Effective: May 18, 2018
- 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:
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:
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
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.
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.
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.
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.
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.
Frame Technology, Inc.
52 Walker Street
New York, NY 10013