Privacy Notice

Last Updated: July 15, 2026

This Privacy Notice (“Notice”) applies to the processing of personal information by Phil, Inc. and our affiliates (“Phil,” “we,” “us,” or “our”), including on our mobile application, our website available at www.phil.us, www.myphil.us, our associated site(s), our microsite(s), and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

Special Note to Phil Patients and Potential Patients: When you visit our website or inquire about or register for our Services, we may collect information that identifies you and relates to your past, present, or future physical or mental health, treatment and services received, and payment for such treatment and services. This information may be considered protected health information (“PHI”) by the Health Insurance Portability and Accountability Act of 1996 (as amended) and the Health Information Technology for Economic and Clinical Health Act. If you receive care from us, this Notice describes how we collect, use, and share your non-PHI personal information and is separate from and in addition to our HIPAA Notice of Privacy Practices describing how we use and disclose your PHI.

Special Note to Consumers Residing in States with Laws Protecting Consumer Health Data or Sensitive Personal Information Privacy. For information on our processing of “consumer health data” or “sensitive personal information” subject to a consumer health data or other privacy law, please see Annex A – Supplemental U.S. Consumer Health Data Privacy Notice.

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website and/or by sending other communications where required by law.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources (see Section 4 below), as described below.

Personal Information You Provide to Us Directly

We may collect personal information you provide to us.

Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, date of birth, gender, email address, phone number, medical and health information, and other information you store when registering and maintaining your account. To fully utilize our Services, you may be required to fill out and submit forms containing additional personal information such as your postal address, social security number, and other personal information relevant to your health status, diagnosis, treatment, and insurance coverage.
Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our online chat tool.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information, educational and employment history, and CV information.

Personal Information Collected Automatically

We may collect personal information automatically when you use the Services. We use third-party customer relationship management, marketing automation, analytics, and data enrichment tools, including HubSpot and ZoomInfo, that collect or receive personal information when you visit or interact with our websites, emails, or other online content.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
Usage Information. We may collect personal information about your use of the Services, such as the pages you visit, you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
Cookie Notice (and Other Technologies). We, as well as third parties (such as HubSpot), may use cookies, pixel tags, web beacons, and other technologies, collectively “Technologies”) to automatically collect personal information (such as IP address, device and browser information, and information about pages visited, links clicked, and other website activity) through your use of the Services. These Technologies may be used for analytics, marketing, lead generation, and business development purposes. Please note, if you become a Phil patient, such Technologies will collect personal information only as permitted by applicable federal and state laws.
- Cookies. Cookies are small text files stored in device browsers.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services collecting personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from such Third-Party Service you have made available via your privacy settings. In addition, we and other third parties may upload or otherwise provide personal information about you (i.e., prescription fill date).

We may receive business contact, professional, and company-related information about you from third-party data providers such as ZoomInfo. This information may include your name, business email address, business phone number, job title, employer, industry, and related professional information, and is used for sales, marketing, business development, and other purposes.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

Managing your information;
Providing access to certain areas, functionalities, and features of the Services;
Delivering accurate and personalized recommendations through the use of artificial intelligence and machine learning capabilities;
Providing newsletters, advertisements, and other promotional communications (with your consent);
Answering requests for support;
Communicating with you;
Sharing personal information with third parties as needed to provide the Services;
Processing your financial information and other payment methods for products and Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.

Our Services are enabled and/or supported by machine-learning tools fundamental to our ability to provide real-time engagement, inform and document treatment approaches, and track progress. These machine-learning tools process natural language communications to support user experience and outcomes.

Administrative Purposes

We use personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Carrying out analytics;
Measuring interest and engagement in the Services;
Improving, upgrading, or enhancing the Services through activities such as data management, analytics, lead scoring, data quality, business intelligence, and internal reporting;
Analyzing, improving, upgrading, and/or enhancing the Services through the use of artificial intelligence and other methods;
Developing new products and services;
Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
Debugging to identify and repair errors with the Services;
Auditing relating to interactions, transactions, and other compliance activities;
Enforcing our agreements and policies; and
Carrying out activities required to comply with our legal obligations.

Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law. Additionally, with your consent, we may also use your information to contact you about goods and services that may be of interest to you. You may opt out of receiving such communications at any time by clicking the “unsubscribe” link at the bottom of these communications, by replying STOP to promotional text messages, or by contacting us as set forth in “Contact Us” below.

We use marketing automation and customer relationship management tools, including HubSpot, to manage communications, measure content engagement, support marketing campaigns, and identify potential business opportunities.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

With Your Consent or Direction

We may use personal information for other purposes clearly disclosed to you at the time you provide personal information with your consent, such as if you opt-in to participate in research studies and research and development activities, or as otherwise directed by you.

Automated Decision Making

We may engage in automated decision making, including profiling. Phil’s processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making.

If you have questions about our automated decision making or to appeal a decision or finding made by such automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Personal information collected through our SMS/text messaging program, including your mobile phone number and SMS consent status, will not be shared, sold, or rented to any third party, whether affiliated or unaffiliated with Phil, for that third party’s own marketing or promotional purposes.

Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

Service Providers. We may disclose personal information to third-party service providers assisting us with the provision of the Services. This may include, but is not limited to, service providers providing us with hosting, cloud storage, generative AI tools, customer service and relationship management, analytics, marketing automation and services, IT support and security, payment processing, system administration, data enrichment services (such as HubSpot and ZoomInfo), deployment of Technologies, chat features, and other related services. Please note, where required by law, we bind our service providers to privacy and security controls (including zero-day retention periods, where applicable). Where permissible by law, certain service providers collect or receive personal information through Technologies and, depending on configuration, may use such personal information for their own business purposes (such as improving their products, services, and datasets) subject to their terms and privacy notices.

Some of the service providers we may engage include:
- Google Analytics. For information about how Google uses your personal information, please visit Google Analytics’ Privacy Notice. To learn about how to opt-out of Google Analytics’ use of your personal information, please click here.
- HubSpot. For information about how HubSpot uses your personal information, please visit HubSpot’s Privacy Policy. To learn how to opt out of its use of your personal information, please click here.
- LinkedIn Analytics. For information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn about how to opt-out of LinkedIn’s use of your information, please click here.
- ZoomInfo Co-Pilot. For information about how ZoomInfo uses your personal information, please visit ZoomInfo’s Privacy Policy. To learn how to opt out of its use of your personal information, please click here.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”). Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
Affiliates. We may share your personal information with our corporate affiliates.

Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.” Some of the advertising Technologies we may use include Google, HubSpot, and LinkedIn.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, divestiture, restructuring, acquisition, financing, reorganization, bankruptcy, dissolution, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices.

The privacy choices you may have about your personal information are described below:

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
Text/SMS Messages. If you receive an unwanted promotional text/SMS message from us, you may opt out of receiving future text/SMS messages from us by following the instructions in the text/SMS message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
Do Not Track Signals, Global Privacy Control, and Universal Opt-Out Mechanisms. Some browsers, browser extensions, and devices transmit automated “opt-out preference signals,” such as the Universal Opt-Out Mechanisms (“UOOMs”) (including the Global Privacy Control (“GPC”)), to indicate a user’s preference to opt out of certain data practices. These signals must typically be enabled through your browser settings or through a supported extension. You can check and adjust your settings by going to the “Do Not Sell or Share My Personal Information” link in the footer of this website.
- We recognize and process UOOMs in the states where applicable law requires such recognition and, when required by law, we treat a valid UOOM signals as a request to opt out of the sale or sharing of personal information and/or targeted advertising, as applicable in that jurisdiction.
- Where not required by law, we may (but are not obligated to) process UOOM signals as a best-effort opt out of the sale or sharing of personal information and/or targeted advertising. In such jurisdictions, any such best-effort honoring will apply only to the extent supported by our systems and may not affect all data flows, disclosures, or cookies. For a comprehensive opt-out, please use the “Do Not Sell or Share My Personal Information” link in the footer of this website.
- Some browsers also send “Do Not Track” (“DNT”) signals. Because DNT signals are not yet standardized and no law currently requires their recognition, we do not respond to DNT signals.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
- Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others.
- The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative and the Digital Advertising Alliance.
- Please note you must separately opt out in each browser and on each device.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:

Confirm Whether We Are Processing Your Personal Information.
Request Access to or Portability of Your Personal Information.
Request Correction of Your Personal Information.
Request Deletion of Your Personal Information.
Request Restriction of or Object to our Processing of Your Personal Information.
Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
Withdraw Your Consent to our Processing of Your Personal Information Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

Please note that if your request relates to protected health information (PHI) maintained in connection with prescription or pharmacy services, those rights are governed by HIPAA and our Notice of Privacy Practices rather than applicable state consumer privacy laws. If your request relates to information held by one of our partner pharmacies, we will notify you and assist in directing your request to the appropriate party.

If you would like to exercise any of these rights, please click HERE and follow the instructions on that page or by emailing us at: privacy@usephil.com. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

Consumer Health Privacy Laws

If you are a consumer residing in a U.S. state with a consumer health data privacy law, or a comprehensive consumer privacy law defining “sensitive personal information” to include health or medical information (or related data), please review our Annex A – Supplemental Consumer Health Data Privacy Statement for our privacy practices related to consumer health data.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws different from the laws where you live.

7. DATA SECURITY AND RETENTION

We employ reasonable physical, technical, and administrative safeguards designed to keep personal information secure; however, no data collection, storage, or transmission including over the Internet or other network can be guaranteed to be 100% secure. Therefore, despite these safeguards, we cannot and do not guarantee the security of any personal information transmitted to us.

Additionally, take steps to protect against unauthorized access to your password, phone, tablet, and computer by, among other things, signing off after using a shared device, choosing a robust password nobody else knows or can easily guess, and keeping log-in information and passwords private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. Where required by applicable law, you may request access to information about our security policies and procedures by contacting us as described in “Contact Us” below.

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, unless you ask us to delete or transfer such information by contacting us as set forth in “Contact Us” below.

To determine the appropriate retention period for personal data, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal data, certain risk factors, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

8. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 18 (or other age as required by local law outside the United States) and we do not knowingly collect personal information from children. We may collect information from employers about members of all ages to determine eligibility for our services.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

9. WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

10. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Phil, Inc.
ATTN: Privacy Officer
14500 N Northsight Blvd, Suite 307
Scottsdale, Arizona 85260
Phone: (855) 977-0975; Option 3
Email: privacy@usephil.com