PRIVACY POLICY

“Personal Information” is any information that can identify or is linked to a specific individual, including, without limitation, your name, mailing address, email address, telephone number, credit card number, debit card number, bank account number, demographic, location and household information. We collect the following types of Personal Information about you:

Personal Information you provide us directly
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Certain portions of the Services may require that you submit some Personal Information before using those portions of the Services. We may request certain Personal Information when you register for a Frame One account or when you contact us directly, such as your first and last name, preferred name, preferred pronouns, telephone number, email address and geographical details. We may also collect certain professional, education or other demographic information, such as your date of birth, title or occupation, job function or expertise, company name and other information about the company where a user may work. In addition, when purchasing our Services, we collect certain commercial information, such as payment/billing information (payment card type, last 4 digits of payment card, billing address and contact information) and purchase history.

We also collect any feedback you send us and may collect Personal Information you provide in Customer Material you send to Frame One or which Frame One receives through your use of any Services, such as text and photos you upload to the Services or provide through customer support communications. We use this Personal Information to operate, maintain, and provide the features and functionality of the Services to you, to communicate with you, and to address any concerns you may have about the Services.

You are not required to provide this information. Please be aware, however, that if you do not provide the Personal Information requested, you may not be able to access or use all or portions of our Services.

Personal Information we receive from third parties
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Frame One does not sell to third parties the information you have submitted through your use of the Services that identifies you personally.

At times, Frame One may collaborate with third parties such as Third Party Service providers to offer certain services, which may require the sharing of your Personal Information with them to access those services, and such third parties may pass certain Personal Information about your use of its service to us.

While Frame One will handle any Personal Information it receives in accordance with this Privacy Policy, Frame One will not be responsible for the information you submit to Third Party Service providers. Please be aware that this Privacy Policy does not apply to your activities on these Third Party Services or any information you disclose to these third parties. We encourage you to continuously review, and if necessary, adjust your privacy settings on Third Party Services before linking or connecting them to our Services. You may also unlink your third party account from the Services by changing your settings on the Third Party Service. If you unlink your Third Party Service account, we will no longer receive Personal Information collected about you in connection with that Third Party Service.

Personal Information we collect from you automatically
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We may collect certain Personal Information automatically when you use the Services, such as your IP address, type of browser, domain server, mobile device ID, the date and time you visit, information regarding the links you click on our Services, the content you view, how you navigate the Services, and other customary server log information used to help us measure traffic and usage trends for the Services. This helps us improve our websites and deliver a better and more personalized service, including enabling us to (i) estimate audience size and understand usage patterns; (ii) store your preferences; (iii) expedite your searches; and (iv) recognize you upon your return to our website.
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We may also collect certain Personal Information for aggregated or statistical data analytics purposes. This anonymous data helps Frame One understand and know its customer base better. That anonymous data may be provided to third parties but never in such a way as to identify you personally.
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Personal Information derived from cookies and taken from other similar technologies
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When you use our Services, we will send cookies – small data files that are placed on your computer or mobile device when you visit the Services – and other similar technologies to your computer that uniquely identifies your browser. These cookies allow us to help you log in to the Services faster, enhance your navigation of our website, remember your preferences and generally improves the content and offerings across our Services. They also provide us with information about how you use the Services (e.g., the pages you are on, the content you view, and the links you click) and allow us to track your usage of the Services.

Some content or applications on our Services are served by Third Party Services providers. The Third Party Services providers may also use cookies to collect information about you when you use our Services. The information the Third Party Services providers collect may be associated with your Personal Information or they may collect information, including your Personal Information, and collect information about your online activities over time and across different websites and other online services.

You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Services may not function properly if these cookies are refused, disabled, or deleted. For more information on how we use cookies and other similar technologies and how you can control them, please read Section 4 (Cookies) below.

In addition to the purposes of collection described above, we use the Personal Information we collect about you to operate our business and for a variety of purposes, including the following:

Who Your Personal Information is Shared With
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We share your Personal Information with third parties retained in connection with the provision of our Services to you and so that we can provide the Services to you in an efficient and safe manner. We work with different types of third parties, presently including:

Cookies are small bits of information that are stored by your computer’s web browser to collect standard Internet log information and visitor behavior patterns. When you use the Services, we may collect information from you automatically through cookies or similar technology. For further information, including how to see what cookies have been set and how to manage and delete them, visit aboutcookies.org or allaboutcookies.org.

What Types of Cookies We Use
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While there are a variety of cookie types, we use the following:

We employ analytics services such as Google Analytics to gather and analyze data related to how you use the Services. For more information on Google’s practices, please visit: https://www.google.com/policies/privacy/partners. Additionally, to safeguard against spam and automated abuse, we utilize Google’s invisible reCAPTCHA application across our Services. This tool may utilize cookies and collect various data points including IP address, date, time, language, screen size and resolution, and mouse movements. The usage of the reCAPTCHA tool and any data collected through it are governed by Google’s privacy policy, accessible at: https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms.

How to Manage Cookies
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You may be able to refuse or disable cookies by adjusting your web browser settings.  Because each web browser is different, please refer to the instructions provided by your web browser (usually provided in the “help” section of every browser).  
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Useful links for browsers:
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Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies‍
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en‍
Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored‍
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
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Please note that if you choose to refuse, disable, or delete these cookies, some functionalities of the Services may no longer be available to you.

Protecting the security of your Personal Information is important to us. We take precautions including commercially reasonable technical, physical and administrative measures to help protect Personal Information from loss, theft, unauthorized access, misuse, disclosure, alteration and destruction. While we generally follow our standards to protect Personal Information, no data storage system or transmission of data over the Internet can be guaranteed to be one hundred percent (100%) secure. As a result, we cannot guarantee or warrant the security of any information you provide us or we collect about you. To protect the security of your Personal Information, we take reasonable steps to verify your identity before granting you access to your account. You can help us to keep Personal Information about you accurate by providing us with notice of any change to your email address, geographical details or phone number.
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Furthermore, please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

Should any Personal Information under our control be compromised due to a breach of security, Frame One will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose Personal Information have been compromised and take other reasonable measures, in accordance with applicable laws and regulations.

You have certain rights and choices with respect to your Personal Information we maintain about you, subject to local data protection laws. We will process your request as set forth below, however, our data retention policies and legal and audit obligations may require us to maintain some of your information (e.g., to be able to contact you to fulfill your requests).

You Control Your Account Information and Settings
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You may access and update your account information and your Personal Information contained therein by logging into your account and changing your profile settings. If you have any questions about reviewing or modifying your account, or would like to make a request that we delete your Personal Information contained therein, you may contact us directly at [email protected].

If you are a resident of California, please read Section 12 (California Users’ Privacy Rights) below.

Unsubscribing and Opting Out of Communications

You have the option to discontinue receiving communications from us. You may also withdraw your consent at any time prior to our collection, use and disclosure of your Personal Information subject to legal or contractual obligations and on reasonable notice. Where you no longer want us to use your Personal Information, you may withdraw your consent by emailing us at [email protected]. If you decide to withdraw your consent to our collection, use and disclosure of your Personal Information, we may not be able to provide you with all the services you may request or require from Frame One.

To the extent permitted by applicable law, we retain your profile information for a commercially reasonable time after termination or deactivation of your account with us, and for as long as we have a valid purpose to do so. In particular, we will retain your Personal Information in order to comply with our legal and audit obligations, in addition to backup and archival purposes.

Our Services are not intended to be used by children, and we do not wish to receive data from children. We do not knowingly collect or solicit Personal Information from children. If you are a child under the age of eighteen (18), please do not attempt to register for or otherwise use the Services or send us any Personal Information. If we become aware that we have collected Personal Information from a child under the age of eighteen (18), we will delete their Personal Information as quickly as possible. If you are a parent or guardian and believe your child has provided us with Personal Information, please contact us by emailing us at [email protected], and we will take measures to delete such Personal Information from our systems as quickly as possible.

The Services may contain links to websites, services or products offered by third parties outside Frame One. We do not control these third party websites, services or products. Accordingly, we are not responsible for the practices employed by websites, services or products linked to or from the Services, including the information or content contained therein. When you navigate away from the Services to another website, this Privacy Policy will no longer apply to third party websites, services or products, and any information that the third party collects from or about you will be governed by the privacy policies and practices of that third party. You should always review and understand the privacy policies and practices of third parties before disclosing any Personal Information to those third parties.

In addition, you acknowledge that we are not responsible for, and we do not exercise control over any third parties that you authorize to access your Customer Material. If you are using a third party website or service, and you allow such a third party access to your Customer Material, you do so at your own risk.

Your Personal Information may be collected, transferred to, and stored by us in the United States and by our affiliates and third parties disclosed above, that are based in other countries, including the United Kingdom. Therefore, your Personal Information may be processed outside your country or jurisdictions. The data privacy and protection laws in such places may not be as comprehensive as those in your country or jurisdiction. By using the Services or otherwise providing us with your Personal Information, you acknowledge that you fully understand and consent to: (i) the transfer and storage of your Personal Information in servers located outside your resident jurisdiction and, to the extent you are a resident of a country other than the United States, that you consent to the transfer of such data to the United States; and (ii) the processing of your Personal Information in accordance with this Privacy Policy.

Information for European Data Centers

In addition to the rights discussed above, under the General Data Protection Regulation (GDPR), you may have certain rights set forth below. For more information about these rights, or to submit a request, please email us at [email protected]. For purposes of this section, “personal information” and “processing” shall be used as they are defined in the GDPR. Frame One will be the controller with regard to personal information it collects.

Be Informed about Our Use of Your Personal Information – Section 1 (Personal Information We Collect and Why) above details the personal information that we collect from you. Frame One will only process your personal information if it has a lawful basis for doing so, including consent, contractual necessity and to facilitate its “legitimate interests” or the legitimate interest of others. Section 2 (How Your Personal Information is Used) above explains how we use your personal information.

Access Your Personal Information, Correct Mistakes and Deletion Rights – You also have the right to access your personal information held by us and to request rectification of inaccurate personal information. You further have the right to have the data collected by us erased.

Data Portability – You can request a copy of your personal information in a commonly used, machine-readable format. You can also request that your personal information be transmitted directly from one data controller to another, where technically feasible.

Object to Processing of Personal Information – You can contact us to object to the processing of your personal information for certain purposes.

Restriction on Processing of Personal Information – You can request that we restrict further processing of your personal information.

Right to File Complaint – You have the right to file a complaint with the supervisory authority of the member state where you reside or where the alleged infringement took place.

To Not be Profiled – You have the right not to be discriminated against for exercising your rights described above.

The California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 and its implementation regulations, as amended or superseded from time to time (CPRA) requires us to provide California consumers with some additional information related to how we collect, use, retain, and disclose Personal Information as well as describe additional rights, which are summarized below.
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For purposes of this Section 12, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CPRA. Personal Information does not include information that is publicly available (as defined by the CPRA), deidentified or aggregated or otherwise excluded from the scope of the CPRA.

Sources of Personal Information We Collect

We collect Personal Information about you from the following categories of sources:

Business or Commercial Purposes for Collecting Personal Information

We process your Personal Information in accordance with the specific business and commercial purposes below:

Disclosure, Sale or Sharing Personal Information

We disclose your Personal Information to the following categories of third parties:

Data Retention

To the extent permitted by applicable law, we keep your profile information for a reasonable period after your account is terminated or deactivated, and as long as we have a valid purpose. Specifically, we retain your Personal Information to meet legal and audit requirements, as well as for backup and archival purposes.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights:

How to Exercise Your Rights

To exercise your right to know, correct and delete under the CPRA, please submit your request by emailing us at [email protected]. We will handle your request in accordance with applicable law, considering the nature and sensitivity of the Personal Information involved. In some cases, we may reject your request if the applicable law or right does not apply or if there is an exception. To verify your identity and prevent fraud, we might ask for additional Personal Information like your name and email. If you have a password-protected account, we will use our authentication methods and may ask you to re-authenticate before disclosing, correcting, or deleting your Personal Information.
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You may appoint an authorized agent to exercise some of your rights. Notwithstanding the foregoing, in order to assist in the protection of the security of your Personal Information, the authorized agent must send us a request that: (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information; and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to such request. Each request that meets both of these conditions will be considered a “Valid Request”. We will only use Personal Information provided in a Valid Request to verify your identity and to complete your request. Please note that you are not required to have an account with us in order to submit a Valid Request.

If you are a resident of Colorado, Connecticut, Utah or Virginia, we have certain obligations, and you have certain rights with respect to your Personal Data (as defined below). This Section 13 applies to: Colorado residents from whom we collect Personal Data as a controller under the Colorado Privacy Act as amended or superseded from time to time (ColoPA); Connecticut residents from whom we collect Personal Data as a controller under the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (CPOMA); Utah residents from whom we collect Personal Data as a controller under the Utah Consumer Privacy Act (UCPA); and Virginia residents from whom we collect Personal Data as a controller under the Virginia Consumer Data Protection Act as amended or superseded from time to time (VCDPA). The ColoPA, CPOMA, UCPA and VCDPA are collectively referred to herein as the “United States Privacy Laws”.
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For purposes of this Section 13, “Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal Data does not include de-identified data, publicly available information (as these terms are defined under the United States Privacy Laws) or any other Personal Data otherwise excluded from the scope of the United States Privacy Laws.
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If you are a Colorado, Connecticut, Utah or Virginia resident, you may exercise the following rights with respect to your Personal Data:

Each of the rights mentioned above may be subject to exceptions and limitations under the United States Privacy Laws. If you wish to exercise one or more of these rights, please email us at [email protected].
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If you are a Colorado, Connecticut, Utah or Virginia resident and we refuse to act on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by emailing us at [email protected].

We may update this Privacy Policy from time to time to reflect our current practices and ensure compliance with applicable laws. If we change our Privacy Policy, we will update the “Published” date at the top of this webpage. We recommend that you review this Privacy Policy from time to time to stay informed of the latest modifications. Your decision to continue using the Services after this Privacy Policy is updated will signify that you have agreed to any new terms.

If you have any questions about this Privacy Policy and our privacy practices, please contact us at: [email protected] or you may write us at: Sandy Patch, 71 W 2Street, 19^th Floor, New York, New York 10010.