Frame Privacy Notice

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you sign up for our mailing list, register for an account, input your financial information, post a review, participate in an event, contest, promotion or survey or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us:

• Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for customer support purposes.
• Government Identifiers, including social security number or another national or tax identification number for you and the other members of your household and/or family. We use this information primarily to provide you with our products and services and to facilitate your requests.
• Household Information, including first and last name, gender, age, date of birth, citizenship / residency status, and relationship status for you and the other members of your household and/or family. We use this information primarily to provide you with our products and services and to facilitate your requests.
• Professional Information, including current and prior employment status, job title, employer, and employment details for you and the other members of your household and/or family. We use this information primarily to provide you with our products and services and to facilitate your requests.
• Financial Information, including income, budgets, expenses, debts, investments, assets, accounts and account history / balances, transaction and payment history, taxes and tax status, risk tolerance and financial goals and concerns for you and the other members of your household and/or family. We use this information primarily to provide you with our products and services and to facilitate your requests.
• Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number) used to pay for our products and services. Please note that we use third-party payment providers, including Stripe, to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider's use of your personal data is governed by their privacy notice.
• Event, Contest, Promotion, and Survey Information, including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial. We use this information primarily to administer and facilitate our products and services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business, and facilitate the related event, contest, promotion, or survey.
• Communication, Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, including our online live chat or automated chat functions, email addresses, or other contact information we make available to customers, as well as recordings of calls or meetings with us, where permitted by law (including through the use of automated or artificial intelligence tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you via online chat, email, phone, text message or social media, and to deliver and improve our products and services.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners' automatic data collection technologies, including (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted by law) to link information collected from different devices.
• Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.
• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address.

All of the information collected automatically through these tools allows us to improve your experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, to offer communications features such as live and automated chat, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

• Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system and confirm you successfully authenticated.
• Mobile Sign-On: We may provide you the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful.
• Integration Partners: We may provide you the ability to integrate or link your third-party financial account information with our platform via third-party integrations. If you choose to utilize these integrations, we may obtain financial information about you and other information you make available through the integration.
• Financial Advisors: We may receive personal data from your financial advisors in connection with our products and services.
• Members of Your Household or Family: We may receive personal data from members of your household and/or family in connection with our products and services.
• Other Customers: We may receive your personal data from our other customers. For example, a customer may provide us with your contact information as a part of a referral.
• Social Media: When you interact with us or our services through other social media networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network.
• Advertisers, Influencers, and Publishers: We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts.
• Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services as a part of or in connection with our services.
• Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us.
• Other Sources: We may also collect personal data about you from other sources, including publicly available sources, or through transactions such as mergers and acquisitions.
• Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
• Manage our organization and its day-to-day operations;
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Facilitate the relationship we have with you and, where applicable, the company you represent;
• Request you provide us feedback about our product and service offerings;
• Address inquiries or complaints made by or about an individual in connection with our products or services;
• Create and maintain accounts for our customers;
• Verify your identity and entitlement for our products and services;
• Market our products and services to you, including through email, phone, text message, push notification, and social media;
• Administer, improve, and personalize our products and services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services (including by training or fine-tuning our and our third-party providers' artificial intelligence and machine learning models);
• Identify and analyze how you use our products and services;
• Conduct research and analytics on our user base and our products and services;
• Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
• Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity;
• Comply with contractual and legal obligations and requirements;
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

As noted above, we may use your personal data to improve our services and train or fine-tune the artificial intelligence and machine learning models that power our platform and services.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

• To Other Customers and the General Public: We make available personal data designed for sharing through our services with certain or all other Frame customers, or the general public, based on the applicable privacy settings and intended recipients.
• To Integration Partners: We work with third-party integration providers to receive information from your linked third-party financial accounts. We may need to share personal data with our third-party integration providers to identify and link your third-party financial accounts with our platform.
• To Your Financial Advisors: At your direction, we may share personal data with your financial advisors in order to facilitate our products and services.
• To Members of Your Household and/or Family: At your direction, we may share personal data with members of your household and/or family in order to facilitate our products and services.
• To Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the products and services we make available.
• To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices.
• To Business Partners: We may share personal data with our business partners, or we may allow our business partners to collect personal data directly from you in connection with our services.
• To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above.
• To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.
• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization.
• To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process; to protect our rights and property; to detect, suppress, or prevent fraud; to reduce credit risk and collect debts owed to us; to protect the health and safety of us, our customers, or any person; or as otherwise required by applicable law.
• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction.

Your Privacy Choices

Communication Preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in any of our email communications. Please note you cannot opt-out of service-related email communications.
• Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out (where available), or replying STOP to any one of our promotional text messages.
• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device's notification settings menu or in the applicable service-specific application.
• Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us as set forth in the Contact Us section below.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data, you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

Automatic Data Collection Preferences

You may use the "Cookie Settings" manager linked in the footer of our website to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting. You may also be able to utilize third-party tools and features to restrict our use of automatic data collection technologies. Please note that blocking automatic data collection technologies may negatively impact your experience using our services.

Targeted Advertising Preferences

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests. In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs:

• Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device.
• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program.
• Network Advertising Initiative: The Network Advertising Initiative also provides individuals instructions for further controlling how information is used for online advertising.
• Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests.

Modifying or Deleting Your Personal Data

If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us as set forth in the Contact Us section below. We may not be able to modify or delete your personal data in all circumstances.

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data:

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us may provide you additional choices with regard to the data you choose to share with us.
• Google Analytics: Google Analytics allows us to better understand how our customers interact with our services. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Add-On.

Children's Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child's parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

Retention of Personal Data

We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. In addition, we take steps designed to ensure any third party with whom we share personal data provides a similar level of protection. However, despite these controls, we cannot completely ensure or warrant the security of your personal data.

Third-Party Websites and Services

Our websites and other services may include links to or redirect you to third-party websites, plug-ins, applications, or other services, including social media services where you may connect with us. Third-party websites and other services may also reference or link to our websites and services. This Privacy Notice does not apply to any personal data practices of these third-party websites, plug-ins, applications, or other services. To learn about these third parties' personal data practices, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. If you are a resident of the state of California, Connecticut, Minnesota, Montana, or Oregon, please click here for additional state-specific privacy disclosures, including a description of the personal data rights made available to residents of these states under applicable law.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact us at: frame@cointracker.com.