Privacy Policy

Last Updated: May 29, 2025

In order to ensure transparency and give you more control over your personal information, this privacy policy ("Privacy Policy") governs how we, Frame, Inc. ("Frame", "we", "our" or "us") use, collect and store personal information that we collect or receive from or about you ("you") in connection with www.framesecurity.com (the "Website").

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of contents:

• What personal information we collect, why we collect it, and how it is used
• How we protect and retain your personal information
• How we share your personal information
• Your privacy rights
• International transfers of personal information
• Use by children
• Interaction with third party products
• Specific provisions applicable under California privacy law
• Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

We Process the Following Personal Information:

Personal information provided through the Website. When you use the Website, we collect and process full name, email address, when you interact with the Website.

Personal information automatically collected. We automatically collect certain information through your use of our Website, such as cookie, pixels, tracking technologies and similar identifiers ("Technologies"), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other personal information about actions taken through the use of the Website.

We process personal information for the following purposes:

• To allow you to make use of our Website. We will use your personal information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal information to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us; (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience.
• For Administrative Purposes. Frame use your personal information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with our Website and promote our services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) for legal and accounting reasons; and (v) to generally administer the our Website.
• To Market our Website. Frame uses personal information to market the Frame Website and services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) developing and marketing our Website, products and services, and to measure interest in Frame's Website; (iii) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.
• Security purposes. Some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
• De-identified and Aggregated Information Use. In certain cases, we may or will anonymize, aggregate and/or de-identify part or all of your personal information. This data may be used for both internal and external purposes, such as analyzing, enhancing and improving Frame's Website and services (including through the use of artificial intelligence) and for research purposes. We may also share this aggregated information and/or disclose it to third parties without restrictions.
• Cookies and Similar Technologies. We use Technologies to automatically collect information through the Website, which in certain cases could be considered personal information. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website. Most browsers allow you to change your cookie settings, usually found in the "options" or "preferences" menu. For more information, consult your browser's "Help" function or online documentation. For example, www.allaboutcookies.org/manage-cookies/. Please note that refusing cookies may limit your use of our Website's features.

The lawful bases we rely on for processing personal information are (if and when applicable):

• The data subject has given consent to the processing of his or her personal information;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
• Processing is necessary for the purposes of legitimate interest.

HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your personal information. Your personal information will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information as follows:

• The personal information Frame gathers may shared with our partners and other third parties.
• We also share personal information about you with our affiliated companies.
• We use third party service providers to process your personal information for the purposes outlined above, including, without limitation:
  • With cloud service providers for hosting purposes;
  • With websites and web content creation platforms in order to help us manage and analyze the use of our Website;
  • With email providers, marketing, CRM, other similar tool providers;
  • With artificial intelligence tools and features; and
  • With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
• To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Frame, our services, customers, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
• We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
• We may use or disclose the personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
• If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.
• Where you have otherwise provided your consent to us for sharing or transferring your personal information.

YOUR PRIVACY RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

• You have the right to withdraw consent to the processing, where consent is the basis of processing.
• You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
• You have the right to object to unlawful data processing under certain conditions.
• You have the right to the erasure of past personal information about you (your "right to be forgotten") under certain conditions.
• You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
• You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
• The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by contacting Frame directly or by following the instructions through the unsubscribe options in our email messages.

You can exercise your rights by contacting us at privacy@framesecurity.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

In order to run our business and provide our Website to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by using Standard Contractual Clauses or other lawful mechanisms:

• making sure the destination country has been deemed by the European Commission to provide an adequate level of protection for personal information; and/or
• by executing data onward transfer instruments such as data processing and protection agreements.

USE BY CHILDREN

We do not offer our Website for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provided personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@framesecurity.com.

INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain personal information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@framesecurity.com. Please note that we are only required to respond to one request per customer each year.

CONTACT US

For any questions, concerns, or to exercise your privacy rights, please contact us at: privacy@framesecurity.com

Terms of Use

Last updated: July 2, 2025

Welcome to www.framesecurity.com (together with its subdomains, Content, Marks and services, each as defined below, the “Site”). Please read the following Terms of Use (the "Agreement") carefully before using this Site so that you are aware of your legal rights and obligations with respect to Frame Inc. ("Frame", "we", "our" or "us"). By accessing or using the Site, you expressly acknowledge and agree that you are entering a legal agreement with us and have understood and agree to comply with, and be legally bound by, this Agreement, together with the Privacy Policy which is hereby incorporated into this Agreement by reference (the date of such acceptance, the "Effective Date"). You hereby waive any applicable rights to require an original (non-electronic) signature or delivery or retention of non-electronic records, to the extent not prohibited under applicable law. If you do not agree to be bound by this Agreement, please do not access or use the Site.

1. Background. The Site is intended to provide you with information related to our products and services and to enable you to contact us via the Website.
2. Modification. We reserve the right, at our discretion, to modify this Agreement at any time. Such modification will be effective ten (10) days following posting of the revised Agreement on the Site, and your continued use of the Site thereafter means that you accept those modifications.
3. Ability to Accept. The Site is only intended for individuals aged eighteen (18) years or older. If you are under 18 years please do not visit or use the Site.
4. Site Access. For such time as this Agreement is in effect, we hereby grant you a personal, limited, non-exclusive, non-assignable, non-sublicensable, revocable right to access and use the Site solely for your own personal and non-commercial use, and provided that you comply with this Agreement. Except for the foregoing right, we do not grant you any right or licenses to any of our or a third party's Intellectual Property Rights.
5. Restrictions. As a condition to your right to access and use the Site, you shall not (and shall not permit or encourage any third party to) do any of the following: (a) copy or reproduce the Site; (b) sell, assign, lease, lend, rent, distribute, or make available the Site to any third party, or otherwise offer or use the Site in a time-sharing, outsourcing, or service bureau environment; (c) modify, alter, adapt, arrange, translate, decompile, disassemble, reverse engineer, decrypt, or otherwise attempt to discover the source code or non-literal aspects (such as the underlying ideas, algorithms, structure, sequence, organization, and interfaces) of, the Site; (d) remove, alter, or conceal, in whole or in part, any copyright, trademark, or other proprietary rights notice or legend displayed or contained on or in the Site; (e) circumvent, disable or otherwise interfere with security-related or technical features or protocols of the Site; (f) make a derivative work of the Site, or use the Site to develop any service or product that is the same as (or substantially similar to or competitive with) the Site; (g) publish or transmit any robot, virus, malware, Trojan horse, spyware, or similar malicious item intended (or that has the potential) to damage or disrupt the Site; (i) take any action that imposes or may impose (at our sole discretion) an unreasonable or disproportionately large load on the Site infrastructure, or otherwise interfere (or attempt to interfere) with the integrity or proper working of the Site; (j) use the Site for competitive purposes, and/or on behalf of any person or entity that competes with the activities, services, or products offered by Frame, including but not limited to utilizing the Site to receive information, data, or insights for the development or enhancement of competing services or products; (k) engage in any activity that may excessively burden or disrupt the functioning of the Site or its supporting systems; (l) impersonate another person or entity or use a deceptive identity to mislead others about who you are or who you acting on behalf of; and/or (m) use the Site in any manner that is otherwise malicious, illegal or fraudulent; and/or (n) use the Site to infringe, misappropriate or violate any third party's Intellectual Property Rights (as defined below), or any law.

7. Payments to Frame. Your right to access and use the Site is currently for free, but Frame may in the future charge a fee for certain access or usage. You will not be charged for any such access or use of the Site unless you first agree to such charges, but please be aware that any failure to pay applicable charges may result in you not having access to some or all of the Site.
8. Linking. We permit you to link to the Site provided that: (i) you link to (but do not replicate) any page on this Site; (ii) the hyperlink text shall accurately describe the Content as it appears on the Site; (iii) you shall not misrepresent your relationship with Frame or present any false information about us, and shall not imply in any way that we are endorsing you or any services or products, unless we have given you our express prior consent to do so; (iv) you shall not link from a website which prohibits linking to third parties; (v) the website from which you link to the Site does not contain content that (a) is offensive or controversial (both at our discretion), or (b) infringes any Intellectual Property Rights; and/or (vi) you, and your website, comply with this Agreement and applicable law.
9. Intellectual Property Rights.

1. Content and Marks. The content and information on the Site, including without limitation, the text, documents, articles, brochures, descriptions, products, software, graphics, photos, sounds, videos, links, interactive features, and services (collectively, the "Content"), and (ii) the trademarks, service marks, trade names, service names, trade dress, symbols, brands, and logos contained therein ("Marks"), are the property of Frame and/or its licensors and may be protected by Intellectual Property Rights laws and treaties. “Frame.io”, "Frame", the Frame logo, and other marks are Marks of Frame or its affiliates. All other Marks used or appearing on the Site are the Marks of their respective owners. We reserve all rights not expressly granted in and to the Site.
2. Use of Content. Content on the Site is provided to you for your information and personal use only and may not be used, modified, copied, distributed, transmitted, broadcast, displayed, sold, licensed, de-compiled, or otherwise exploited for any other purposes whatsoever without our prior written consent. If you download or print a copy of the Content you must retain all copyright and other proprietary notices contained therein. In any event you wish to use, publish, copy, distribute, transmit, broadcast, display or otherwise exploit such Content, please be in touch with us at Office@framesecurity.com in order to receive our written consent.

10. Information Description. We attempt to be as accurate as possible. However, we cannot and do not warrant that the Content available on the Site is accurate, complete, reliable, current, or error-free. We reserve the right to make changes in or to the Content, or any part thereof, in our sole judgment, without the requirement of giving any notice prior to or after making such changes to the Content. Your use of the Content, or any part thereof, is made solely at your own risk and responsibility.
11. Third Party Content. The Site may present, or otherwise allow you to view, access, link to, and/or interact with, Content from third parties and other sources that are not owned or controlled by us (such Content, "Third Party Content"). The Site may also enable you to communicate with the related third parties. The display or communication to you of such Third Party Content does not (and shall not be construed to) in any way imply, suggest, or constitute any sponsorship, endorsement, or approval by us of such Third Party Content or third party, or by such third party of us, and nor any affiliation between us and such third party. We do not assume any responsibility or liability for Third Party Content, or any third party's terms of use, privacy policies, actions, omissions, or practices. Please read the terms of use and privacy policy of any third party that you interact with before you engage in any such activity.
12. Privacy. We will use any personal information that we may collect or obtain in connection with the Site in accordance with our privacy policy which is available at https://www.framesecurity.com/privacy. You agree that we may use personal information that you provide or make available to us in accordance with the Privacy Policy.
13. Warranty Disclaimers.

1. This section applies whether or not the services provided under the Site are for payment. Applicable law may not allow the exclusion of certain warranties, so to that extent certain exclusions set forth herein may not apply.
2. THE SITE (WHICH, FOR CLARITY, INCLUDES WITHOUT LIMITATION CONTENT AND MARKS) IS PROVIDED AND MADE AVAILABLE TO YOU ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITH ALL FAULTS, AND WITHOUT ANY REPRESENTATION, WARRANTY, GUARANTEE OR CONDITION OF ANY KIND WHATSOEVER, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, SATISFACTORY QUALITY, QUIET POSSESSION, TITLE, QUALITY OF SERVICE, NON-INFRINGEMENT, OR THAT OTHERWISE ARISE FROM A COURSE OF PERFORMANCE OR DEALING, OR USAGE OF TRADE, ALL OF WHICH ARE HEREBY DISCLAIMED BY US AND OUR LICENSORS AND SUPPLIERS. YOU AGREE THAT WE WILL NOT BE HELD RESPONSIBLE OR LIABLE FOR ANY CONSEQUENCES TO YOU OR ANY THIRD PARTY THAT MAY RESULT FROM TECHNICAL PROBLEMS OF THE INTERNET, SLOW CONNECTIONS, TRAFFIC CONGESTION OR OVERLOAD OF OUR OR OTHER SERVERS.
3. IN ADDITION, NEITHER FRAME NOR ITS LICENSORS OR SUPPLIERS MAKE ANY REPRESENTATION, WARRANTY, GUARANTEE OR CONDITION: (A) REGARDING THE EFFECTIVENESS, USEFULNESS, RELIABILITY, AVAILABILITY, TIMELINESS, ACCURACY, OR COMPLETENESS OF THE SITE; (B) THAT YOUR USE OF, OR RELIANCE UPON, THE SITE WILL MEET YOUR REQUIRMENTS OR EXPECTATIONS; (C) THAT THE SITE WILL BE UNINTERRUPTED, SECURE, ERROR-FREE OR VIRUS-FREE, OR THAT DEFECTS IN THE SITE WILL BE CORRECTED; OR (D) REGARDING THE SATISFACTION OF, OR COMPLIANCE WITH, ANY GOVERNMENT REGULATIONS OR STANDARDS
4. EXCEPT AS EXPRESSLY STATED IN OUR PRIVACY POLICY, FRAME DOES NOT MAKE ANY REPRESENTATIONS, WARRANTIES, GUARANTEES, OR CONDITIONS OF ANY KIND, EXPRESS, IMPLIED, OR STATUTORY AS TO THE SECURITY OF ANY INFORMATION YOU MAY PROVIDE OR ACTIVITIES YOU ENGAGE IN DURING THE COURSE OF YOUR USE OF THE SITE.

14. Limitation of Liability.

1. IN NO EVENT SHALL FRAME OR ANY OF OUR LICENSORS OR SUPPLIERS BE LIABLE UNDER, OR OTHERWISE IN CONNECTION WITH, THIS AGREEMENT, FOR:

1. ANY CONSEQUENTIAL, INDIRECT, SPECIAL, INCIDENTAL, OR PUNITIVE DAMAGES;
2. ANY LOSS OF PROFITS, LOSS OF BUSINESS, LOSS OF REVENUE, OR LOSS OF ANTICIPATED SAVINGS;
3. ANY LOSS OF, OR DAMAGE TO, DATA, REPUTATION, OR GOODWILL; AND/OR
4. THE COST OF PROCURING ANY SUBSTITUTE GOODS OR SERVICES.

2. THE AGGREGATE LIABILITY OF FRAME UNDER, OR OTHERWISE IN CONNECTION WITH, THIS AGREEMENT SHALL NOT EXCEED THE LOWER OF: (A) FIVE U.S. DOLLARS (US $5), AND (B) THE AMOUNTS ACTUALLY PAID BY YOU (IF ANY) TO FRAME DURING THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE DATE ON WHICH YOU BRING YOUR CLAIM.
3. THE FOREGOING EXCLUSIONS AND LIMITATIONS SHALL APPLY: (A) TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW; (B) EVEN IF FRAME HAS BEEN ADVISED, OR SHOULD HAVE BEEN AWARE, OF THE POSSIBILITY OF LOSSES, DAMAGES, OR COSTS; (C) EVEN IF ANY REMEDY IN THIS AGREEMENT FAILS OF ITS ESSENTIAL PURPOSE; AND (D) REGARDLESS OF THE THEORY OR BASIS OF LIABILITY, INCLUDING WITHOUT LIMITATION NEGLIGENCE, MISREPRESENTATION, STRICT LIABILITY, OR OTHER CONTRACT OR TORT LIABILITY.
4. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, or of other damages, and to the extent applicable to you, such exclusions and limitations shall not apply. Furthermore, nothing in this Agreement shall be deemed to exclude or limit liability for death or personal injury resulting from negligence, or for fraud or fraudulent misrepresentation.

15. Indemnity. You agree to defend, indemnify and hold harmless Frame and our affiliates, and our respective officers, directors, employees and agents, from and against any and all claims, damages, obligations, losses, liabilities, costs and expenses (including but not limited to attorney's fees) arising from: (i) your use of, or inability to use, the Site; or (ii) breach of any provision of this Agreement.
16. Term and Termination.

1. This Agreement commences on the Effective Date and shall continue in full force and effect until terminated in accordance herewith (the "Term").
2. We reserve the right to immediately terminate this Agreement, or otherwise modify, suspend or discontinue your access to and use of the Site (or any part thereof), for any reason whatsoever, at any time, and without notice or obligation to you, and you agree that Frame shall have no liability to you or any third party for any such termination, modification, suspension, or discontinuance. If you breach the terms of this Agreement, Frame reserves the right to suspend your access to the Site and its services temporarily until such breach is cured, or indefinitely if deemed to be permitted by Frame. Suspension may occur without prior notice and is at the sole discretion of Frame.
3. You may terminate this Agreement at any time and for any reason. If you object to any term or condition of this Agreement or any subsequent changes thereto, or become dissatisfied with the Site in any way, your sole remedy is to terminate this Agreement and to immediately discontinue use of the Site.

17. Consequences of Termination and Survival. Upon termination of this Agreement your right to access and use the Site will automatically terminate and be deemed revoke. Sections ‎9 (Intellectual Property Rights) through ‎23 (Entire Agreement) inclusive shall survive any termination of this Agreement. Termination shall not affect any rights and obligations accrued as of the effective date of termination.

18. Independent Contractors. You and Frame are independent contractors. Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between you and Frame. You must not under any circumstances make, or undertake, any warranties, representations, commitments or obligations on behalf of Frame.

18. Assignment. Frame may assign this Agreement (or any of its rights and/or obligations hereunder) without your consent, and without notice or obligation to you. This Agreement is personal to you, and you shall not assign (or in any other way transfer) this Agreement (or any of your obligations or rights hereunder) without Frame's express prior written consent. Any prohibited assignment shall be null and void.
19. Governing Law and Place of Jurisdiction. This Agreement (including without limitation its validity and formation) shall be governed by, and construed in accordance with, the laws of the State of New York, without regard to any conflicts of laws rules or principles. The United Nations Convention on Contracts for the International Sale of Goods and the Uniform Computer Information Transaction Act shall not apply to this Agreement and are hereby disclaimed. The competent courts of the city of New York, New York shall have the exclusive jurisdiction with respect to any dispute and action arising under or in relation to this Agreement.
20. Severability. If any provision of this Agreement is held by a court of competent jurisdiction to be invalid, illegal, or unenforceable, then: (a) the remaining provisions of this Agreement shall remain in full force and effect; and (b) such affected provision shall be ineffective solely as to such jurisdiction (and only to the extent and for the duration of such invalidity, illegality, or unenforceability), and shall be substituted (in respect of such jurisdiction) with a valid, legal, and enforceable provision that most closely approximates the original legal intent and economic impact of such provision.
21. Remedies. Except as may be expressly stated otherwise in this Agreement, no right or remedy conferred upon or reserved by any party under this Agreement is intended to be, or shall be deemed, exclusive of any other right or remedy under this Agreement, at law or in equity, but shall be cumulative of such other rights and remedies.
22. Waiver. No failure or delay on the part of any party in exercising any right or remedy under this Agreement shall operate as a waiver thereof, nor shall any single or partial exercise of any such right or remedy preclude any other or further exercise thereof or the exercise of any other right or remedy. Any waiver granted hereunder must be in writing (for waivers by you, emails will be acceptable; for waivers by Frame, the writing must be duly signed by an authorized representative of Frame), and shall be valid only in the specific instance in which given.
23. Entire Agreement. This Agreement represents the entire agreement between Frame and you with respect to the subject matter hereof, and supersedes and replaces any and all prior and contemporaneous oral and/or written agreements, understandings and statements between you and Frame with respect to such subject matter. You acknowledge and agree that in entering into this Agreement you have not relied on any statement or representation (whether negligently or innocently made) not expressly set out in this Agreement; for example, statements and explanations in any FAQs or other marketing material on the Site (defined below) are for convenience only, and are not binding or a part of this Agreement.

Candidates Privacy

FRAME CANDIDATES PRIVACY NOTICE

Last updated: February 16, 2026

Please note that any reference in this notice to “Frame”, “we”, “us”, “our” refers to Frame Inc., and Frame Labs Ltd., together “Frame Group”. Frame has prepared this Candidate Privacy Notice (“Notice”) to be provided to you as Frame’s job candidate.

In connection with your application for a position with Frame, Frame needs to process certain personal data in order to assess your application, communicate with you during the recruitment process, and comply with legal and regulatory obligations. There are also statutory and other requirements we have to comply with in relation to your application. If we are not able to carry out certain processing activities described in this Notice, we may not be able to process your application.

This Notice is intended to inform you about the types of personal data Frame may collect, process, and use about you as a candidate, the circumstances in which your data may be used, and your rights regarding your personal data and how you can exercise them.

As with many other company policies, this document is not part of your potential contract of employment, and we may update it from time to time, for example if we implement new systems or processes that involve the use of personal data. With respect to Israeli law, the provision of your personal data is voluntarily, and its provision is subject to your consent and free will. If you choose not to provide us with personal data for which your consent is required, this may affect our ability to review and assess your candidacy and we will not be able to carry out certain processing activities described in this Notice, and therefore may not be able to process your application.

Frame acts as the controller of the relevant database(s) in which candidates’ personal data is stored and processed. The database is used to review applications for positions at Frame and to manage our screening and recruitment processes.

Important note: Nothing in this privacy notice is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

1. WHAT PERSONAL DATA WE COLLECT AND PROCESS

The types of personal data we collect include, among others: your full name, address, email address, phone number, date of birth, CV/resume, LinkedIn profile URL, personal website, cover letter, portfolio, employment and education history, academic records, professional qualifications, references, and other information you provide during interviews or assessments that you would like to share about yourself (e.g., military service). We may also collect information generated during the recruitment process, such as interview notes, assessment results, communications with you, and background check results (where permitted by law). If you receive and accept an offer of employment with Frame, you may be asked to provide additional proof of your identity and, in some jurisdictions, proof of your right to work (failure to provide this will mean that the company is unable to hire the applicant).

2. FOR WHAT PURPOSE WE PROCESS THE PERSONAL DATA

• Frame collects and uses the candidates’ personal data for the purpose of considering and verifying your suitability for employment. You are not obligated to provide us with the above-mentioned information, and you may refuse to do so.
• Any offer and commencement of employment is conditional on the verification, to the satisfaction of Frame, of the information the applicant provides as part of their application and Frame being able to obtain satisfactory references. If the applicant receives and accepts an offer of employment with Frame, they will undergo pre-employment screening involving verification of the details as specified below.
• Frame or an independent agent acting on behalf of Frame, may verify the information provided by you and carry out further inquiries which may include, a CV check (e.g., to call your previous employers) and gap analysis, a verification of your highest education, a reference check, proof of relevant qualifications, a professional membership check, or a media search (which may include social media and search engine searches). If the applicant fails to supply personal data which Frame requires in order to satisfy these checks, Frame might be unable to employ the applicant.
• Where the applicant’s personal history requires verifications to be carried out for countries where they have worked and resided, their data may be sent and processed in those relevant jurisdictions, subject to applicable data security and transfer requirements.
• If the applicant is successful in obtaining employment at Frame, relevant personal data will be retained by Frame in order to facilitate the employment.

• If the applicant is not successful then any personal documents that they have submitted to Frame or background check vendors (if applicable) will be destroyed in accordance with Frame’s data retention and deletion policy.
• To improve our recruitment processes and candidate experience.
• If the applicant has any questions, they can contact privacy@framesecurity.com

3. HOW DO WE COLLECT THIS INFORMATION?

In most cases, Frame collects personal data directly from you during the recruitment process. Additionally, Frame may also collect personal data from other members of the Frame Group, recruitment agencies, background check providers or criminal wanted lists (to the extent permitted by law), or publicly available sources (e.g., LinkedIn). Our recruitment process is not intended for individuals under the age of 18.

4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In certain cases, your personal data may be shared with other entities of the Frame Group, which may be in other countries (e.g., Israel or the US). Frame may also share your personal data with third parties such as regulators, courts, banks or competent authorities where required by law, to comply with any legal obligation, or to protect its legitimate rights, property, or the safety of its employees, candidates, customers, or others, provided there is no legal reason preventing such sharing. Furthermore, Frame may share or allow access to your personal data by its vendors and service providers assisting Frame in the recruitment and employment process, including, without limitation, applicant tracking systems and artificial intelligence tools as detailed in our trust center. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events. Frame will use commercially reasonable efforts to ensure that equivalent data protection applies, or that suitable safeguards are in place to protect your data, such as through the use of appropriate contractual measures.

5. HOW LONG WILL FRAME KEEP PERSONAL DATA FOR?

The applicant’s information will be handled in accordance with Frame’s data retention and deletion policy. Your personal data will be stored until we proactively delete it from our records, or until you send a valid deletion request. If you are not hired, we may retain your information for a limited period to consider you for future opportunities, unless you request deletion. Please note that in some circumstances we store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

6. DATA SECURITY.

Frame implements appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures are designed to ensure a level of security appropriate to the risks presented by the processing of your personal data. Access to your personal data is limited to those who have a business need to know and are subject to confidentiality obligations.

7. DATA TRANSFERS.

If we transfer your personal data outside of your country of residence, we will take appropriate measures to ensure that your personal data is protected in accordance with applicable privacy laws. With respect to Israeli law, in certain cases, third parties to whom your personal data may be transferred as described above may be located outside of Israel, including in the United States. You hereby acknowledge and consent that personal data relating to you may be transferred to and stored outside the borders of Israel, in accordance with applicable law and for the purposes set out above.

8. WHAT RIGHTS DO I HAVE IN RESPECT OF MY PERSONAL DATA?

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

1. You have the right to request access to your personal data held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal data about you. We will promptly correct any information found to be incorrect.
2. You have the right to object to unlawful data processing under certain conditions.
3. You have the right to the erasure of past personal data about you (your “right to be forgotten”) under certain conditions.
4. You have the right to demand that we restrict the processing of your personal data, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal data is inaccurate.
5. You have the right to data portability of personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.

If you wish to exercise your privacy rights under applicable law, or if you have concerns or questions regarding this Notice, you can send an email to privacy@framesecurity.com. We will review and respond to your request in accordance with applicable laws and within the timeframes required by law. Please note that, in order to verify your identity or the authority of your request, we may need to request additional information from you before processing your request. We will not discriminate against you for exercising any of your privacy rights.

9. CAN FRAME UPDATE THIS NOTICE?

We reserve the right to update this Notice at any time, and we will provide you with a new Notice when we make any substantial updates and take any additional steps as required by applicable law.

10. WHO CAN I CONTACT ABOUT THIS?

If you have concerns or questions regarding this Notice or if you would like to exercise your rights as a data subject, you can send an email at privacy@framesecurity.com.