Legal




Thank you for choosing Phrame. This privacy policy (“Privacy Policy”) describes how Phrame Inc. (“Phrame,” "we," "us" or “our”) collects, uses, discloses and secures information collected from or about you and your devices through the Phrame website (“Website”) and through the use of Phrame products (“Products”) and associated mobile applications (“Mobile Apps”) (collectively “Offerings”).

Advanced, innovative internet-connected devices, such as Phrame, collect, use and share data. We have done our best to explain these concepts in a clear and concise way. Please read this Privacy Policy carefully as by accessing the Website and using the Offerings you are consenting to the terms of this Privacy Policy.



What information do we collect?

We collect both Personal Information and Non-Personal Information.

  • In this Privacy Policy, "Personal Information" is data that can be used to identify or contact a specific natural person, such as name, street address, email address, or telephone number.
  • "Non-Personal Information" is data in a form that does not, on its own, permit direct association with any specific individual.
  • “Anonymous and Aggregate Data” are considered Non-Personal Information under this Policy. When we collect information that identifies you personally, we may anonymize it for certain purposes. We remove data fields (such as name, address and telephone number) that can reasonably be used to identify you. We also use a variety of statistical techniques and operational controls to anonymize data. Anonymizing information is one of the tools we use to protect your privacy. We also combine data into anonymous groups, and analyze it. We call this type of data Aggregate Data.

We collect this information about our customers in several different ways:

From Our Website: Phrame collects Personal and Non-Personal Information from you if you visit our Website. We collect this information through the use of technologies such as cookies and web beacons to help us serve your needs better. Examples include log file information, browser type or history, page views, IP address, traffic and usage trends and information about how you interact with the Site’s web pages and with third party links.

When You Make a Purchase: If you pre-order or purchase a Product on our Website or through other channels, you will provide your name, email address, billing and shipping address, payment card information and any other information necessary to complete the transaction to our third party service providers. We do not collect or store your full credit card information. Our third party payment card processor will collect and store full payment card information from you, when an order is placed until when it ships. When we fulfill your order we will associate the serial number of the Product we send to you with the information you have provided to us to purchase your Product for warranty and customer service purposes only.

When You Install An Offering: When you install an Offering (i.e., download and use our Mobile App and install the Product on your vehicle), we will collect your email address and information regarding your mobile device (e.g., mobile device model and operating system version and crash logs).

When you use our Offerings: Once you have installed and activated the Offerings they will collect behavioral, contextual, and operational data.

  • The majority of the data we extract is anonymized by the creation of a Universally Unique Identifier (UUID.) Examples of this include periodic speed readings, battery and solar data, product sensor readings and software events. This data may be tied back to you or your vehicle if you provide the device or the UUID to us or to an authorized representative of ours.
  • A small, aggregated subset of this data will also be associated with your Personal Information in your user account to allow us to provide customer support and understand how our Products are being used. Examples of this include battery charge level, software and firmware versions, software errors, a count of camera uses and the Vehicle Identification Number (VIN) from the vehicle on which you install the product.
  • Any locally stored data remaining on your Product is accessible if you provide us, or an authorized representative of ours, with access to such data, which will be used for warranty and customer service purposes only.

From Third Party Partners and Advertisers: The privacy practices set forth in this Privacy Policy are applicable only to the Website and Offerings. If you link to or obtain information from third party websites or other online services, please be aware that Phrame does not control the privacy practices of such websites or services. Accordingly, your use of any information received from such websites or services or the collection of your Personal Information from such outside websites, shall be governed by the policies of those websites or services.



How do we use the information?

The information we collect from and about you and your vehicle and devices will be used:

  • to provide and update Phrame Offerings and to evaluate and improve the features and functionality of current and future Phrame Offerings.
  • to maintain customer relationships.
  • to fulfill your requests and complete transactions. For example, confirming and tracking your order.
  • to operate the websites.
  • to provide customer support and service.
  • to create Anonymous and Aggregate Data or reports, which are analyzed for purposes of creating summary reports, identifying and summarizing data patterns or trends, including for sale or distribution to other companies.
  • for sales and marketing purposes. For example, analyzing preferences and trends, informing you of new products and services and to understand our sales channels.
  • to comply with legal requirements.
  • as part of a business transition.


Who do we disclose the information to?

Disclosure to Third Party Service Providers: We may disclose your Personal Information and Non-Personal Information to our third party service providers (e.g., hosting providers, payment processors, analytics companies and social networking providers for promotional and marketing activities, etc.). When we supply information to these third parties, we require them to use it only for the purpose for which they are working with Phrame, and prohibit disclosure except at our direction and consistent with the services they are contracted to provide.

External Marketing & Analytics Reports: We may use Anonymous and Aggregate Data to generate statistical or other analysis about users to other companies for their own business, marketing, advertising or other similar uses. For example, we may publish reports about driving behavior. This information may also be shared with other users to help them better understand driving behavior or raise safety awareness. When we provide individual Anonymous and Aggregate Data to businesses, we require that they only use it to compile aggregate reports, and for no other purpose. We also require businesses to agree they will not attempt to identify any person using this information, and that they will handle it in a secure manner, consistent with this Policy.

Legal Disclosures: Phrame may disclose Personal Information and Non-Personal Information about you, your vehicle, or other users of the Offerings with or without your consent, and with or without notice, to comply with a valid legal obligation, for example a subpoena or court order.

We may also disclose this information about you, your vehicle, or users of the Offerings when we believe in good faith that the disclosure of information is necessary to address suspected illegal activity, protect or defend the legal rights, property, safety and security of Phrame, our customers, the public and third parties, or to prevent imminent physical harm.

Business Transfers: We may provide your Personal Information and Non-Personal Information to a third party in connection with the sale, transfer or reorganization of some or all of Phrame or its assets, and any such acquirer or transferee will have the right to use and disclose such information subject to the terms of this Privacy Policy.



Your choices

Our aim is to provide you with clear choices over your information.

““Do Not Track” or “DNT” Technology; Opting Out*. The Website, whether accessed on a computer or a mobile device, is not at this time configured to read or respond to “do not track” settings or signals in your browser headings, which vary by browser provider. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device to delete and disable cookies and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit allaboutcookies.org). Some features of the Website require the use of cookies and other tracking/recording tools in order to customize the delivery of information to you. If you disable such tools you may not be able to use certain aspects of the Offerings.

You should be aware that Phrame cannot control the use of cookies or similar tracking technologies (or the resulting information) by third-parties. The use of such technologies is not covered by our Privacy Policy. We do not have access or control over these uses.

If you have any questions, concerns, or comments about our Privacy Policy you may contact us at legal@phrame.com or at the address below.


Phrame Inc.
Attention: Legal
75 Broadway
San Francisco, CA
94111



For marketing-related emails, you may opt-out by following the opt-out instructions in the email. Please note that we may still send you important non-promotional messages, such as details about your order or safety matters even if you follow the opt-out instructions. We will comply with your request within 10 business days.



Data storage and security

Data security is very important to us. Your information collected through the Offerings will be collected, processed and secured using reasonable operational, technical and administrative measures.

Our Offerings are available for sale and use within the United States only. You may not use our Products or Mobile App outside the United States. Phrame will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.



Public forums

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used for any purpose by others who access them. We are not responsible for the Personal Information or other information you choose to submit in these areas.

Our policy on children’s information:
We do not knowingly collect or solicit information from children under 13; if you are a child under 13, please do not attempt to register for the Offerings or send any about yourself to us. If we learn we have collected information from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided information to us, please contact legal@phrame.com.



How do we make changes to this policy?

We may periodically modify this Privacy Policy. If we make significant changes to the Privacy Policy, we will notify you via the Website and/or Offerings indicating that the Privacy Policy has been changed. By continuing to access the Website and use the Offerings you are consenting to the revised Privacy Policy.

This Privacy Policy was last modified on September 14, 2017.