Privacy Policy

EFFECTIVE DATE: October 15, 2026

About this policy

Pivot Point Holdings Inc. & Fulcrum Construction (“Fulcrum Construction,” “we,” “us,” or “our”) wrote this Privacy Policy to explain what personal information we collect online through fulcrumconstruction.com (the “Site”) and offline, such as by email and phone, how we use it, who receives it, and the choices you have. We designed this Privacy Policy to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

It covers Site visitors, people who contact us through our forms, subcontractors who submit inquiries, and job applicants. It applies to all five Fulcrum Construction offices: Atlanta, Los Angeles, San Antonio, Portland, and Philadelphia. The policy has three parts: Website Visitors and Inquiries, Job Applicants, and Security, Your Rights, and Contact. The last part applies to everyone.

Personal information means information that identifies, relates to, or could reasonably be linked to you. Personal information does not include:

• Publicly available information, including information from government records, widely distributed media, or information a person made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated information.
• Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) or the California Confidentiality of Medical Information Act (CMIA), and personal information covered by the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), or the Driver’s Privacy Protection Act.

Website visitors and inquiries

Information we collect

We collect the information you give us and the technical information your browser sends when you visit the Site. In the last 12 months, we have collected the following categories:

Category	Examples	Collected	Purpose	Retention	Disclosed to
A. Identifiers	Name, email address, phone number, IP address, device and browser identifiers	Yes	Respond to and communicate with you; send information about our services; operate and secure the Site; comply with the law and prevent fraud	2 years	Website hosting, security, and IT vendors; form and email service providers
B. California Customer Records	Name, phone number, company name, job title	Yes	Respond to and communicate with you; manage business relationships; send information about our services	2 years	Form and email service providers; the Fulcrum Construction office that handles your inquiry
C. Protected classifications	Age, race, sex, disability, veteran status, and other characteristics protected by law	Not requested	Respond to your message only	2 years	The Fulcrum Construction office that handles your inquiry
D. Commercial information	Project market, state, city, name or location, and timeline	Yes	Respond to project inquiries; manage business relationships	2 years	Form and email service providers; the Fulcrum Construction office that handles your inquiry
E. Biometric information	Fingerprints, faceprints, voiceprints, and similar identifiers	No	Not applicable	Not applicable	Not applicable
F. Internet or other network activity	Pages viewed, links clicked, referring page, browser type, operating system, date and time of visit, and the content of messages you send us through the Site	Yes	Operate, secure, and improve the Site; respond to your message	2 years	Analytics providers; hosting and security vendors; form and email service providers; the Fulcrum Construction office that handles your inquiry
G. Geolocation data	City or region inferred from your IP address	Yes	Understand how visitors use the Site	2 years	Analytics providers
H. Sensory data	Audio, visual, or similar information, such as call recordings	No	Not applicable	Not applicable	Not applicable
I. Professional or employment-related information	Trades, licensing details, primary service area, travel capability, year founded, annual revenue, number of employees, the Fulcrum Construction office and contact you work with, area of interest, and preferred office	Yes	Review subcontractor inquiries; route your inquiry; manage business relationships	2 years	Form and email service providers; the Fulcrum Construction office that handles your inquiry
J. Non-public education information	Education records maintained by a school	Not requested	Respond to your message only	2 years	The Fulcrum Construction office that handles your inquiry
K. Inferences	Conclusions drawn from information you submit, such as an assessment of a subcontractor’s qualifications	Yes	Review subcontractor inquiries and prequalification requests	2 years	The Fulcrum Construction office that handles your inquiry
L. Sensitive personal information	See the Sensitive Personal Information chart below	Not requested	Respond to your message only	2 years	The Fulcrum Construction office that handles your inquiry

We collect this information from the following sources:

• Directly from you, when you submit the Contact form, send a subcontractor inquiry, or email or call us.
• Indirectly from you, through your browser and device when you browse the Site.
• From our service providers, such as analytics providers.

Job applications follow a separate process described in the Job Applicants section below.

The Site does not ask for sensitive personal information. Please leave Social Security numbers, financial account numbers, and health information out of any message you send through the Site. If you include information we did not ask for, including sensitive personal information, we use it only to respond to your message, we do not use it to infer characteristics about you, and we keep it with your message for the same 2-year period.

Sensitive personal information

California law treats certain categories of personal information as sensitive personal information when a business collects or uses them to infer characteristics about a person. The chart below identifies which sensitive personal information categories, if any, we have collected from Site visitors to infer characteristics about them in the last 12 months.

Sensitive Personal Information Category	Collected to Infer Characteristics?	Retention
L.1. Government identifiers, such as Social Security, driver’s license, state identification card, or passport number	No	2 years, if included in a message
L.2. Complete account access credentials	No	2 years, if included in a message
L.3. Precise geolocation	No	2 years, if included in a message
L.4. Racial or ethnic origin	No	2 years, if included in a message
L.5. Citizenship or immigration status	No	2 years, if included in a message
L.6. Religious or philosophical beliefs	No	2 years, if included in a message
L.7. Union membership	No	2 years, if included in a message
L.8. Mail, email, or text messages not directed to Fulcrum Construction	No	2 years, if included in a message
L.9. Genetic data	No	2 years, if included in a message
L.10. Neural data	No	2 years, if included in a message
L.11. Unique identifying biometric information	No	2 years, if included in a message
L.12. Health information	No	2 years, if included in a message
L.13. Sex life or sexual orientation information	No	2 years, if included in a message
L.14. Personal information of children under 16	No	2 years, if included in a message

How we use information

We use personal information collected through the Site to:

• Route your message to the right person or office and reply to it.
• Review and respond to subcontractor inquiries and prequalification requests.
• Operate, secure, and improve the Site, including fixing errors and understanding which pages visitors use.
• Communicate with you about a project or business relationship.
• Send you information about Fulcrum Construction services, projects, and news.
• Comply with local, state, and federal law, and respond to legal requests.
• Protect against fraud, abuse, and other malicious or illegal activity.
• Verify and respond to privacy requests.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without notifying you. If the law requires it, we will also ask for your consent before using your personal information for a new or unrelated purpose.

How we share information

Fulcrum Construction does not sell personal information. We have not sold personal information in the last 12 months and will not sell it in exchange for money or any other valuable consideration. We do not share personal information for cross-context behavioral advertising, and we do not knowingly sell or share the personal information of anyone under 16.

We disclose information only in these situations:

• Service providers: Companies that host the Site, provide security and IT support, run our forms and email, and provide analytics. They receive only the information they need to perform those services and may not use it for other purposes. We disclose information to service providers only under written contracts that require them to keep it confidential, prohibit them from using it for any purpose except performing the contract, and meet the CCPA’s other requirements for service providers and contractors.
• Aggregate statistics: We may share statistics about the Site and its visitors, such as the number of visitors or the pages viewed most often. These statistics do not identify any individual. We keep aggregated and deidentified information in deidentified form and do not attempt to reidentify it.
• Fulcrum Construction offices: Your message is routed internally to the office or team member best placed to respond.
• Legal and safety reasons: We may disclose information when we believe in good faith that the law requires it or that disclosure protects our employees or the public.
• Business transfers: If Pivot Point Holdings Inc. and/or Fulcrum Construction sells or transfers part or all of its business, personal information may transfer as part of the transaction.
• At your direction: We share information when you ask us to.

Cookies, analytics, and Global Privacy Control

The Site uses cookies and similar technologies to keep pages working and to understand how visitors use the Site. We use [analytics provider] for visitor statistics. You can block or delete cookies in your browser settings. Some Site features may not work if you do.

Global Privacy Control

If your browser or device sends a Global Privacy Control (GPC) signal, we treat it as a valid request to opt out of the sale or sharing of your personal information and of targeted advertising. Fulcrum Construction does not sell personal information or use it for targeted advertising, so a GPC signal requires no change to how we handle your information.

Do Not Track

No uniform standard exists for Do Not Track browser signals, and the Site does not respond to them.

Job applicants

Applying through Pinpoint

Pivot Point Holdings Inc. & Fulcrum Construction uses Pinpoint, an online recruitment software product provided by The Infuse Group Ltd. (trading as Pinpoint Software), to manage job applications. When you select VIEW OPENINGS & APPLY or register your interest in a future opening, you move to the Pinpoint application portal. The Pinpoint application portal may use cookies and similar technologies for Pinpoint’s own purposes.

Fulcrum Construction decides what applicant information we collect and how we use it. Pinpoint acts as our service provider (data processor). It processes your information on our behalf and only in accordance with our instructions.

Pinpoint’s tools can also link the information you give us to information you have published online, such as LinkedIn and other social media profiles, and can search databases to find possible candidates. When we find you this way, we obtain your information from those sources.

The rest of this section describes how Fulcrum Construction handles applicant information. It applies in addition to the rest of this Privacy Policy.

What we collect

In the last 12 months, we have collected the following categories of personal information from or about job applicants. The examples illustrate each category and do not list everything we may collect.

Category	Examples
Identifiers	Name, alias, date of birth, Social Security number, driver’s license or state identification number, passport number, company ID number
Contact information	Home or mailing address, email address, phone number
Pre-hire information	Application and resume details, work authorization status, background screening and reference check results, pre-hire drug test results, interview notes, candidate evaluations and assessments, work samples, voluntary disclosures such as protected classifications
Professional or employment-related information	Prior jobs and positions held; salary history or expectations where the law permits
Education information	Education history, transcripts, degrees, vocational certifications
Disability and accommodation information	Information about a disability or a need for reasonable accommodation
Inferences	Conclusions drawn from the information above about your abilities, aptitudes, and fit for a role, used in recruiting and hiring decisions

Some of this information is sensitive personal information under California law, including Social Security, driver’s license, and passport numbers, work authorization status, drug test results, and disability or accommodation information. We use it to evaluate your application, complete pre-hire screening, provide accommodations, and comply with the law. We do not use or disclose sensitive personal information for any purpose that gives rise to a right to limit its use under the California Consumer Privacy Act.

Where it comes from

• You, when you apply, register your interest, or send us information.
• Public online profiles, such as LinkedIn and other social media, and databases that Pinpoint’s tools search, as described in Applying Through Pinpoint.
• Job platforms and career sites such as Glassdoor, Indeed, LinkedIn, and ZipRecruiter.
• Personal references, former employers, and schools you attended.
• Credit and consumer reporting agencies and HR support vendors.
• Recruiting firms and staffing agencies.
• Friends, family, or colleagues who email you a job posting from our application platform.
• Surveillance cameras at our physical locations.
• Our employees, contractors, vendors, suppliers, guests, visitors, and customers, based on your interactions with them.

How we use it

• Evaluate, make, and communicate decisions about your application and candidacy.
• Keep your application and applicant profile on file for future openings, including when you register your interest.
• Obtain and verify background checks, references, and employment history.
• Keep records that employment laws require, such as immigration, safety, and tax records.
• Evaluate and improve our recruiting methods.
• Monitor lawfully when you are on Company premises or use Company networks, devices, and systems.
• Protect against malicious or illegal activity and prevent identity theft.
• Verify and respond to privacy requests, and conduct the risk assessments, cybersecurity audits, and internal audits the law requires.
• Manage our relationships with the vendors that support recruiting.
• Review applicant records under non-disclosure agreements when a merger, acquisition, or similar transaction requires it.

Who receives it

We disclose applicant information to government agencies as the law requires; to Pinpoint, our applicant tracking service provider, and to other HR system vendors; to recruiting firms and staffing agencies; to credit and consumer reporting agencies; to security, IT, and privacy vendors; and to social media platforms. We have not disclosed disability and accommodation information to any third party in the last 12 months.

How long we keep it

We keep each category of applicant information for as long as we have a legal or business need that matches the purpose for which we collected it. We consider the purposes of collection, federal, state, and local recordkeeping laws, statutes of limitation for related claims, and legal preservation obligations. The law sets minimum periods for some records, and we keep those records for the required period plus additional years. Vendors manage some of these records for us. When the business purposes and legal reasons for keeping information have both ended, we securely purge it.

Security, your rights, and contact

The sections below apply to website visitors and job applicants alike.

How we protect and keep information

Protecting your information is a priority for us, and we take reasonable measures to safeguard it:

• We keep automatically collected data and voluntarily provided data separate.
• We encrypt the data stores that hold information you provide voluntarily.
• We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
• We restrict access to personal information to the people who need it to do their jobs.

No method of transmission or storage is completely secure. If a security incident affects your personal information, we will notify you as the law requires.

For Site inquiries and subcontractor submissions, we keep personal information for 2 years. When we no longer need it, we delete it or remove identifying details. Retention for job applications is described in the Job Applicants section.

Your privacy rights

Your rights depend on where you live. To use any of them, follow the steps in How to Submit a Request.

California residents

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), you have the right to:

• Know the categories of personal information we collected about you, the sources, the business purposes, the categories of third parties and service providers that received it, and the categories we sold or shared (none).
• Access the specific pieces of personal information we hold about you.
• Delete personal information we collected from you, subject to legal exceptions. We will also notify our service providers and contractors to take appropriate action.
• Correct inaccurate personal information. We will also notify our service providers and contractors to take appropriate action.
• Opt out of the sale or sharing of your personal information. Fulcrum Construction does not sell or share it.
• Limit the use and disclosure of sensitive personal information. We do not use or disclose it for purposes that give rise to this right.
• Receive equal treatment. We will not retaliate against you for exercising your rights, including when you are a job applicant, employee, or independent contractor.

You may make a request to know or access your personal information twice in any 12-month period. Our response covers the 12 months before we receive your request. On request, we will cover a longer period back to January 1, 2022, unless doing so is impossible or would involve disproportionate effort. When you request a copy of your personal information, we provide it in a readily usable format that allows you to transmit it to another entity.

Under California Civil Code Section 1798.83, California residents may also ask which personal information we disclosed to third parties for their direct marketing purposes. We make no such disclosures.

Automated decision-making technology

When a business uses automated decision-making technology (ADMT) to make significant decisions about you, California law gives you the right to obtain information about how the business uses ADMT, to opt out of its use, or to appeal a decision to a human reviewer with the authority to overturn it. Significant decisions include decisions about employment or independent contracting opportunities.

These rights take effect January 1, 2027. We will update this section by that date to describe any use of ADMT by Fulcrum Construction and how to exercise these rights. If you have questions about ADMT, call us at 1‑888‑204‑9517 or use our Contact page form and choose “Something else.”

Texas residents

Under the Texas Data Privacy and Security Act, you have the right to:

• Confirm whether we process your personal data and access it.
• Correct inaccuracies in your personal data.
• Delete personal data you provided to us.
• Obtain a copy of your personal data in a portable format, where the data is available digitally.
• Opt out of targeted advertising, the sale of personal data, and profiling that produces legal or similarly significant effects. Fulcrum Construction does not use personal data for targeted advertising, does not sell personal data, including sensitive personal data, and does not use personal data for profiling that produces legal or similarly significant effects.
• Exercise these rights without discrimination from Fulcrum Construction.

Oregon residents

Under the Oregon Consumer Privacy Act, you have the right to:

• Confirm whether we process or have processed your personal data, access it, and obtain a list of the categories of personal data we process.
• Obtain a list of the specific third parties to which we have disclosed your personal data.
• Correct inaccuracies in your personal data.
• Delete personal data you provided or we obtained about you.
• Obtain a copy of your personal data in a portable format, where the data is available digitally.
• Opt out of targeted advertising, the sale of personal data, and profiling that produces legal or similarly significant effects. Fulcrum Construction does not use personal data for targeted advertising, does not sell personal data, and does not use personal data for profiling that produces legal or similarly significant effects.
• Exercise these rights without discrimination from Fulcrum Construction.

Georgia, Pennsylvania, and other states

Georgia and Pennsylvania have not enacted comprehensive consumer privacy laws. Residents of those states and of any other state can use the same contact methods to ask questions or submit requests about their information. We will review each request and respond.

How to submit a request

You can submit a request by either method below. Include your name, your state of residence, how to reach you, and the right you want to use.

• Contact Us Form: Tell us through our Contact page and choose “Something else”. Fill in the box with your Request(s) and we will respond within the required time for your location.
• Email: build@fulcrumconstruction.com
• Phone: 1‑888‑204‑9517

Verifying your identity

When you submit a request to know, access, delete, or correct personal information, we ask you to confirm information that links your identity to the information we hold. What we ask for depends on your relationship with us. We use the information you provide in a request only to verify your identity or authority to make the request. You do not need to create an account with us to submit a request.

Response times

• California: We confirm receipt within 10 business days and aim to respond within 45 calendar days. If you do not receive confirmation within 10 business days, contact us at build@fulcrumconstruction.com. If we need more time, we may extend by up to 45 additional calendar days (90 in total) and will tell you the reason and the extension period in writing.
• Texas and Oregon: We respond within 45 days. We may extend once by 45 days when reasonably necessary, and we will tell you about the extension and the reason within the first 45 days.

We deliver our response by mail or electronically, at your option. If we cannot comply with a request, our response explains why. We do not charge a fee unless a request is excessive, repetitive, or manifestly unfounded. In that case, we explain our decision and give you a cost estimate before we continue.

For a request to correct information, we review any documentation you provide. We may ask for documentation to rebut our own records, and we may deny a correction request that we reasonably and in good faith believe is fraudulent or abusive.

Authorized agents

California residents may authorize another person to submit a request on their behalf. The agent must provide a valid, verifiable, and notarized power of attorney or other written, signed authorization from you. We will also contact you to verify your identity directly. We may deny a request when the agent does not provide your signed permission.

Appeals

If you live in Texas or Oregon and we decline your request, you may appeal. Email or call us using the contact details above and put “Privacy Appeal” in the subject line or at the start of your call. We will tell you in writing what action we took on your appeal and why, within 60 days for Texas residents and 45 days for Oregon residents. If we deny your appeal, we will give you the information you need to submit a complaint to your state attorney general.

CCPA rights request metrics

Metrics regarding the consumer rights requests we received from January 1, 2026 through December 31, 2026 will be available through a link in this policy by July 1, 2027. If you have questions about these metrics, call us at 1‑888‑204‑9517 or use our Contact page and choose “Something else.”

Children, changes, and contact

Children

The Site is intended for business and professional visitors. We do not knowingly collect personal information from children under 13 through the Site or from job applicants under 16. If you believe a child has given us personal information, contact us and we will delete it.

Changes to this policy

We review this Privacy Policy at least once every 12 months and update it when our practices change. We post the revised policy and its effective date on this page. For material changes, we will place a notice on the Site.

Accessibility

We provide the Privacy Policy in a form that is accessible to people with disabilities. To request it in another format, contact us using the details below.

Contact us

Questions about this Privacy Policy can go to Fulcrum Construction at:

Contact Us Form: Tell us through our Contact page and choose “Something else”. Fill in the box with your question(s) and we will respond within 5 business days.

Email: build@fulcrumconstruction.com

Phone: 1‑888‑204‑9517

Mail:
Fulcrum Construction
Attn: Fulcrum Construction Admin
1945 The Exchange, Suite 400
Atlanta, GA 30339