Privacy Policy

Last updated: August 30, 2023

This Privacy Policy describes how Frame collects, uses, and discloses information, and what choices you have with respect to the information.

Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:

• • organizing it into the sections listed in the Table of Contents below,
  • providing a series of examples that help illustrate how the policies may be implemented by Frame, and
  • defining and capitalizing a few terms that are used more than once for simplicity and brevity.

When we refer to “Frame“, we mean the Frame entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Table of Contents:

• • Applicability of this Privacy Policy
  • Information We Collect and Receive
  • How We Use Information
  • Data Retention
  • How We Share and Disclose Information
  • Security
  • Age Limitations
  • Changes to this Privacy Policy
  • Identifying the Data Controller and Processor
  • Your Rights
  • Data Protection Authority
  • Contacting Frame

Applicability Of This Privacy Policy

This Privacy Policy applies to Frame’s online workplace productivity tools and platform, including the associated add-ons to third-party platforms (collectively, the “Services“), frame.ai and other Frame websites (collectively, the “Websites“) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Frame. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Frame’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Frame platform (“Third Party Services“), or any other third party products, services, or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “Customer Agreement“), including the processing of any messages, files, or other content submitted through Services accounts (collectively, “Customer Data“). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer“) controls their instance of the Services (their “Frame Contexts“) and any associated Customer Data. If you have any questions about specific Frame Context settings and privacy practices, please contact the Customer whose Frame Context you use. If you have an account, you can check your Frame Context for contact information of its owner owner(s) and administrator(s). If you have received an invitation to join a Frame Context but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect And Receive

Frame may collect and receive Customer Data and other information and data (“Other Information“) in a variety of ways:

• • Customer Data. Customers or individuals granted access to a Frame Context by a Customer (“Authorized Users“) routinely submit Customer Data to Frame when using the Services.
  • Other Information. Frame also collects, generates, and/or receives Other Information:
    1. Frame Context and Account Information. To create or update a Frame account or an account within another Frame Context, you or your Customer (e.g., your employer) supply Frame with an email address, phone number, password, domain, and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Frame (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
    2. Usage Information.
       • Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Frame logs the Frame Contexts, channels, rooms, groups, people, features, content, and links you interact with, the types of files shared, and what Third Party Services are used (if any).
       • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences, and cookie data.
       • Device information. Frame collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, and unique device identifiers. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
       • Location information. We receive information from you, your Customer, and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Frame may also collect location information from devices in accordance with the consent process provided by your device.
    3. Cookie Information. Frame uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
    4. Third Party Services. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Frame Context. Once enabled, the provider of a Third Party Service may share certain information with Frame. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Frame. When a Third Party Service is enabled, Frame is authorized to connect and access Other Information made available to Frame in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
    5. Contact Information. In accordance with the consent process provided by your Frame Context, any contact information that an Authorized User chooses to import (such as an address book from a device) may be collected when using the Services.
    6. Third Party Data. Frame may receive data about organizations, industries, Websites visitors, marketing campaigns, and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to legal entities, zip codes, or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
    7. Additional Information Provided to Frame. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity, or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Frame.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information“). However, certain Information is collected automatically and, if some Information, such as Frame Context setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Frame in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Frame is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Frame Context, assign roles and configure settings, access, modify, export, share, and remove Customer Data and otherwise apply its policies to the Services.

Frame uses Other Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Frame uses Other Information:

• • To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
  • As required by applicable law, legal process, or regulation.
  • To communicate with you by responding to your requests, comments, and questions. If you contact us, we may use your Other Information to respond.
  • To develop and provide search, learning, and productivity tools and additional features. Frame tries to make the Services as useful as possible for specific Frame Contexts and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels, or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
  • To send emails and other communications. We may send you service, technical, and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Frame. These are marketing messages so you can control whether you receive them.
  • For billing, account management, and other administrative matters. Frame may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Frame may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Frame will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Frame Context level or other level. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Frame may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Frame to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share And Disclose Information

This section describes how Frame may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Frame does not control how they or any other third parties choose to share or disclose Information.

• • Customer’s Instructions. Frame will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
  • Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Frame Contexts. For example, an Authorized User’s email address may be displayed with their Frame Context profile.
  • Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Frame Context activity, or accessing or modifying your profile details.
  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth at Frame Subprocessors.
  • Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Frame may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Frame and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
  • Corporate Affiliates. Frame may share Other Information with its corporate affiliates, parents, and/or subsidiaries.
  • During a Change to Frame’s Business. If Frame engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Frame’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Frame customer the average amount of time spent within a typical Frame Context.
  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how Frame responds to requests to disclose data from government agencies and other sources.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Frame or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With Consent. Frame may share Other Information with third parties when we have consent to do so.

Security

Frame takes security of data very seriously. Frame works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process, and store, and the current state of technology. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Overview. Given the nature of communications and information processing technology, Frame cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

Age Limitations

To the extent prohibited by applicable law, Frame does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.

Changes To This Privacy Policy

Frame may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Frame will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Frame is the processor of Customer Data and the controller of Other Information. Frame Technology, Inc., a US company based in New York, NY is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Frame Contexts established for Customers worldwide.

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance. Please check your Frame Context(s) for Customer contact information.

To the extent that Frame’s processing of your Personal Data is subject to the General Data Protection Regulation, Frame relies on its legitimate interests, described above, to process your data. Frame may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Frame’s use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Frame’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority.

Contacting Frame

Please also feel free to contact Frame if you have any questions about this Privacy Policy or Frame’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at support@frame.ai or at our mailing address below:

Frame Technology, Inc.
169 Madison Ave, Suite 11243
New York, NY 10016