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Frame.io’s Privacy Policy

This Privacy Policy describes the policies and procedures of Frame.io, Inc. ("Frame.io", "we", "our" or "us") on the collection, use and disclosure of your information on www.frame.io (the " Site") and the services, features, content or applications we offer (collectively with the Site, the "Services"). We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your " Account"); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Any capitalized terms used but not defined in this Privacy Policy are defined in our Terms of Service available at: https://www.frame.io/terms.

If you are located in the European Union ("EU"), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights under the EU General Data Protection Regulation ("GDPR") with respect to your Personal Data, as outlined below.

Frame.io will be the controller of your Personal Data that is provided, collected and/or processed pursuant to this Privacy Policy. If you have any questions about whether any of the foregoing applies to you, please contact us using the information set forth in the " What If You Have Questions or Concerns Regarding Your Personal Data " section below.

What Does This Privacy Policy Cover?

This Privacy Policy covers our handling practices and how we collect and use the Personal Data you provide when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.

In this Privacy Policy, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through the Services or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Data Do We Collect?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information We Collect From You Directly : We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

Account Information: When you create an Account, you will provide information that could be Personal Data, such as your name, username, password, email address, profile picture, location and company affiliation. You acknowledge that this information may be personal to you, and by creating an Account on the Services and providing Personal Data to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services, but only rarely when we feel such information is important. You may unsubscribe from these messages through your Account settings or via the email communication, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

User Content: Some features of the Services allow you to provide content to the Services, such as written comments. Subject to this Privacy Policy, all content submitted by you to the Services may be retained by us after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Data, as described in this Privacy Policy.

Financial Information: We do not currently collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company, Stripe, (the "Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy, available at https://stripe.com/us/legal.

Information We Receive From Third Party Sources : Some third parties, such as our business partners and service providers, (including, but not limited to those who provide services related to customer messaging, surveying, advertising, marketing, social media, and analytics), provide us with Personal Data about you, such as the following:

· Name and email address from participation in our referral and promotional codes programs

Information We Automatically Collect When You Use Our Services : Some Personal Data is automatically collected when you use our Services, such as the following:

IP Address Information and Other Information Collected Automatically: We automatically receive and record information from your web browser when you interact with the Services, including your IP address, device ID, and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

Generally, the Services automatically collect usage information, such as which parts of the Site you use and the number and frequency of visitors to the Site. We may use this data in a manner that would identify you personally. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Email Communications: We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.

Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet.

As noted, we use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that to take advantage the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Cookies can either be "session cookies" or "persistent cookies". Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas "persistent cookies" are stored on your device for a period of time after you leave our website or Services. We've provided a quick summary of some of the cookie types we and our service providers use on the Service, but for more information about cookies, visit http://www.allaboutcookies.org/ or http://www.aboutcookies.org.uk/ .

Analytics Data: We collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Services.

Aggregate Information: We collect statistical information about how both unregistered and registered users, collectively, use the Services ("Aggregate Information"). Some of this information is derived from Personal Data. While Aggregate Information is not Personal Data, it may be tied back to you, your Account or your web browser.

How Do We Use Your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

· Operate, maintain and provide our features and services on the Services;

· Respond to user inquiries;

· Provide support and assistance for the Services;

· Personalize content and communications based on your preferences;

· Maintain interoperability with third party services, such as Spotify;

· Conduct online behavioral advertising;

· Remember information so that you will not have to re-enter it during your visit or the next time you visit the Site;

· Comply with our legal or contractual obligations;

· Provide and monitor the effectiveness of our Services;

· Protect against or deter fraudulent, illegal or harmful actions;

· Serve relevant advertisements;

· Monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services;

· Diagnose or fix technology problems;

· Complete corporate transactions such as mergers and acquisitions; and

· Enforce our Terms of Service.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests", as further described below.

o Operation and improvement of our business, products and services

o Marketing of our products and services

o Provision of customer support

o Protection from fraud or security threats

o Compliance with legal obligations

o Completion of corporate transactions

How, and With Whom, Do We Share Your Data?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties. We share your Personal Data in the instances described below.

Public Information about Your Activity on the Services:

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Services.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business as specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services' privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Data about you that they have independently developed or acquired.

Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery.

User Profile Information:

User profile information including your name and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.

Financial Information:

As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our "Agents"). These Agents work on our behalf and provide us with services related to the purposes described in this Privacy Policy, which include providing cloud storage or hosting services, marketing assistance, content or service fulfillment, or providing analytics services. We share Personal Data with these third parties as needed to perform services for us and under reasonable confidentiality terms. These parties include:

We also share information with third parties and Agents when you give us consent to do so.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address criminal (including fraud), security or technical issues, (iv) respond to user support requests, (v) investigate and defend ourselves against any third party claims or allegations, (vi) protect our rights, property or safety, our users and the public, or (vii) maintain the security of our Services. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of your information, including your IP address information, using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights : Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/ or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Frame.io, 45 W 27th St, Fl 10, New York, NY 10001.

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing support@frame.io. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

What Choices Do I Have Regarding My Information?

Marketing Communications . If you do not want to receive promotional emails from us, you can click the "unsubscribe" button on the promotional email communications or email us at support@frame.io with the subject "Marketing Opt-Out". Note that you will not be able to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, password reminders, changes or updates to features of the Service, or technical and security notices.

Behavioral Advertising and Tracking Tools.

You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.

Please note the following with respect to opting out of Behavioral Advertising:

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services, and for an additional two years or until we receive a request to delete it. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes in the way we collect or use information, we will notify you by posting an announcement on the Services, sending you an email and/or by some other means. Each time you use the Services or provide us with information, you accept the practices described in this Privacy Policy as applicable at that time.

Transfers of Personal Data

The Services are hosted and operated in the United States ("U.S.") through Frame.io and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Frame.io in the U.S. and will be hosted on U.S. servers, and you authorize Frame.io to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.

Frame.io is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Company's compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.

Please contact us at privacy@frame.io with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you can also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you can also be entitled to invoke binding arbitration for complaints not resolved by other means.

European Union

If you are located in the EU, the United Kingdom, Lichtenstein, Norway, or Iceland, and use or access the Services, you may have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email support@frame.io. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

What If You Have Questions or Concerns Regarding Your Personal Data?

To address your individual rights or if you have any questions or comments related to this Privacy Policy, please send us a detailed message to support@frame.io. We will make every effort to resolve your concerns.


Name: Frame.io

Frame.io, Inc.

Address: 45 W 27th St, Fl 10, New York, NY 10001

Email: support@frame.io