This document focuses on information related to the operation of the public websites available at Phrame.com and Phrame.com sub-domains (each, a “Site”), including our online store. We provide additional details about how we collect and use information in connection with Phrame products and services in our Privacy Statement for Phrame Products and Services.
COLLECTION AND USE: Phrame collects information about you through our Sites in several ways. This information is used to provide users with Phrame products and services, to allow us to understand how visitors navigate our Site, and to provide advertising that is relevant to your interests.
Purchase and Login Information: If you pre-order or purchase Phrame products from our Site, we request that you provide your name, email address, billing and shipping address, credit card information and any other information necessary to complete the transaction. If you create a Phrame account, your name, billing and shipping address and the last four digits of your credit card information can be stored. We do not collect or store your full credit card information. Our credit card processing service provider, CyberSource, will collect and store full payment card information from you, even as a guest user, when an order is placed until when it ships. If you create a Phrame account and elect to have payment card information saved, CyberSource will store your payment information.
Mailing List Information: You may choose to submit your email address via a submission form located on our Site. Your email address may be used to send you news about Phrame-related services, products or promotions. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.
Device Usage information: If you are logged into your Phrame account, we record the IP address you visit our website from, and if you have a Phrame device or other connected device, we record adjustments you make to the product through the website interface. We store this data along with your email address, information about your Phrame device, data collected directly by the device, a history of your device settings, and any other information we have collected about your use of Phrame products and services. See our Privacy Statement for Phrame Products and Services to learn more about the usage information collected through our products.
Website Use Information: Like many websites, we and our third-party partners analyze log file information and other data collected through cookies, web beacons, and other tracking technology, to collect information about your browsing behavior when you visit our Site, including for example, your browser type, domains, page views, IP address, referring/exit pages, information about how you interact with our Site’s webpages and with third-party links, traffic and usage trends on the service, etc. We use session cookies to keep you logged in while you use features of our Site; these disappear after you close your browser. We also use persistent cookies, which stay in your browser and allow us to recognize you when you return to the Site. We use this to remember your information so you will not have to re-enter it, to better understand how you use our website and products and services, to diagnose and fix technology problems, and otherwise enhance our Site, products, and services. In some of our email messages, we use a “click-through URL” linked to content on the Site. We track this click-through data to help us measure the effectiveness of our customer communications. We also use third-party analytics tools (including Google Analytics) to assist us with analyzing and improving our service. Most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our Site may not work for you. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.
- Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes . 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 visitallaboutcookies.org).
Minors: Our Site does not knowingly collect or store any personal information about children under the age of 13.
DATA SHARING: Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the delivery of Phrame Products and services without asking you first. Period. We do not rent or sell our customer lists.
- With your explicit consent: We may share personal information when we have your consent. One example of this would be if you sign up for programs offered by our partners (e.g., energy or insurance companies). If you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device. Similarly, when you connect third-party devices and services to your Phrame Products through the Works with Phrame program, you are shown information about any proposed exchange of data. Your explicit consent is required to allow these exchanges on your behalf and you can change your mind at any time.
- For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems. These technicians (as well as Phrame employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Phrame purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video data.
- As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
- For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States).
We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about energy use or elevated carbon monoxide levels in the home. This information may also be shared with other users to help them better understand their energy usage compared to others in the Phrame community, raise awareness about safety issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.
Your personal information may be collected, processed and stored by Phrame or its service providers in the United States and other countries where our servers reside. As a result, your personal information may be subject to legal requirements, including lawful requirements to disclose personal information to government authorities, in those jurisdictions.
SECURITY: Phrame takes security seriously and cares about the integrity of your personal information. We use commercially reasonable physical, administrative, and technological methods to transmit your data securely including HTTPS, TLS/SSL protocol, AES and RSA data encryption. The data is stored using Amazon’s S3 cloud service. However, Phrame cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
International Visitors: The Phrame website is hosted in the United States and is intended for United States and Canadian visitors as well as visitors from the United Kingdom, Ireland, France, Belgium and the Netherlands. If you are accessing the site from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer.
International data transfers: When we transfer personal data from the European Economic Area to other countries, including to the United States, we use a variety of legal mechanisms to help ensure your data is appropriately protected.
Phrame, Inc. complies with the EU-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal information from the European Economic Area, as described in our Privacy Shield certification.
As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through JAMS based in the US, and under certain conditions, through the Privacy Shield arbitration process. If you have a Privacy Shield-related complaint, please contact us at email@example.com.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants like us may be liable for the transfer of personal information from the EU to third parties outside the EU. Learn more about Privacy Shield here.
If you have any questions, please contact us at firstname.lastname@example.org. Last Updated: September 14, 2016