I. Introduction.

The following is the privacy policy of Phylmar Group, Inc., a California corporation (“Phylmar” or “we” or “our” in this document). Since AFIRM is a division of Phylmar, in this document all references to Phylmar also refer to AFIRM. Our contact information is as follows:

Address: 10513 Santa Monica Boulevard, Los Angeles, CA 90025
Phone: 310-474-3937
Email: info@phylmar.com

By using any of our websites (“https://www.phylmar.com” & “https://afirm-group.com”), or becoming a Client, Consortium/Academy Member, or Affiliate of Phylmar, you agree to this Privacy Policy. For those in jurisdictions that require specific consent to such a policy, you must consent or not consent to this Privacy Policy at the end of this document. The European Community is such a jurisdiction.

The data Phylmar collects is different for each of the following groups of people and entities:

A. Visitors to the Phylmar websites (“Visitors”).
B. Those on our email mailing list (“Recipients”).
C. Consortium/Academy Members (“Members”).
D. Phylmar Clients (“Clients”).
E. Phylmar Affiliates (“Affiliates”).
F. Potential Clients, Members or Affiliates.

Phylmar does not “process” or sell the data we collect. Nor does Phylmar transfer such data, except as follows: between Phylmar Clients and Phylmar Affiliates, we transfer data necessary to the performance of work by Phylmar Affiliates for Phylmar Clients (for example, when a Phylmar Affiliate performs work for a Phylmar Client, it is necessary for Phylmar to provide the Affiliate with enough information about the Client in order to perform the requested work, and to provide the Client with enough information about the Affiliate to identify the Affiliate to the Client). Use of data from the above groups is described within.

We may revise this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the bottom of this document. Visitors, Recipients, Members, Clients, and Affiliates are responsible for regularly reviewing the current policy and terms. Continued use of our websites after we post any revisions constitutes your agreement to any such revisions. Again, for jurisdictions that require specific consent to such revisions, you may be asked to consent or not consent to the revised Privacy Policy.

Phylmar reserves the right described within to keep specified data or information for certain periods of time. The fact that Phylmar is permitted to do so shall not be interpreted as requiring Phylmar to keep any data or information for any period of time, nor is it a promise by Phylmar to store any data or information.

II. Deletion of Information Collected by Phylmar.

Phylmar collects somewhat different kinds of data about different categories of individuals and entities, depending upon your relationship with Phylmar. We only collect data strictly necessary for the purpose for which such is provided. The following describes the kind of data we collect from different categories of individuals and entities.

A. Visitors to the Phylmar websites.

Phylmar uses “cookies” to help in identifying you to our websites on future visits, and to improve and personalize your experience.

Cookies are files stored on the hard disk of your computer. A cookie is not used to collect personal data from website visitors, but to record information about their browsing behavior on our websites that can be directly read by Phylmar during that and future website visits. Cookies help us recognize you and to know preferences necessary to provide you with service.

Phylmar does not store any data about those who merely visit our websites, unless they request to be placed on our mailing list or some other affiliation.

B. Those on our mailing lists.

If you have requested to be placed on our mailing lists (e.g., email, newsletter, etc.), or if you have been included by virtue of your having or had some other relationship with Phylmar, we will store the data that you provided to us: your name, firm, and email address. The legal basis for this treatment of your data is your consent.

Every email or other electronic communication we send you will have an “Unsubscribe” option near the bottom. If you click “Unsubscribe” we will remove your data from our mailing list within thirty (30) days. If you are also a Member, Client, or Affiliate, and wish to remove your data relating to those categories deleted, you will need to notify Phylmar as discussed below under the specific category.

Mailing list data is kept by Phylmar until you Unsubscribe from our mailing lists. Such data is only used for communicating with you.

C. Consortium/Academy Members.

If you have joined one of Phylmar’s Consortium/Academy, we store the data you have provided to us: your name, email, company, and phone number. The legal basis for this treatment of your data is your consent. We keep your data as long as you are a member of a Phylmar Consortium/Academy.

If you would like us to delete your data, please send an email to info@phylmar.com and in the subject area say “Delete Data” and in the body of the email write one of the following:

“Delete All Data”
“Delete Member Data” (if you only want Consortium/Academy data deleted, but wish Phylmar to continue to store your data relating to your status as a Client or Affiliate).

Please send the above email from the account at which you have received emails from Phylmar, or provide that email address in the body of the request.

If you request “Delete Member Data” Phylmar will remove your Consortium/Academy data from our system within thirty (30) days of receipt of your request.

If you request “Delete All Data” Phylmar will remove your Consortium/Academy data from our system within thirty (30) days of receipt of your request. Phylmar will remove all other data about you (i.e., Client and Affiliate data) as discussed below under the specific category.

Phylmar only uses Consortium/Academy data to facilitate the exchange of information and articles and posts by Members (and to include such Members in our email mailing list – unless and until they “Unsubscribe”).

D. Phylmar Clients (“Clients”).

If you are a Client of Phylmar (e.g., we have performed some sort of work for you at any time), we store the data you have provided to us and that we have developed: your name, email, company, contact people, address, phone number, correspondence, payment information, work product, contracts and related information and materials. We maintain these data until the end of the “Retention Period” – which shall be defined as two (2) years after the minimum retention required by appropriate statutes of limitations and government agencies (e.g., the Internal Revenue Service, government regulatory agencies, etc., as well as foreign equivalent agencies). We reserve the right to maintain contracts, work product and correspondence (“Safety & Legal Data”) for a longer period of time, until Phylmar determines that it has absolutely no use or value in the future evaluation of potentially dangerous conditions. The legal basis for this treatment of your data is your consent and safety concerns.

If you would like us to delete your data, please send an email to info@phylmar.com and in the subject area say “Delete Data” and in the body of the email write one of the following:

“Delete All Data”
“Delete Client Data” (if you only want Client data deleted, but wish Phylmar to continue to store your data relating to your status as an Affiliate or Member)

If you request “Delete Client Data” Phylmar will remove your Client data from our system within thirty (30) days after end of the Retention Period, except for the above-noted Safety & Legal Data that we may keep for a longer period.

If you request “Delete All Data” Phylmar will remove all of your data from our system within thirty (30) days after end of the Retention Period, except for the above-noted Safety & Legal Data that we may keep for a longer period.

Please send the above emails from the account at which you have received emails from Phylmar, or provide that email address in the body of the request.

Phylmar uses Client data only as necessary for performance of the work authorized by the Client (and to include such Clients in our email mailing list – unless and until they “Unsubscribe”).

E. Phylmar Affiliates (“Affiliates”).

If you are an Affiliate of Phylmar (e.g., you have performed some sort of work for or through Phylmar at any time), we store the data you have provided to us and that we have developed: your name, email, company, contact people, address, phone number, correspondence, payment information, work product, contracts and related information and materials. We will maintain these data until the end of the “Retention Period” – which shall be defined as two (2) years after the minimum retention required by appropriate statutes of limitations and government agencies (e.g., the Internal Revenue Service, government regulatory agencies, etc., as well as foreign equivalent agencies). We will maintain contracts, work product and correspondence (“Safety & Legal Data”) for a longer period of time, until Phylmar determines that it has absolutely no use or value in the future evaluation of potentially dangerous conditions. The legal basis for this treatment of your data is your consent and safety concerns.

If you would like us to delete your data, please send an email to info@phylmar.com, in the subject area write “Delete Data” and in the body of the email write one of the following:
“Delete All Data”
“Delete Affiliate Data” (if you only want Affiliate data deleted, but wish Phylmar to continue to store your data relating to your status as a Client or Member)

If you request “Delete Affiliate Data” Phylmar will remove your Affiliate data from our system within thirty (30) days after end of the Retention Period, except for the above-noted Safety & Legal Data that we may keep for a longer time.

If you request “Delete All Data” Phylmar will remove all of your data from our system within thirty (30) days after end of the Retention Period, except for the above-noted Safety & Legal Data that we may keep for a longer time.

Phylmar uses Affiliate data only as necessary for performance of the work by the Affiliate for Phylmar or a Phylmar Clients (and to include such Affiliates in our email mailing list – unless and until they “Unsubscribe”)

F. Potential Members, Clients or Affiliates.

Potential Members, Clients or Affiliates are those individuals and entities who have been in contact with Phylmar regarding becoming Members, Clients or Affiliates, but who never actually became such (e.g., never performed work for or through Phylmar, and never had Phylmar or Phylmar Affiliates do work for them). Phylmar stores the following data about Potential Clients or Affiliates: your name, email, company, address, phone number, correspondence.

We will keep your data for a period of three (3) years after the last incoming contact from you. The legal basis for this treatment of your data is your consent.

If you would like us to delete your data, please send an email to info@phylmar.com and in the subject area say, “Delete Data” and in the body of the email write “Delete Data” and we will remove your data from our system within thirty (30) days after receipt of your request.

III. Privacy Concerns.

A. Complaints and Concerns.

If you have a complaint or concern about our Privacy Policy, please let us know by contacting Phylmar at the following address:
10513 Santa Monica Boulevard
Los Angeles, CA 90025

or at info@phylmar.com

You also have the right to object to the processing of your personal data, as well as the right to object to these data being used for commercial prospecting purposes.

Finally, you have the right to file a complaint with appropriate governmental agencies, such the National Commission for Informatics and Freedoms. Again, we hope you will contact Phylmar to allow us to resolve the matter in advance.

B. Copies of Stored Data.

If you want a listing of the data Phylmar is storing about you, please send an email to info@phylmar.com, and write “Data Stored” in the Subject Line.

Last Updated: June 12, 2018