Astra Brainby Fulcrum Digital
Legal

Privacy Policy

Last updated: 6 August 2026

This Privacy Policy describes how Fulcrum Digital LLC ("we", "us") handles data in connection with Astra Brain, our commerce and advertising analytics platform available at brain.astra-brands.com (the "Platform"), and this public website.

Astra Brain is the proprietary platform of Fulcrum Digital LLC. It is used by our team to manage and measure advertising for the e-commerce storefronts we manage. It is not a consumer product; access is provisioned by us.

1. Who we are

The Platform is operated by Fulcrum Digital LLC, 5830 E 2nd St, Ste 7000 #32329, Casper, WY 82609, United States. The storefronts we manage serve customers primarily in Europe. For any privacy-related question or request, contact us at verkoop.woni@gmail.com.

2. Data we process on this public website

  • No analytics or marketing cookies. This public website does not use advertising trackers, analytics pixels or fingerprinting.
  • Authentication cookie. When staff sign in, a single encrypted session cookie is set to keep them signed in. It is strictly necessary for the service and is not used for tracking.
  • Server logs. Our web server keeps standard, short-lived technical logs (IP address, request path, timestamp) for security and abuse prevention.

3. Data the Platform processes

Behind its sign-in, the Platform processes the following categories of data, all originating from systems and accounts under our management:

  • Order and commerce data from the Shopify storefronts we manage: order identifiers, order values, timestamps, order status and aggregated product performance. The Platform stores the minimum customer-related fields needed for revenue and conversion reporting; it is not a customer-relationship or marketing database.
  • Advertising performance data from the advertising accounts under our management (including Google Ads): spend, clicks, impressions and conversion metrics.
  • Conversion tracking data collected first-party on the storefronts we manage: advertising click identifiers (such as GCLID) associated with orders, used solely to measure which advertisement led to a sale.
  • Email program metrics from the email accounts under our management: aggregate campaign and flow performance (open, click, delivery and conversion rates). No individual mailbox content is processed.

4. How we use the Google Ads API

The Platform connects to the Google Ads API only for the Google Ads accounts under our management, in order to:

  • retrieve performance reports (spend, clicks, conversions) for the campaigns we manage;
  • upload conversion events for orders placed on the storefronts we manage, so campaign measurement is accurate; and
  • verify that uploaded conversions were accepted.

Data obtained through the Google Ads API is used only for these reporting and measurement purposes. We do not sell it, share it with unrelated third parties, use it to build advertising profiles of individuals, or use data from one account for the benefit of another advertiser. Our use of Google APIs complies with the Google APIs Terms of Service and the Google Ads API policies.

5. Legal bases

Where the GDPR applies, we process the data described above on the basis of our legitimate interest in operating, measuring and improving the stores and advertising under our management (Art. 6(1)(f) GDPR), and where applicable to comply with legal obligations such as bookkeeping requirements (Art. 6(1)(c) GDPR).

6. Sharing

We do not sell personal data. Data is shared only with the service providers that host and support our infrastructure, under agreements that restrict them to processing on our instructions, and with the platforms we work with (for example, sending conversion data to Google Ads as described above).

7. Retention

Commerce and advertising records are retained for as long as they are needed for reporting and for applicable statutory retention periods (including bookkeeping requirements). Technical server logs are kept for a short rolling window. Data that is no longer needed is deleted.

8. Security

All traffic to the Platform is encrypted in transit (TLS), and the Platform is protected by authentication — operational data is never publicly accessible. We apply appropriate technical and organisational measures to protect the data we process.

9. Your rights

If you are in the EU/EEA, you have the right to request access to, correction of, or deletion of personal data we hold about you, to object to processing based on legitimate interest, and to lodge a complaint with your local data protection supervisory authority. To exercise these rights, email verkoop.woni@gmail.com.

10. Changes

We may update this policy from time to time. The "Last updated" date above reflects the latest revision; material changes will be reflected on this page.