Effective Date: January 1, 2021
Last Updated: June 23, 2025
INTRODUCTION
PHSW Corporation, doing business as PHS West, LLC (collectively referred to herein as “PHSW,” “we,” “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users,” “you” or “your”) who visit our websites or engage with us in other related ways – including but not limited to, any sales, marketing or events. This Privacy Policy applies to data collection by PHSW and shall apply to your use of the website, https://www.phswest.com and other PHSW related sites, events, applications, software, communications, capabilities and services (“services”) accessible on or by any top-level PHSW domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state they are offered under a different privacy policy.
Our Privacy Policy explains (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:
Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites or engaging with us, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.
Irrespective of which country you live in, you authorize us to transfer, store and use your information in the United States and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
If you have any questions or comments about this Privacy Policy, please submit a request to info@phswest.com.
WHEN THIS POLICY APPLIES
Our Privacy Policy applies to all of the Services offered by PHSW and its affiliates, including some PHSW partners and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
INFORMATION WE COLLECT
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity such as login name or handle, information about your device and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data or sexual orientation. We do not collect Sensitive Personal Data.
When you use our Services, we collect Personal Data in the following ways:
1. INFORMATION YOU GIVE TO US
As you evaluate whether PHSW is the right solution for your company, you may choose to provide us with Personal Data about yourself including your name, company name, phone number, billing address, shipping address, job title, industry, country of residence and email address by completing forms on our website. You may also choose to provide us with employment and education information when you apply for a job at PHSW via our Site.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in some areas of the Sites may be publicly accessible or accessible to other Users.
2. INFORMATION WE OBTAIN FROM YOUR USE OF OUR SERVICES
Log and Usage Data
Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the website (such as date and time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports sometimes called ‘crash dumps,’ and hardware settings).
Device Data
We collect device data such as information about your computer, phone, tablet or other device you use to access the website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile provider, operating system and system configuration information.
Location Data
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. If you choose to opt out, you may not be able to use certain aspects of the Services.
3. Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google Analytics, Facebook Ads and similar partners.
The technologies we use for this automatic data collection may include:
Cookies: A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.
Web Beacons: Pages of our services or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data: Clickstream data is information collected by our computers when you request web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
INFORMATION COLLECTED RELATED TO CALIFORNIA AND VIRGINIA RESIDENTS
During the last 12 months, we have collected the following categories of personal information from consumers:
CATEGORY | TYPE OF IDENTIFIERS WE COLLECT | COLLECTED |
Identifiers | First and last name, business address, unique personal identifier, online identifier, Internet Protocol address, email address, signatures; account ID and password | YES |
Personal Information Categories Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)) | A name, business address, telephone number, employment, employment history, credit card number, debit card number or any other financial information | YES |
Internet or Other Similar Network Activity | Browsing history and time, search history, information on a consumer’s interaction with a website application or advertisement | YES |
Commercial Information | Records of personal property, products or services purchased, obtained or considered, or any other purchasing or consuming histories or tendencies | YES |
Professional or Employment-Related Information | Current or past job history or performance evaluations, inferences drawn from other personal information, profile reflecting a person’s preferences, behavior, attitudes and social media account information | YES |
Inferences Drawn from Other Personal Information | Profile reflecting a person’s preferences, behavior, attitudes and social media account information | YES |
We obtain the categories of Personal Information listed above from the following categories of sources:
HOW WE USE INFORMATION WE COLLECT
We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including the following purposes:
We use the information we collect from our Sites to provide, maintain and improve them to develop new services and to protect our company and our Users.
We use information collected from cookies and other technologies to improve your User experience and the overall quality of our services. We may use your Personal Data to see which web pages you visit at our Site, which website you visited before coming to our Site and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide more specific notice at the time of collection.
We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.
SALE OF PERSONAL INFORMATION
In the preceding 12 months, we have not sold any Personal Information.
OUR LEGAL BASIS FOR COLLECTING PERSONAL DATA
Whenever we collect Personal Data from you, we may do so on the following legal bases:
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
INFORMATION WE SHARE
We do not share Personal Data with companies, organizations and individuals outside of PHSW unless one of the following circumstances applies:
We attempt to notify users about legal demands for their Personal Data when appropriate in our judgement, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
In the preceding 12 months, we have disclosed the following categories of Personal Information for one or more business purposes:
We disclose your Personal Information for a business purpose to the following categories of third parties:
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of PHSW if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
We attempt to notify you about legal demands for your Personal Information when appropriate in our judgement, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
YOUR FAILURE TO PROVIDE PERSONAL DATA
Your provision of Personal Data is required in order to use certain parts of our Services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
OUR RETENTION OF YOUR PERSONAL DATA
We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use or fulfill your request to “unsubscribe” from further messages from us.
YOUR PRIVACY RIGHTS AND CHOICES
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
PRIVACY RIGHTS SPECIFIC TO CALIFORNIANS
Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
PRIVACY RIGHTS SPECIFIC TO VIRGINIANS
Under the House Bill 2307 for the Consumer Data Protection Act (CDPA) of the Virginia legislator, Virginia residents have specific rights regarding their personal information. This section describes Virginians’ rights and explains how Virginian residents can exercise those rights.
Below, we further outline specific rights which Virginia residents may have under CDPA.
EXERCISING YOUR RIGHTS
If you choose to exercise your rights, you can:
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification and the authorized agent’s valid government issued identification.
OUR RESPONSE TO YOUR REQUEST
Upon receiving your request, we will confirm receipt of your request by [sending you an email, confirming receipt via our online portal, sending a message to your online account]. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to, in fact, delete your personal information before acting on your request.
We will respond to your request within 30 days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
PRIVACY RIGHTS SPECIFIC TO EUROPEAN UNION, OTHER INTERNATIONAL AND OTHER US STATE RESIDENTS
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in Switzerland and in the United Kingdom, and some US state laws provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area or other region, you may have the following rights:
You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/newsroom/article29/items/612080
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request. We may respond to your request by letter, email, telephone or any other suitable method. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
OUR OPT-IN AND OPT-OUT POLICY
By providing an email address on the PHSW Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service-related notices, or to provide you with information about our events, invitations or related educational information.
For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.
We currently provide the following opt-out opportunities:
Notwithstanding anything else in this Privacy Policy, please note we always reserve the right to contact you in the event of a change in this Privacy Policy or to provide you with any service-related notices.
YOUR AD CHOICES
As described above, we or third-party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. PHSW is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not PHSW. PHSW does not control or operate these tools or the choices that advertisers and others provide through these tools.
THIRD PARTY LINKS
The Sites may contain links to webpages operated by parties other than PHSW. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. PHSW strongly recommends that each User review the third party’s terms and policies.
INTERNATIONAL TRANSFER
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.
Personal Data and any additional information submitted may be used globally in connection with employment, business processes within PHSW or communicating with our PHSW Partners. Therefore, Personal Data may be transferred to such entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.
If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally provided mechanisms to lawfully transfer data across borders to ensure your Personal Data is protected.
HOW WE PROTECT PERSONAL DATA
PHSW maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to PHSW employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
If PHSW collects account information for payment or credit, PHSW will use the information only to complete the task for which the account information was offered.
CHILDREN
The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have that information deleted from our records. If you believe we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at info@phswest.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
DIRECT MARKETING AND “DO NOT TRACK” SIGNALS
The PHSW website does respond to Do Not Track (DNT) signals.
California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request to info@phswest.com. California users may request further information about our compliance with this law by contacting us at info@phswest.com or by writing to us at the address listed in the “How to Contact Us” section.
CHANGES TO THIS PRIVACY POLICY
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
HOW TO CONTACT US
If you have any specific questions about this Privacy Policy, you can contact us via email, telephone or by writing to us at the address below:
Send email to: info@phswest.com
Send mail to our address:
PHS West, LLC
6704 Bleck Drive
Rockford, MN 55373
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