Privacy Policy

1. Who processes your data

The data controller is Fulcrum, Registration Code 306318621, Italy. For any request about your data please use the Contact page of this site: that is the channel we monitor.

We have not appointed a Data Protection Officer. If we appoint one, the contact details will be published here.

2. What data we collect

Only if you consent to measurement cookies, we use Google Analytics 4 to understand how people use the site (pages visited, referral source, device): this is aggregated data and Google applies IP masking.

We do not collect special categories of data and we do not ask for anything we don't need to reply. The message field is free text: don't put confidential data or other people's personal data in it.

• Contact form: full name, company, work email, company size, area of interest, message
• Call booking: name, email and chosen slot, collected by the zcal calendar service
• Site usage statistics via Google Analytics 4, only if you consent to measurement cookies
• Infrastructure technical logs: data needed to serve the pages and protect the site from abuse

3. Why we process it and on which legal basis

Marketing consent is separate from sending the form: you get an answer without it.

• Reply to your request and set up the call — legal basis: pre-contractual steps at your request (Art. 6.1.b GDPR)
• Send updates on AI agents and use cases — legal basis: your consent, optional and revocable (Art. 6.1.a GDPR)
• Keep the site secure and working, with logs and anti-spam protection — legal basis: our legitimate interest (Art. 6.1.f GDPR)

4. How long we keep it

When the period ends we delete the data or make it anonymous, unless the law or the defence of a legal claim requires otherwise.

• Form requests and bookings: 24 months from the last contact
• Marketing consent: until you withdraw it
• Infrastructure technical logs: according to the retention period of the hosting provider

5. Who processes it for us

Your data stays ours: we don't sell it and we don't share it for third-party purposes. It is processed on our behalf by the providers that run the site, appointed as data processors.

• Hosting and site infrastructure provider
• zcal — calendar and booking management
• Google Ireland Limited — Google Analytics 4, only with your consent to measurement cookies
• Email provider and transactional email service

Fulcrum staff authorised to answer requests can access the data, as can public authorities where the law requires it.

6. Transfers outside the European Union

Some providers are based or hosted also in the United States. Transfers rely on the European Commission's Standard Contractual Clauses or on the provider's participation in the EU-US Data Privacy Framework. On request we tell you which safeguard applies to each service.

7. Cookies and third-party content

The site uses cookies and technical storage needed to work. With your consent, we also load Google Analytics 4 for usage statistics and the zcal calendar on the Contact page. The full list and how to change your choice are in the Cookie Policy.

8. Your rights

To exercise a right, use the Contact page of this site. We reply within one month; if the request is complex we tell you and explain why.

• Access: know which data we hold and get a copy
• Rectification: correct wrong or incomplete data
• Erasure: ask for your data to be deleted
• Restriction and objection: ask us to pause or stop a processing activity
• Portability: receive your data in a machine-readable format
• Withdrawal of consent: at any time, without affecting what was done before

9. Complaint to the supervisory authority

If you believe the processing of your data breaches the GDPR, you can lodge a complaint with the Italian data protection authority (Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, www.garanteprivacy.it) or with the supervisory authority of your country. You can also go to court.

10. Changes to this page

If we change tools or purposes we update this page and the date at the top. Significant changes are announced on the homepage or by email to people who gave marketing consent.