the features you use, the actions you take, and the time you spend, and we link this information to your account. We use it to understand how you are following your plan, to tailor reminders and features to your progress, and to improve the Services. We may use a service provider for this analysis, which may use cookies or similar technologies on our website on our behalf. We do not use this information for advertising.

Other parties. We do not permit other parties to collect personal information about your online activities over time and across different websites while you use the Services.

Do Not Track and Global Privacy Control. Because we do not track you across other websites, or sell or share your information for advertising, we do not alter our practices in response to Do Not Track signals. If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of any sale or sharing of your personal information.

We maintain administrative, technical, and physical safeguards designed to protect your information, including:

• encryption of information in transit and at rest;
• additional encryption of the credentials we use to access your linked accounts through Plaid;
• multi-factor authentication for accounts;
• databases and servers maintained on private networks that are not directly reachable from the internet;
• access limited to the personnel and systems that require it;
• monitoring for security issues.

No method of transmission or storage is completely secure, and we cannot guarantee the security of your information. If a security incident affects your personal information, we will notify you and the appropriate authorities as required by law. To report a security concern, contact us using the details in Contact us.

• While your account is open, we retain your account information, linked-account information, inputs, plans, and the information we derive from them as needed to provide the Services.
• When you delete your account, we revoke our access to your linked accounts, cancel your subscription, and delete your personal information from our active systems within 30 days, as described in Deleting your information.
• Backups: copies in our encrypted database backups are removed as those backups expire, within 14 days after deletion from our active systems.
• Usage information: information about how you use the Services that is linked to your account is retained while your account is open and deleted with it, as described in Deleting your information.
• Logs: security and operational logs are retained for up to 90 days. We design them to exclude your financial information.
• Records we are required to retain: we retain payment and billing records for as long as tax, accounting, and other legal requirements require, along with a minimal record confirming that your deletion request was completed, which does not contain your financial information.
• Inactive accounts: if your account remains inactive for an extended period, we may disconnect your linked financial accounts and suspend access for security purposes. We do not delete your information because of inactivity alone. To have it deleted, submit a request as described in Your rights and choices.

Deleting your information. When you delete your account or request deletion of your information, we delete the information that identifies you or is linked to you within the timeframes described above. This includes your profile, your linked financial accounts, the financial data we received through Plaid, your plans, your usage information, and any pseudonymized copies used for model training. Before deletion, we may create de-identified versions of your plan results, reports, and usage information, which we retain. Deletion requests do not extend to de-identified information, including aggregated statistics that cannot reasonably be linked to you: because such information cannot be traced to you, we are unable to locate or remove it. For models trained before your request, see Model training and de-identified information.

Plaid, Stripe, and our other service providers retain information in accordance with their own legal obligations and privacy policies.

Wherever you reside in the United States, you may request that we:

• disclose the personal information we hold about you and how we use and share it;
• provide a copy of your personal information in a portable format;
• correct inaccurate personal information;
• delete your personal information and your account, subject to the limits described in Deleting your information.

You may disconnect linked accounts, export your data, and delete your account from your account settings, or submit a request by email to the address in Contact us. We will verify your identity before acting on a request, typically by asking you to submit it while signed in or from the email address associated with your account. An authorized agent may submit a request on your behalf with your written permission, which we will verify.

We will respond within 45 days and will inform you if we require additional time. If we decline a request, we will explain why, and you may appeal by replying to our decision. We will not discriminate against you for exercising your rights.

Emails. We send messages necessary for your account, security, and billing. Any promotional emails we send include an unsubscribe link; unsubscribing does not stop account-related messages.

Some state privacy laws, including California’s, require specific disclosures. During the past 12 months, and going forward:

• Categories we collect: identifiers (such as name, email address, phone number, and IP address); financial information (account, balance, liability, and transaction information); commercial information (subscription and payment records); internet activity (website usage and how you use the Services); approximate geolocation derived from IP address or transaction data; and inferences (the analyses, plans, and estimates of your financial patterns and plan engagement that we derive).
• Sources: you; the financial institutions you link, through Plaid; Stripe; Google or Apple, if you use them to sign in; and your use of the Services.
• Purposes: the uses described in How we use information.
• Disclosures: each category may be disclosed for business purposes to the service providers listed in How we share information.
• No sale or sharing: we have not sold or shared personal information, including that of consumers under 16, for cross-context behavioral advertising.
• Sensitive personal information: we use financial account information and account sign-in information to provide the Services and to improve and develop them as described in Improving Fulcrum.

We extend the rights in Your rights and choices to all users, whether or not a particular state’s law applies to us.

The Services are intended only for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe that someone under 18 has provided us with personal information, contact us and we will delete it.

The Services are intended for residents of the United States. We operate from, and store and process information in, the United States.

We may update this policy from time to time. When we do, we will revise the effective date above. If a change is material, such as a new use of your financial information or a new category of recipient, we will notify you by email and through a notice in the Services before the change takes effect.

For questions, requests, or security concerns, contact:

Fulcrum Solutions, Inc.
2810 N Church St, PMB 833693
Wilmington, DE 19802-4447
United States
privacy@fulcrumplan.com