WestCX Privacy Statement

Effective April 17, 2026

This Privacy Statement applies to Televox, Inc. and CX360, Inc. and their affiliates (“WestCX”, “we”, “us”, “our”) unless the affiliate has a separately posted privacy statement. WestCX values the privacy of our customers, users, and any individual who accesses or uses the WestCX websites, products, and services (collectively, the “Services”). Your privacy is an important factor WestCX considers in the development, delivery and improvement of our Services. This Privacy Statement explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.

WestCX is a global organization, and the provision of the Services to users may require Personal Information to be shared with other WestCX companies around the world. All WestCX companies are bound by privacy statements, confidentiality and data transfer agreements as appropriate.

What do we mean by “Personal Information”?

For us, “Personal Information” means information or data that relates to an identified or identifiable individual. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, sex life, criminal convictions, biometric information, and precise geolocation data. We apply additional safeguards when processing Sensitive Personal Information, including limiting access, applying enhanced security controls, and processing such data only where permitted by law or with appropriate consent.

What type of Personal Information is collected?

We may collect data, including Personal Information, about you as you use our websites or Services and interact with us. This information may include name, address, email address, IP address, phone number, login information, coarse geolocation, marketing preferences, payment card number, communications content and related metadata (such as timestamps, delivery status, routing information and error codes, as applicable). We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

Please understand, in addition to collecting Personal Information, WestCX may also gather information that does not personally identify you regarding your use of the WestCX websites or the Services (“Anonymous Information”). We may use the Anonymous Information we collect to measure the effectiveness of our marketing efforts, for improving the Services we offer, or to improve the WestCX websites and to train, develop and improve our artificial intelligence and machine learning models and capabilities. Generally, you will not be aware when we collect such Anonymous Information. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the WestCX websites.

How do we receive Personal Information about you?

We learn Personal Information about you when:

    • you give it to us directly (e.g., when you choose to contact us, or provide it on WestCX websites);
    • we collect it automatically through our Services (e.g., your use of Services);
    • someone else tells us Personal Information about you (e.g., our customer provides us your Personal Information in order for us to perform Services for them, and in such case, our customer is responsible for ensuring Personal Information has been collected and shared with us in compliance with applicable law); or
    • when we try to understand more about you based on Personal Information you’ve given to us (e.g., when we use your IP address to customize language for some of our Services).

Our Services are not directed to children under the age required by applicable law, and we do not knowingly collect Personal Information directly from such individuals. If we become aware that we have collected Personal Information from a child without appropriate authorization, we will take steps to delete it in accordance with applicable law. Our customers may, however, use the Services to process Personal Information relating to individuals under the applicable age threshold. In such cases, the customer is responsible for ensuring that such Personal Information is collected and provided to WestCX in compliance with applicable law, including obtaining any required consents or parental authorizations. WestCX processes such Personal Information solely on behalf of and in accordance with the instructions of its customers and does not independently determine the purposes or means of such processing. Parents or guardians who believe that a child’s Personal Information has been provided through our Services may contact us as described below. Where appropriate, we will direct such requests to the relevant customer.

What do we do with your Personal Information once we have it?

WestCX does not sell Personal Information and does not use Personal Information provided by customers for cross-context behavioral advertising or independent marketing purposes.

When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our customers who provided us the Personal Information instruct. In many cases, WestCX provides Services on behalf of our business customers. In these cases, our customers determine the purposes for which Personal Information is processed. In limited circumstances, WestCX may act as a data controller for certain Personal Information, such as accounting, billing, support and service-related data. We distinguish between “Customer Data” and “Service Data”. Customer Data is Personal Information processed on behalf of our customers, whereas Service Data is information generated through operation of our Services such as usage metrics, logs, diagnostics and performance data. WestCX may use Service Data to operate, secure, maintain and improve the Services, develop new services that may be helpful to you or our customers, and, in aggregated or de-identified form that does not identify any individual or customer, to train, develop and improve the artificial intelligence and machine learning models and capabilities of the Services. Where permitted, Service Data may be aggregated or de-identified so that it does not identify any individual or customer. We may use the Personal Information you provide to contact you regarding additional or new services and features offered by WestCX, or important information regarding WestCX.

We may use Personal Information to enforce our agreements with you or our customers, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our Services.

How do we use automation and Artificial Intelligence?

Our Services include an orchestrated system of action that may incorporate the use of automated processing and artificial intelligence capabilities, such as workflow automation, routing decisions, classification, prioritization, and recommendations. These capabilities are generally configured and controlled by our customers. WestCX does not determine the specific use cases or outcomes implemented by customers. Nor does WestCX independently make decisions about individuals outside of the configurations and instructions provided by our customers. Where such decisions are made at the direction of our customers, you may have the right to request human review of the decision, express your point of view or contest the outcome, and any such requests should be directed to the relevant customer of WestCX.

WestCX is committed to the responsible use of artificial intelligence, including promoting fairness, transparency, accountability, and minimizing bias in AI-enabled systems.

What is our legal basis for processing your Personal Information?

Where required by applicable law, we rely on one or more of the following legal bases to process your Personal Information: performance of a contract, legitimate interests, consent, legal obligation and/or protection of vital interests (e.g., where necessary to protect the safety of individuals). Legitimate interests may include ensuring the security and integrity of our Services, preventing fraud/misuse, improving the Services, supporting customer relationships and service delivery. Where we rely on consent, you may withdraw your consent at any time as described in this Privacy Statement.

How long will we retain Personal Information?

We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.

When do we share your Personal Information with others?

We may share your Personal Information with others:

    • When we have asked and received your permission to share it.
    • When we’re required to provide it to our customer from whom we received your Personal Information, or with whom you have a business relationship.
    • For processing or providing products and Services to you, but only if those entities (i.e., subprocessors) receiving your Personal Information (such as cloud providers, telecommunications carriers, messaging platforms and other service providers necessary to deliver communications and operate our Services) are contractually obligated to handle the data in ways approved by WestCX. We may use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development).
    • where necessary to provide and improve our Services, subject to appropriate contractual and legal safeguards. Separately, we may share aggregated or de-identified information that does not identify individuals, as described above.
    • To provide your Personal Information to business partners in case you purchase services of third parties from WestCX (“Third Party Services”). Third Party Services are not directly controlled, operated or maintained by WestCX and WestCX’s Privacy Statement does not apply to such Third-Party Services. For any Third-Party Services you purchase from WestCX, we recommend you consult the respective privacy statements of the Third-Party Services providers to determine how they will handle your Personal Information.
    • To comply with applicable law, regulation, legal process, or enforceable governmental request (such as a subpoena or court order). We review such requests to ensure they are valid, legally binding, and appropriately scoped. Where permitted, we will limit the disclosure to only the Personal Information necessary to comply with the request. Where appropriate and not legally prohibited, we will notify you or the customer on whose behalf we process the Personal Information prior to disclosure, so that they may seek to challenge or limit the request. We reserve the right to object to or challenge requests that we believe are unlawful, overbroad, or otherwise inappropriate.
    • If we have a good faith belief it is reasonably necessary to protect the rights, property or safety of you, our other users, WestCX or the public.
    • If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may pass your Personal Information to a successor or affiliate.

How do we protect your Personal Information?

We are committed to protecting your Personal Information once we have it. We implement industry standard physical, administrative and technical security measures. If, despite these efforts, we learn of a security breach involving your Personal Information, we’ll investigate and make all legally-required notifications without undue delay and, where required by law, within applicable regulatory timeframes so appropriate protective steps can be taken.

How can you protect your Personal Information?

Electronic communication (e.g., email, text messaging, online chat or instant messaging, etc.) you send to us may not be secure unless we advise you in advance that security measures will be in place prior to you transmitting the information. For this reason, we ask you do not send Personal Information such as financial information, social security numbers or passwords to us through unsecured electronic communication. Users should also take care with how they handle and disclose their Personal Information.

The WestCX websites may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the WestCX websites are provided solely as a convenience to you. If you use these links, you will leave the WestCX websites. WestCX has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, WestCX does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked from the WestCX websites, you do this entirely at your own risk. Remember, this Privacy Statement only applies to WestCX. When you are no longer on a WestCX website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.

How do we keep your healthcare information private?

WestCX is required by law to maintain the privacy of PHI. WestCX may process PHI on behalf of its customers in accordance with applicable law, including the Health Insurance Portability and Accountability Act (“HIPAA”), and pursuant to applicable Business Associate Agreements. Where WestCX processes PHI on behalf of a customer, that customer is responsible for providing any required HIPAA notices to individuals. Depending on how our Services are used, we may process other Sensitive Personal Information. Such information is processed only as permitted by applicable law and contractual safeguards.

Does WestCX use cookies or other tracking technologies?

Our website uses cookies and similar tracking technologies, including pixels and scripts, to support site functionality, analyze usage, and support our marketing efforts. These technologies may be used by us and our third-party partners to understand how users interact with our Services, measure performance, and deliver WestCX content or advertisements tailored to your interests. Where required by applicable law, we will obtain your consent before using non-essential cookies or tracking technologies. You can manage your preferences through our cookie consent banner.

Most browsers are initially set to accept cookies. Where required by law, we will obtain your consent before placing non-essential cookies or similar technologies on your device. You can manage your own cookie preferences by using your browser settings. You may browse some WestCX websites without accepting cookies from WestCX; however, you may not be able to take full advantage of the functionality of the websites or the Services if you do so. Other Services, particularly those which require a login and password, require cookies and cannot be used when you have disabled cookies in your browser.

How does WestCX ensure compliance with legal obligations?

WestCX complies with applicable privacy and data protection laws in the jurisdictions in which it operates. Our customers act as data controllers (the entities that determine the purposes and means of processing Personal Information) and we act as a data processor (the entity that processes Personal Information on behalf of the data controller).

We’re a global organization and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your Personal Information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. The whole or any part of your Personal Information in connection to the Services may be processed by WestCX, its affiliates and subcontractors in the United States, the Philippines, India, Canada and the rest of the world, and may be transferred outside the country in which you provided the Personal Information. Where Personal Information is transferred internationally, we implement appropriate safeguards, including technical and organizational measures, to protect the data against unauthorized access, including access by public authorities. WestCX uses Standard Contractual Clauses approved by applicable regulatory bodies as an international data transfer mechanism. No matter what country your Personal Information is in, we comply with applicable law and will also abide by the commitments we make in this Privacy Statement.

Data Analytics

We provide business to business communication technology Services and may use aggregated or de-identified information derived from Personal Information or Anonymous Information to deliver data analytics services, which may include transforming, examining, cleansing and modelling data in order to support decision making, determining useful information and informing conclusions. Specifically, data analytics are intended to include the following data sharing and recommendations across our various lines of business:

    • Enrich and validate contact information provided by customers;
    • Aggregation of data to identify trends and benchmarks;
    • Provide recommendations;
    • Help to understand usage, adoption and engagement;
    • Increase and demonstrate return on investment of customer investments; and
    • Give insight to customer analytics to develop new customers and expand existing customer relationships.

We may use aggregated or de-identified information derived from Personal Information or Anonymous Information to analyze usage, improve and support our Services, develop new features and train and improve our artificial intelligence and machine learning models and capabilities. We do not use such data in a manner that identifies individual users or customers without authorization.

Data created or existing from data analytics is intended only for use by you or our customers. Such data may not be resold, reused or shared with third parties without prior written consent from WestCX, and nothing in this section limits any individual's rights with respect to their Personal Information as described in this Privacy Statement.

What choices do you have regarding your Personal Information?

We are aware you have several rights in respect to how we process your Personal Information, which include but are not limited to, a right to access your Personal Information, be forgotten, restrict and/or object to processing in some circumstances and request your Personal Information be transferred to you or your nominated third party.

You may choose not to have your information disclosed to a third party (unless WestCX is legally required to share it). You may also choose to not have your information used for a purpose materially different than the purpose for which it was originally collected or subsequently authorized by you.

We will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated. We may deny a request to delete your data if we have legal obligations to retain it. Any such data will be subject to our standard retention guidelines.

To correct inaccuracies in your Personal Information, limit purpose of use and disclosure, delete your Personal Information, or for any other requests or questions, please contact us as directed in the “How to Contact Us” section below. Once we have verified your identity, we will complete the request from you or an authorized agent you have designated. We will make all efforts to verify your identity using information we already have but may need to request additional data if we are unable to make the verification on this data alone. If you designate an agent to make requests for you, we reserve the right to ask for proof of the agency.

You may withdraw consent at any time where processing of your Personal Information is based on consent.

You may lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing violates applicable law.

WestCX will not discriminate against any individual for exercising their privacy rights outlined above.

If your Personal Information has been provided to WestCX by one of our customers in connection with Services they use, you should contact that organization directly to exercise your rights. We will assist our customers in responding to such requests as required by applicable law and our contractual obligations.

What if we change this Privacy Statement?

We may need to update this Privacy Statement from time to time. Unless otherwise required, the updates will be posted online. To make your review more convenient, we will post an effective date at the top of the page. If we make material changes to how we process Personal Information, we will provide appropriate notice prior to such changes taking effect. Where required by applicable law, we will obtain your consent for any new or expanded processing activities that rely on consent as the legal basis for processing.

How to Contact Us?

If you want to make a correction to your Personal Information, or you have any questions about our privacy statement, please contact our Data Protection Officer by emailing privacy@west.com or by mail at:

WestCX
Privacy and Legal Department
PO Box 541178
Omaha, NE 68154

Attn: Data Protection Officer