This Privacy Policy explains how Fulcrum Health Partners, LLC and its affiliates (“Fulcrum,” “we,” “us,” or “our”) collect, use, disclose, and protect personal information in connection with the website at fulcrumhp.com and related pages, communications, events, and online services (collectively, the “Site”). Fulcrum is a national healthcare reimbursement advisory and analytics firm serving providers, employers, health plans, private equity firms, and investment banks.
This policy addresses information collected through the Site and our marketing activities. Personal information and any protected health information handled in the course of a client engagement are governed by the applicable engagement agreement, business associate agreement, and confidentiality terms — not by this policy. See Section 3.
1.Introduction & Scope
This policy applies to personal information we collect from visitors to the Site, prospective and current clients, subscribers, event participants, job applicants, and other individuals who interact with us online. It does not apply to third-party websites we link to, or to information governed by a separate agreement.
By using the Site, you acknowledge this Privacy Policy. If you do not agree, please do not use the Site. This policy should be read together with our Terms of Use.
2.Information We Collect
We collect the categories of personal information below, depending on how you interact with us:
2.1 Information You Provide
- Identifiers & contact details: name, business or personal email, phone number, mailing address, employer, job title, and industry.
- Professional information: organization type (e.g., hospital, health system, physician group, health plan, employer, private equity firm, investment bank), professional credentials, and areas of interest.
- Inquiry & engagement content: messages submitted through contact, demo, RFP, media, speaking, or event forms; meeting requests; and survey responses.
- Recruiting information: resume/CV, cover letter, work history, education, references, LinkedIn profile, and other applicant details (see Section 17).
- Communications preferences: newsletter and marketing subscriptions and communication history.
- Future services: if we offer accounts, client portals, subscriptions, or paid tools, we may collect login credentials, authentication data, subscription details, billing and payment information (processed by a payment processor), and user-generated content.
2.2 Information Collected Automatically
- Device & usage data: IP address, browser type, operating system, device and cookie identifiers, referring pages, pages viewed, links clicked, and approximate location derived from IP address.
- Cookies & analytics identifiers: as described in Section 5.
3.Healthcare Data & HIPAA
The Site is a business-to-business marketing and information resource. It is not intended to collect Protected Health Information (PHI), patient records, claims data, or other individually identifiable health information, and you should not submit such information through Site forms.
In the course of consulting engagements, Fulcrum may receive provider-level reimbursement data, hospital or payer financial information, claims or benchmarking datasets, and, where applicable, PHI. When Fulcrum acts as a business associate under the Health Insurance Portability and Accountability Act (HIPAA), that information is handled under the applicable business associate agreement, engagement agreement, and confidentiality terms — and this Privacy Policy does not govern it. Where analytics incorporate health-related data, we use de-identified or aggregated information wherever practicable.
4.How We Collect Information
We collect personal information from the following sources:
- Directly from you when you complete a form, subscribe, register for an event, apply for a role, or communicate with us.
- Automatically through cookies, analytics, and similar technologies as you use the Site.
- From service providers such as our customer relationship management (CRM), marketing-automation, analytics, advertising, and event platforms.
- From third parties and public sources such as social media (e.g., LinkedIn), professional and business databases, referral partners, and publicly available information, consistent with applicable law.
- Through future integrations such as application programming interfaces (APIs) and AI-enabled tools, subject to appropriate safeguards.
6.How We Use Information
We use personal information to:
- operate, maintain, secure, and improve the Site;
- respond to inquiries, demo and RFP requests, and meeting or media requests;
- send newsletters, thought leadership, white papers, regulatory and payer-policy updates, and event invitations (subject to your preferences);
- evaluate and communicate with job applicants;
- analyze usage and produce aggregated analytics, benchmarks, and market intelligence (see Section 7);
- personalize content and measure and deliver advertising;
- establish, manage, and service client relationships and future accounts, portals, or subscriptions;
- detect, prevent, and respond to fraud, abuse, and security incidents; and
- comply with legal obligations and enforce our agreements.
7.Analytics & Market Intelligence
As an analytics-driven firm, we analyze Site interactions and usage to understand engagement and improve our content and services. We may aggregate or de-identify information and use it to generate benchmarks, research, and market intelligence, and we may publish insights derived from aggregated data.
We do not disclose your personal identity in published research or benchmarks unless you have authorized it or it is required by law. Once information is aggregated or de-identified such that it no longer reasonably identifies you, we may use and disclose it without further restriction, and we maintain such information in de-identified form.
8.Artificial Intelligence & Automation
We may use artificial intelligence and automation to support functions such as customer support, content creation, proposal support, analytics, research, predictive modeling, market intelligence, document review, and workflow automation.
Where AI systems process personal information, we apply safeguards designed to protect confidentiality and maintain meaningful human oversight of decisions that affect you. We do not permit the personal information you submit through the Site to be used to train publicly available, third-party AI models without appropriate contractual and technical safeguards, and we retain such information only as described in Section 13. We do not make decisions producing legal or similarly significant effects about you based solely on automated processing without a lawful basis and, where required, human review.
9.Marketing Communications
With your consent where required, we send marketing communications including newsletters, industry and regulatory alerts, CMS and payer-policy updates, and event invitations. You may opt out at any time by using the unsubscribe link in any email or by contacting us at legal@fulcrumhp.com. We may still send you non-marketing, transactional, or relationship messages, such as responses to inquiries.
11.“Sale” and “Sharing” of Personal Information
Fulcrum does not sell your personal information for money. However, because we use advertising and analytics technologies (such as Google Ads conversion measurement and Google Analytics 4) to measure campaigns and deliver relevant advertising, some of these activities may be considered a “sale” or “sharing” for cross-context behavioral advertising under the California Consumer Privacy Act (as amended) and similar state laws.
You have the right to opt out of this activity. You may do so by using the “Cookie Settings” link in the footer of every page, which serves as our “Your Privacy Choices” control, by declining non-essential cookies in our consent bar, or by enabling a recognized opt-out preference signal such as Global Privacy Control (GPC). We do not knowingly “sell” or “share” the personal information of individuals under 16 years of age.
12.Third-Party Services & Links
The Site may link to or integrate third-party websites and services, such as CMS, HHS, government resources, industry organizations, research publications, LinkedIn, and scheduling or event tools. We do not control and are not responsible for the privacy practices of third parties. Their handling of your information is governed by their own policies, which we encourage you to review.
13.Data Retention
We retain personal information only for as long as necessary to fulfill the purposes described in this policy, unless a longer period is required or permitted by law. Retention periods vary by context — for example, inquiry and CRM records, newsletter and marketing records, applicant data, proposal and engagement-inquiry information, analytics logs, cookie data, and future portal or subscription records may be retained for different periods based on operational, legal, and record-keeping needs. When information is no longer needed, we take reasonable steps to securely delete, destroy, or de-identify it.
14.Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information, which may include encryption in transit and at rest, access controls and role-based permissions, multi-factor authentication, audit logging, secure cloud hosting, vendor risk management, employee training, and incident-response and business-continuity procedures. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your interaction with us is no longer secure, please contact us at legal@fulcrumhp.com.
15.Your Privacy Rights
Depending on your state of residence and applicable law — including the California Consumer Privacy Act as amended by the CPRA, and the comprehensive privacy laws of Virginia, Colorado, Connecticut, Utah, and other states — you may have the right to:
- request access to, and information about, the personal information we process;
- request correction of inaccurate personal information;
- request deletion of your personal information;
- request a portable copy of your personal information;
- opt out of the “sale” or “sharing” of personal information and of targeted advertising (see Section 11);
- limit the use of sensitive personal information, where applicable;
- opt out of certain profiling; and
- appeal a decision we make about your request.
To exercise these rights, contact us at legal@fulcrumhp.com. We will verify your identity before responding and will not discriminate against you for exercising your rights. You may use an authorized agent to submit requests where the law permits. If we decline a request, you may appeal by replying to our response; if you have concerns, you may contact your state attorney general.
16.California Disclosures
This section provides additional detail for California residents. In the preceding 12 months, we have collected the categories of personal information below and disclosed them to service providers for business purposes; categories marked as “shared” may be used for cross-context behavioral advertising as described in Section 11.
| Category (CCPA) | Collected | Disclosed to providers | “Shared” for ads |
|---|---|---|---|
| Identifiers (name, email, IP, cookie IDs) | Yes | Yes | Yes |
| Customer records (phone, address) | Yes | Yes | No |
| Commercial / professional information (employer, title, industry) | Yes | Yes | No |
| Internet/network activity (usage, analytics) | Yes | Yes | Yes |
| Geolocation (approximate, from IP) | Yes | Yes | No |
| Professional/employment & education (applicants) | Yes | Yes | No |
| Inferences | Yes | Yes | No |
We do not intend to collect sensitive personal information through the Site beyond what is necessary, and we do not use or disclose sensitive personal information for purposes that require an opt-out right under California law. California’s “Shine the Light” law permits residents to request information about disclosures to third parties for their direct-marketing purposes; we do not make such disclosures. Requests may be sent to legal@fulcrumhp.com.
17.Careers & Applicant Privacy
If you apply for a position, we collect the information in your application, resume/CV, and related materials, and information from recruiting vendors, applicant-tracking systems, and, with your authorization, references and background-check providers. We use this information to evaluate your candidacy, communicate with you, and comply with employment and equal-opportunity obligations. We retain applicant information for the period necessary for recruiting and legal purposes.
18.Children’s Privacy
The Site is intended for a professional, business audience and is not directed to children. We do not knowingly collect personal information from anyone under 18 years of age. If you believe a child has provided us personal information, please contact us and we will take appropriate steps to delete it.
19.International Visitors
Fulcrum is based in the United States, and the Site is operated from the United States and intended for a U.S. audience. If you access the Site from outside the United States, you understand that your information will be processed in the United States, where data-protection laws may differ from those in your jurisdiction.
20.Business Transactions
If Fulcrum is involved in a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, personal information may be transferred as part of that transaction, subject to the commitments in this policy or a successor policy. We will use reasonable efforts to notify you where required by law.
21.Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date above and post the revised policy on the Site. Material changes will be highlighted as appropriate. Your continued use of the Site after changes take effect constitutes acceptance of the revised policy.
22.How to Contact Us
For questions about this Privacy Policy or to exercise your privacy rights, contact:
Fulcrum Health Partners, LLC
Attn: Privacy
Nashville, TN
Email: legal@fulcrumhp.com