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PRIVACY POLICY

Last updated: December 22, 2022

The Frame.io Privacy Policy describes the privacy practices of Frame.io’s
Services and anywhere we display or reference this policy. Your use of
Frame.io’s Services is subject to our Terms of Service, which incorporates this
Privacy Policy. Any terms we use in this Policy without defining them have the
definitions given to them in the Terms of Service.

Frame.io is an Adobe Company. Frame.io discloses personal information with other
entities in the Adobe family of companies in order to enhance and improve Adobe
products and services, as well as for other legitimate business purposes. Your
personal information will also be used to send you information about other Adobe
products and services that may be of interest to you, consistent with your
choices on how we disclose your data (as detailed more below). A list of these
entities and their respective privacy policies can be found here.


PRIVACY POLICY TABLE OF CONTENTS

 * What does this Privacy Policy cover?

 * What information does Frame.io collect about me?
   
   * Categories of Personal information We Collect
   
   * Categories of Sources of Personal information
   
   * Our Business or Commercial Purposes for Collecting Personal information
   
   

 * How We Disclose Your Personal information

 * Cookies, Tracking Tools, and Advertising

 * Information about Interest-based Advertisements

 * What rights do I have regarding my personal information?

 * Withdrawing consent or otherwise objecting to direct marketing

 * Data Security and Retention

 * Personal information of Children

 * Additional US State Privacy Rights

 * Information for European Union Data Subjects

 * Changes to this Privacy Policy

 * Contact Information

WHAT THIS PRIVACY POLICY COVERS

 * This Privacy Policy covers how we treat personal information that we gather
   when you access or use our Services. “Personal information” means any
   information that identifies or relates to a particular individual or when
   combined with other information could be used to identify a specific
   individual and also includes information referred to as “personally
   identifiable information” or similar terms used in applicable data privacy
   laws, rules, or regulations. This Privacy Policy does not cover the practices
   of companies we don’t own or control or people we don’t manage.

 * This Privacy Policy covers how Frame.io (also referred to as “we,” “us,” or
   “our) will make use of your personal information in the context of:
   
   * Frame.io websites and web-based services;
   
   * Services that display or include a reference to this policy; and
   
   * Frame.io’s marketing, sales, and advertising practices.
   
   

WHAT INFORMATION DOES FRAME.IO COLLECT ABOUT ME?

CATEGORIES OF PERSONAL INFORMATION

When you purchase, register, or use our Services, or contact us for support or
other offerings, Frame.io collects information that identifies you. This
includes identifiers and contact information, such as:

 * Name;

 * Email address;

 * Telephone number;

 * Postal or physical address;

 * Country;

Commercial and transaction information, such as:

 * Payment/billing information (payment card type, last 4 digits of payment
   card, billing address, and contact information);

 * Purchase history;

 * Consumer profiles;

 * Content (e.g., documents, photos, videos, activity logs, direct feedback from
   you, and metadata about your content) which is sent or received using any
   online features which is stored on servers belonging to Frame.io or its
   parent company;

 * Content of and information provided through customer support communications;

Professional, education, or other demographic information, such as:

 * Date of birth;

 * Company or school name;

 * Title or occupation;

 * Job function or expertise;

 * Company details, such as the size, industry, and other information about the
   company where a user may work (when the user has provided the company name);

Analytics or other electronic network activity, such as:

 * IP address, browser, domain server, mobile device ID, and non-identifiable
   request IDs:

 * Use and navigation of Services (collected through cookies and similar
   technologies), referring webpage or source through which you accessed the
   Services.

INFERRED INFORMATION

To help keep our databases current and to provide you the most relevant content
and experiences, we may infer or generate information based on the information
we collect or combine information provided by you with information from third
party sources, in accordance with applicable law. For example, we may profile
user attributes or create profiles reflecting user behavior. We may also infer,
generate, or collect and receive information from third parties, including
partners, and from publicly accessible sources, for purposes that include to
detect, prevent, or otherwise address fraudulent, deceptive, or illegal
activity, misuse of our Services and Software, security or technical issues, as
well as to protect against harm to the rights, property or safety of Frame.io
and Adobe employees, uses, children, or the public.

CATEGORIES OF SOURCES OF PERSONAL INFORMATION

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

 * Personal information you provide directly to us, such as on a form, via a
   browser or mobile-based chat session, via email or telephone, etc. or create
   an account and use our interactive tools and services.

 * Personal information we automatically or programmatically collect or generate
   from your access to and use of Frame.io websites, products, or services
   including our mobile application and any software we make available to you.

 * Personal information we infer or generate from your access to and use of our
   websites, products, or services, such as your approximate location (such as
   your IP address), likely preferences or other characteristics

 * Personal information we obtain or receive from other sources including:
   
   * Data brokers and aggregators from which we obtain information to supplement
     the personal information we collect.
   
   * Third party partners, such as third-party applications and services
     including social networks you choose to connect or interact with through
     our services.
   
   * Service providers such as advertising partners that collect or provide data
     in connection with assisting us in marketing and promotional services
     analyzing how you interact and engage with our Services on our behalf.
   
   * Service providers that generate leads and create user profiles in
     connection with sales and marketing efforts.
   
   * Publicly available sources, such as open government databases.
   
   

OUR BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTING PERSONAL INFORMATION

 * Providing, Customizing and Improving the Services
   
   * Creating and managing your account or other user profiles.
   
   * Processing orders or other transactions; billing.
   
   * Operating and maintaining our features and Services
   
   * Providing you with the products, features, services or information you
     request.
   
   * Meeting or fulfilling the reason you provided the information to us.
   
   * Providing support and assistance for the Services.
   
   * Responding to user inquiries.
   
   * Improving the Services, including testing, research, internal analytics and
     product development.
   
   * Providing and monitoring the effectiveness of the Services.
   
   * Personalizing the Services, website content and communications based on
     your preferences.
   
   * Remembering your preferences and settings, such as username, so that you
     will not have to re-enter it during your visit or the next time you visit
     the Services;
   
   * Monitoring aggregate metrics such as total number of visitors, traffic,
     usage, and demographic patterns on our website and our Services;
   
   * Maintaining interoperability with third party services.
   
   * Doing fraud protection, security and debugging.
   
   * Diagnosing or fixing technology problems.
   
   * Carrying out other business purposes stated when collecting your personal
     information
   
   

 * Marketing the Services
   
   * Marketing and selling the Services.
   
   * Showing you advertisements, including interest-based or online behavioral
     advertising.
   
   

 * Corresponding with You
   
   * Responding to correspondence that we receive from you, contacting you when
     necessary or requested, and sending you information about Frame.io or the
     Services.
   
   * Sending emails and other communications according to your preferences or
     that display content that we think will interest you.
   
   

 * Meeting Legal Requirements and Enforcing Legal Terms
   
   * Fulfilling our legal obligations under applicable law, regulation, court
     order or other legal process, such as preventing, detecting and
     investigating security incidents and potentially illegal or prohibited
     activities.
   
   * Protecting the rights, property or safety of you, Frame.io or another
     party.
   
   * Enforcing any agreements with you.
   
   * Responding to claims that any posting or other content violates third-party
     rights.
   
   * Resolving disputes.
   
   

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to the categories of service providers and
other parties listed in this section.

 * Service Providers. These parties help us provide the Services or perform
   business functions on our behalf. They include:
   
   * Hosting, technology, and communication providers.
   
   * Security, spam, and fraud prevention consultants and providers.
   
   * Analytics providers that allow us to provide you with a more personalized
     experience, investigate issues, and help us improve product quality and
     features.
   
   * Fraud monitoring and prevention providers.
   
   * Support and customer service vendors.
   
   * Product fulfillment and delivery providers.
   
   * Payment processors.
     
     * Our payment processing partner Stripe, Inc. (“Stripe”) collects your
       voluntarily-provided payment card information necessary to process your
       payment.
     
     * Please see Stripe’s terms of service and privacy policy for information
       on its use and storage of your personal information.
     
     
   
   

 * Advertising Partners. These parties help us market our services and provide
   you with other offers that may be of interest to you. They include:
   
   * Ad networks.
   
   * Marketing partners and providers.
   
   

 * Business Partners. These parties partner with us in offering various services
   and include businesses that you have a relationship with.

 * Parties You Authorize, Access, or Authenticate
   
   * Third parties you access through the services.
   
   * Social media services.
   
   * Other users.
   
   

LEGAL OBLIGATIONS

We may disclose any personal information that we collect with third parties in
conjunction with any of the activities set forth under “Meeting Legal
Requirements and Enforcing Legal Terms” in the “Our Commercial or Business
Purposes for Collecting Personal information” section above.

BUSINESS TRANSFERS

All of your personal information that we collect may be transferred to a third
party if we undergo a merger, acquisition, bankruptcy, or other transaction in
which that third party assumes control of our business (in whole or in part).
Should one of these events occur, we will make reasonable efforts to notify you
before your information becomes subject to different privacy and security
policies and practices.

DEIDENTIFIED AND AGGREGATED DATA

We may create aggregated, de-identified, or anonymized data from the personal
information we collect, including by removing information that makes the data
personally identifiable to a particular user. We may use such aggregated,
de-identified, or anonymized data and disclose it to third parties for our
lawful business purposes, including to analyze, build, and improve the Services
and promote our business, provided that we will not disclose such data in a
manner that could identify you.

COOKIES, TRACKING TOOLS, AND ADVERTISING

The Services use cookies and similar technologies to collect usage information
to provide you with a more personalized experience, improve our products and
services, and in some cases, to tailor ads to your likely interests. To change
your collection settings, click on Cookie preferences

Cookies are small text files stored by your web browser when you use websites.
You can control how websites use cookies by configuring your browser’s privacy
settings (please refer to your browser’s help function to learn more about
cookie controls). Note that if you disable cookies entirely, our website may not
function properly.

Frame and the companies that help us run our business use cookies in several
ways, such as:

 * Authenticating and identifying you on our websites so we can provide you the
   services you requested

 * Keeping track of any information you have provided to us

 * Providing you the Frame websites that you use

 * Remembering your preferences or where you left off in your use of a Frame
   website

 * Measuring your use of Frame websites so that we can improve them, tailor our
   websites to your likely interests, and conduct market research

 * Understanding your likely interests so we can provide you more relevant ads
   and content on non-Frame websites and in non-Frame apps

Web beacons and embedded scripts are other technologies that we use in our
websites, as well as in some of our emails and ads. Web beacons (or “tags”) are
bits of programming code included in web pages, emails, and ads that notify
Frame (or the companies that help us run our business) when those web pages,
emails, or ads have been viewed or clicked on.

Embedded scripts are bits of programming code included within some of our web
pages that measure how you use those web pages, such as which links you click.
We use this information to improve our websites, tailor our websites to your
likely interests, conduct market research, and for anti-fraud monitoring
purposes. You may be able to turn off scripting functionality, such as
JavaScript, within your browser (please refer to your browser’s help function).
Note that if you disable scripting functionality, some Frame websites may not
function properly.

Your browser may also offer you a “Do Not Track” option, which allows you to
signal to operators of websites and web applications and services that you do
not wish such operators to track certain of your online activities over time and
across different websites. Currently, there is not an accepted standard on how
companies should respond to web browsers’ “Do Not Track” signals. Accordingly,
our Services do not currently recognize or respond to “Do Not Track” browser
signals.

INFORMATION ABOUT INTEREST-BASED ADVERTISEMENTS

We may serve advertisements, and allow third-party ad networks, including
third-party ad servers, ad agencies, ad technology vendors and research firms,
to serve advertisements through the Services. These advertisements may be
targeted to users who fit certain general profile categories or display certain
preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based
Ads (including personal information) may be provided to us by you, or derived
from the usage patterns of particular users on the Services and/or services of
third parties.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory
Principles for Online Behavioral Advertising. Through the DAA and Network
Advertising Initiative (“NAI”), several media and marketing associations have
developed an industry self-regulatory program to give consumers a better
understanding of, and greater control over, ads that are customized based a
consumer’s online behavior across different websites and properties.

To make choices about Interest-Based Ads from participating third parties,
including to opt-out for all companies who are members of those groups, please
see:

 * Digital Advertising Alliance

 * Network Advertising Initiative

 * European Interactive Digital Advertising Alliance (“EDAA”)

To opt out of advertising solutions that tailor ads shown within mobile apps
based on your likely interests please either:

 * Set the preference on your mobile device to limit ad tracking, or

 * Download the DAA’s AppChoices app

Please also review the privacy policies on the website and mobile apps that you
use because they may offer additional privacy choices.

WHAT RIGHTS DO I HAVE REGARDING MY PERSONAL INFORMATION?

Under the law of some jurisdictions, you have certain rights with respect to
your personal information. You may have the right to ask for a copy of your
personal information; to correct, delete, or restrict (stop any active)
processing of your personal information; and to obtain the personal information
you provide to us for a contract or with your consent in a structured,
machine-readable format, and to ask us to port this information to another
controller. You may be entitled to additional rights based on applicable data
privacy laws in your jurisdiction.

These rights may be limited, for example, if fulfilling your request would
reveal personal information about another person, or if you ask us to delete
information which we are required by law to keep or which we need to defend
claims against us. In some cases, we may also need you to provide us with
additional information, which may include personal information, if necessary to
verify your identity and the nature of your request. To exercise any of these
rights, you can get in touch with us using the details set out below. You may
also be able to access, correct, or delete some of your personal information by
logging into your account.

In addition to these rights, see the “Additional US State Privacy Rights”
section and the “EU Data Subject Rights” section further below for more
information about rights you may be entitled to.

WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING

Frame.io and companies we hire to help market our Services on our behalf may use
your information to provide you with information and offers related to Frame.io.

Where we rely on your consent, you will always be able to withdraw that consent,
although we may have other legal grounds for processing your information for
other purposes, such as those set out above. In some cases, we are able to send
you direct marketing without your consent, where we rely on our legitimate
interests. You have an absolute right to opt out of direct marketing, or
profiling we carry out for direct marketing, at any time by:

 * updating your preferences in your specific website or app accounts;

 * clicking on the unsubscribe link in the email footer;

 * connecting with us through our online support chat; or

 * contacting us using the details provided at the end of this privacy policy.

DATA SECURITY AND RETENTION

We seek to protect your personal information from unauthorized access, use, and
disclosure using appropriate physical, technical, organizational, and
administrative security measures based on the type of personal information and
how we are processing that data. You should also help protect your data by
appropriately selecting and protecting your password and/or other sign-on
mechanisms; limiting access to your computer or device and browser; and signing
off after you have finished accessing your account. Although we work to protect
the security of your account and other data that we hold in our records, please
be aware that no method of transmitting data over the internet or storing data
is completely secure.

We retain personal information about you for as long as you have an open account
with us or as otherwise necessary to provide you with our Services. When you
close your account, we begin deleting certain personal information that we no
longer have a business reason to retain. In some cases, we retain personal
information 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.

PERSONAL INFORMATION OF CHILDREN

As noted in the Terms of Service, we do not knowingly collect or solicit
personal information about children under 13 years of age and our Services are
not intended for minors under the age of 13. If you are a child under the age of
13, please do not attempt to register for or otherwise use the Services or send
us any personal information. If we learn we have collected personal information
from a child under 13 years of age, we will delete that information as quickly
as possible. If you believe that a child under 13 years of age may have provided
personal information to us, please contact us at support@frame.io.

ADDITIONAL US STATE PRIVACY RIGHTS

Some states in the US have passed state-specific privacy laws. This section
supplements our privacy policy by explaining your privacy rights if you are a
resident in one of these states, provides certain mandated disclosures about our
treatment of personal information, and includes:

 * Colorado, Connecticut, Utah and Virginia specific disclosures and rights

 * California specific disclosures and rights

 * Opt-outs for sale or sharing of personal information

 * Metrics on consumers exercising their rights

COLORADO, CONNECTICUT, UTAH, AND VIRGINIA:

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
information, including:

 * Right to confirm whether the controller is processing the consumer’s personal
   information and the right to access such information;

 * Right to correct inaccuracies in personal information;

 * Right to delete personal information;

 * Right of data portability;

 * Right to opt out from targeted advertising; and

 * Right to opt out from the sale of personal information.

In certain states, you also have the right to opt out from profiling in
furtherance of decisions that produce legal or similarly significant effects on
the consumer (such as Virginia, Colorado, and Connecticut) and appeal a decision
regarding a request to exercise your rights.

If you wish to exercise one or more of these rights, please review the “What
rights do I have regarding my personal information?” section above. If you would
like to opt out of targeted advertising or the selling or sharing of personal
information, please see the instructions below.

CALIFORNIA

The California Consumer Privacy Act of 2018 (as amended by the California
Privacy Rights Act of 2021) (“CCPA”) requires us to provide California consumers
with some additional information related to how Frame.io collects, uses,
retains, and discloses personal information as well as describe additional
rights, which are summarized below.

CALIFORNIA PRIVACY POLICY DISCLOSURES

We collect, use, disclose, sell, share, and retain personal information as
further described in this Privacy Policy and summarized below.

PERSONAL INFORMATION WE COLLECT:

In the preceding 12 months, we have collected the categories of personal
information described above in the section “Categories of Personal information.”

SOURCES OF PERSONAL INFORMATION WE COLLECT

The “Categories of Sources of Personal information” section above details the
sources of personal information that we collect from you.

BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTING PERSONAL INFORMATION

The “Our Business or Commercial Purposes for Collecting Personal information”
section above details the business or commercial purposes for collecting
personal information from you.

CATEGORIES OF PERSONAL INFORMATION SOLD OR SHARED IN THE PRECEDING 12 MONTHS:

Categories of Personal information Sold or SharedCategories of Third-Party
RecipientsPurpose for Disclosure- Identifiers and contact informationSocial
media platforms advertisers; ad agencies; advertising networks and platforms;
advertising related technology providersCross-context behavioral advertising-
Commercial and transactional information- Analytics or other electronic network
activity- Inferred information

RETENTION AND DELETION

The “Data Security and Retention” section above details how long Frame retains
personal information.

CALIFORNIA PRIVACY RIGHTS

California consumers have certain rights with respect to their personal
information. These rights include the following:

1. Right to opt out of “selling” or “sharing” certain personal information

You have a right to opt out from future “sales” or “sharing” of personal
information. CCPA requires us to describe the categories of personal information
we sell to or share with third parties and how to opt out of future sales or
sharing. The CCPA defines personal information to include internet or other
electronic network activity information which includes identifiers, such as IP
addresses, cookies IDs, and mobile IDs. The law also defines a “sale” or “share”
broadly to include simply making data available to third parties in some cases.

To opt out of selling or sharing for purposes of cross-context behavioral
advertising you can:

 * Click on “Cookie preferences” to review your preferences and opt out of
   advertising cookies and other technologies used for browser based
   cross-context behavioral advertising. Note you will need to opt out from each
   browser that you use to access Frame.

 * To opt out of the selling or sharing of customer record information for
   cross-context behavioral advertising and partner marketing click here.

Further, using these choices will not stop all interest-based advertising, such
as contextual-based ads.

2. Right to Know or Request Categories of Personal information

You have a right to request that we disclose to you the personal information we
have collected about you. You also have a right to request additional
information about our collection, use, disclosure, or sale of such personal
information such as a list of the categories of personal information collected
about you, and other related information such as the source of the information,
categories of information shared or sold to third parties, and the purpose for
such sharing. Frame has provided this information in this Privacy Policy.

3. Right to Correct.

You have a right to request correction of inaccurate personal information.

4. Right to Request Deletion

You have the right to request that we delete the personal information that we
have collected about you, subject to certain exceptions.

5. Right to Designate an Authorized Agent

You may designate an authorized agent to exercise some of your rights, however,
in order to help protect 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 it. Each request that meets
both of these criteria will be considered a “Valid Request.” We will only use
personal information provided in a Valid Request to verify your identity and
complete your request. You do not need an account to submit a Valid Request.

6. Right against Discrimination

We will not discriminate against you for exercising your rights under the CCPA.

7. Right to Notice

You have a right to receive notice of our practices at or before collection of
personal information

ADDITIONAL INFORMATION ON EXERCISING YOUR RIGHTS

You have right to exercise the rights listed in our Privacy Policy free or
charge or penalty, but we may limit the number of requests you make or charge
reasonable fees as legally permitted. You may exercise many of these rights
yourself by adjusting your preferences as outlined in this Privacy Policy,
filling out a request at https://preferences.frame.io/privacy-management/, or by
reaching out to us via the contact information provided at the end of this
Privacy Policy.

CONSUMER REQUEST METRICS FOR CALENDAR YEAR 2022

Frame believes transparency is critical to maintaining a trusted relationship
with our consumers. To that end, Frame is further enhancing our transparency
with respect to the choices our consumers make regarding personal information.
In this privacy transparency disclosure, we are providing metrics on certain
requests we received from consumers across the United States during the 2022
calendar year, in compliance with the California Consumer Privacy Act.

Requests to know: Frame received 72 consumer requests to know personal
information collected about them, complied with 72 of those requests in whole or
in part, and denied 0 of those requests.

Requests to delete: Frame received 1,896 consumer requests to delete, complied
with 1,838 of those requests in whole or in part, and denied 10 of those
requests while the remaining requests are pending.

INFORMATION FOR EUROPEAN UNION DATA SUBJECTS

If you are a resident of the European Union (“EU”), United Kingdom,
Lichtenstein, Norway or Iceland, you may have additional rights under the EU
General Data Protection Regulation (the “GDPR”) with respect to your personal
information, as outlined below.

For this section, we use the terms “personal information” and “processing” as
they are defined in the GDPR, but “personal information” 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. Frame.io will be the controller with
regard to personal information we collect.

If there are any conflicts between this section and any other provision of this
Privacy Policy, the policy or portion that is more protective of personal
information shall control to the extent of such conflict. If you have any
questions about this section or whether any of the following applies to you,
please contact us at support@frame.io. Note that we may also process personal
information of our customers’ end users or employees in connection with our
provision of certain services to customers, in which case we are the processor
of personal information. If we are the processor of your personal information
(i.e., not the controller), please contact the controller party in the first
instance to address your rights with respect to such data.

PERSONAL INFORMATION WE COLLECT

The “Categories of Personal information We Collect” section above details the
personal information that we collect from you.

PERSONAL INFORMATION USE AND PROCESSING GROUNDS

The “Our Commercial or Business Purposes for Collecting Personal information”
section above explains how we use your personal information.

We will only process your personal information if we have a lawful basis for
doing so. Lawful bases for processing include consent, contractual necessity and
our “legitimate interests” or the legitimate interest of others, as further
described below.

 * Contractual Necessity: We process the following categories of personal
   information as a matter of “contractual necessity”, meaning that we need to
   process the data to perform under our Terms of Service with you, which
   enables us to provide you with the Services. When we process data due to
   contractual necessity, failure to provide such personal information will
   result in your inability to use some or all portions of the Services that
   require such data.
   
   * Profile or Contact Data
   
   * Payment Data
   
   * Commercial Data
   
   

 * Legitimate Interest:
   
   * We process the following categories of personal information when we believe
     it furthers the legitimate interest of us or third parties:
     
     * Profile or Contact Data
     
     * Device/IP Data
     
     * Web Analytics
     
     * Social Network Data
     
     * Consumer Demographic Data
     
     * Professional or Employment Related Data
     
     * Geolocation Data
     
     * Inferences from Other personal information Collected
     
     * Other Identifying Information that You Voluntarily Choose to Provide
     
     * We may also de-identify or anonymize personal information to further our
       legitimate interests.
     
     
   
   * Examples of these legitimate interests include (as described in more detail
     above):
     
     * Providing, customizing, and improving the Services.
     
     * Marketing the Services.
     
     * Corresponding with you.
     
     * Provision of customer support.
     
     * Protection from fraud or security threats.
     
     * Meeting legal requirements and enforcing legal terms.
     
     * Completing corporate transactions.
     
     
   
   

 * Consent: In some cases, we process personal information based on the consent
   you expressly grant to us at the time we collect such data. When we process
   personal information based on your consent, it will be expressly indicated to
   you at the point and time of collection.

 * Other Processing Grounds: From time to time, we may also need to process
   personal information to comply with a legal obligation, if it is necessary to
   protect the vital interests of you or other data subjects, or if it is
   necessary for a task carried out in the public interest.

DISCLOSING PERSONAL INFORMATION

The “How We Disclose Your Personal information” section above details how we
disclose your personal information to third parties.

EU DATA SUBJECT RIGHTS

In addition to the rights discussed above, you may have certain rights set forth
below. For more information about these rights, or to submit a request, please
email us at support@frame.io.

 * Portability: You can ask for a copy of your personal information in a
   machine-readable format. You can also request that we transmit the data to
   another controller where technically feasible.

 * Objection: You can contact us to let us know that you object to the further
   use or disclosure of your personal information for certain purposes, such as
   for direct marketing purposes.

 * Restriction of Processing: You can ask us to restrict further processing of
   your personal information.

 * Right to File Complaint: If you have unresolved concerns, you have the right
   to report them to your local privacy regulator or data protection authority
   and, where applicable, you also have the right to lodge a complaint with
   Adobe Ireland's lead supervisory authority, the Irish Data Protection
   Commission.

TRANSFERS OF PERSONAL INFORMATION

The Services are hosted and operated in the United States (“U.S.”) through
Frame.io and its service providers, but we also transfer personal information to
all other countries in the world where our Services are available. We carry out
these transfers in compliance with applicable laws – for example, by putting
data transfer agreements in place to help protect your personal information.
Where Frame.io transfers your personal information to a country that is not
within the EEA and is not subject to a European Commission adequacy decision, we
rely on one or more of the following legal mechanisms: European Commission
approved Standard Contractual Clauses, and/or your consent in certain
circumstances.

CHANGES TO THIS PRIVACY POLICY

 * We may update this Privacy Policy from time to time to account for new
   technologies, industry practices, regulatory requirements or for other
   purposes. If we do, we will change the “last updated” date at the top of this
   policy and the revised policy will be posted to this page so that you are
   aware of the information we collect, how we use it, and under what
   circumstances we may disclose it. We encourage you to periodically review
   this Privacy Policy for the latest information on our privacy practices.
   Under certain circumstances (for example, with certain material changes or
   where it is required by applicable privacy laws), we will provide notice to
   you of these changes, and where required by applicable law, we will obtain
   your consent. Notice may be by email to you, by posting a notice of such
   changes on our Services, or by other means consistent with applicable law.

 * If you have a privacy question, concern, or request, contact us at:
   
   * www.frame.io
   
   * support@frame.io
   
   * 345 Park Avenue, San Jose, CA 95110, United States
   
   


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