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 [email protected]. 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 [email protected].
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 [email protected]. 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: [email protected]