Effective 17 September 2026. Fulcrum handles personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and with comparable duties where we operate.
1. Who we are
This policy applies to fulcrumcortex.com, Stripe checkout for Cortex plans, and the Cortex product (agents, Sessions orchestration, channels, hosting, human-in-the-loop). “Fulcrum”, “we”, “us” means the Australian company that provides Cortex. Contact: privacy@fulcrumcortex.com.
2. What we collect
Depending on how you use Cortex, we may collect:
- Account and billing — name, email, phone, company, plan, invoices. Card numbers are collected by Stripe, not stored in full on Cortex.
- Workspace content — prompts, files, CRM records, call notes, SMS, campaign copy, code, and other Input you or your agents put through the layer, plus Output we generate for you.
- Channel data — identifiers and messages from Telegram, Discord, WhatsApp, Slack or email when you connect those channels.
- Voice and messaging metadata — numbers, timestamps, duration, delivery status, and recordings or transcripts where the product records them.
- Site and product telemetry — IP address, device, pages, approximate location, crash and performance logs. We use this to keep the product up, not to build an advertising profile.
- Support — what you send our humans when you buy human-in-the-loop hours.
If you do not want to provide something we need to run a paid workspace, we may not be able to provide it.
3. How we use it
We use personal information to:
- Provide, host, secure, and improve Cortex, including routing work to the right agent.
- Bill you, collect GST, prevent fraud, and recover unpaid invoices.
- Fulfil human-in-the-loop work you have purchased.
- Comply with law, enforce the Terms, and protect people from abuse.
- Send service messages (renewals, outages, security). Marketing email is opt-in or as the Spam Act allows.
We do not sell personal information. We do not use your workspace Content to train foundation models for other customers. We may use de-identified, aggregated operational metrics (for example, error rates) to keep the layer reliable.
4. Automated processing
Cortex is an AI execution layer. Models will read Input in order to produce Output and take actions you have configured (send a message, update a deal, book a table, write code). That is the product, not a hidden secondary purpose. Outputs can be wrong. Humans in your team — and, if you buy it, our human-in-the-loop — should review anything that matters. See the Terms for reliance rules.
5. Who we share with
We share personal information only as needed to run Cortex:
- Stripe — payment processing, tax, invoices, fraud checks. Their terms and privacy policy apply to the checkout session.
- Infrastructure and channels — hosting, DNS, SMS and voice carriers, Telegram, Discord, WhatsApp, Slack, email. Each is a separate controller or processor for their network.
- Our people and contractors — under confidentiality, when you have purchased human support or when we must debug an incident.
- Law — if a court, regulator, or Australian law requires it, or to protect rights and safety.
Some processors are overseas (for example Stripe in the United States). We take reasonable steps so they handle information consistently with the APPs, including contractual clauses where appropriate.
6. Retention and security
We keep account and billing records for as long as the workspace exists and then for a period required for tax and dispute purposes (typically seven years for financial records in Australia). Workspace Content is kept while the subscription is active and for a short wind-down after cancellation unless you ask us to delete sooner and the law lets us. We use access control, encryption in transit, and least-privilege operations. No method is perfect; tell us at privacy@fulcrumcortex.com if you think something leaked.
7. Your rights
You may request access to, correction of, or deletion of personal information we hold, and you may complain about how we have handled it. Email privacy@fulcrumcortex.com. We will respond within a reasonable time. If you are not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC). Organisations you represent remain responsible for their own privacy notices to their customers (the people Cortex may call or message on your behalf).
8. Cookies and this website
The marketing site uses cookies or similar storage that are needed for the site to work (session, load balancing, security). We do not run a third-party advertising network on fulcrumcortex.com. Analytics, if enabled, is for understanding which pages help people subscribe — not for selling audiences.
9. Children
Cortex is a business product. It is not directed at children under 18. Do not submit their data to us.
10. Changes
We may update this policy. The effective date at the top will change. Material adverse changes will be notified with the same care as Terms changes. Continued use after the effective date means you acknowledge the update.