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Policy & Procedures

FINE FRAME STUDIOS LLC

PRIVACY POLICY

 

Effective Date: January 1, 2025

Note to Facebook®, LinkedIn® and Other Social Media Users

When visiting our Facebook® page, LinkedIn® profile or other page on social media websites, and when posting information to or otherwise communicating via that page, your activities online are subject to the Privacy Policy of that social media website, which may contain terms and conditions different from Fine Frame Studios’s Privacy Policy.  Please see the following pages for further details:

What This Privacy Policy Covers

 

  • This policy covers how Fine Frame Studios LLC (“Fine Frame Studios”) treats personal data that Fine Frame Studios collects and receives, including information related to your use of Fine Frame Studios equipment or services. 

  • References to "data" in this Privacy Policy will refer to whatever data you use within our website and any equipment and services procured using our website to collect and or process, whether it is data collected in a form, data inserted on a site hosted by us, or data acquired on your behalf from sources internal or external to your organization. 

  • “Personal data” is defined as information about you that is personally identifiable, such as your name, mailing address, email address, or other contact information, and that is not otherwise publicly available

  • References to “GDPR” in this Privacy Policy refer to the General Data Protection Regulation adopted by the Parliament of the European Union and published as Regulation (EU) 2016/679 (General Data Protection Regulation), which become effective on May 25, 2018.  The full text of the GDPR in English can be viewed at https://gdpr-info.eu/.

  • This policy does not apply to the practices of companies that Fine Frame Studios does not own or control or to people that Fine Frame Studios does not employ or manage.

  • This policy does not apply to non-personal data, which means any data or information other than “personal data” as described above.

  • This Privacy Policy is effective on January 1, 2025 or the date upon which you enter into a contract for one or more of Fine Frame Studios’ services, whichever is later.

 

Information Collection and Use

 

  • Fine Frame Studios collects personal data when you register with Fine Frame Studios, when you use Fine Frame Studios equipment or services, when you visit Fine Frame Studios’s website, and when you enter Fine Frame Studios promotions or special offer codes.

  • When you register we ask for information such as your name, alternate email address, zip code, company name, and contact information. Once you register with Fine Frame Studios and use our services, you are not anonymous to us.

  • Fine Frame Studios collects information about your transactions with us and with some of our business partners and affiliates, including information about your use of the equipment and services that we offer.

  • Fine Frame Studios may automatically receive and record information on our server logs from your browser, including your IP address, Fine Frame Studios cookie information, and the page you request.

  • Fine Frame Studios uses information for the following general purposes: to customize our website, advertising and content, to fulfill your requests for equipment and services, to improve our services and customer relations, to contact you, and to conduct research.

  • Fine Frame Studios and/or our selected third-party partners may also collect data about visitors’ activities on this Website and across the Internet over time for non-advertising purposes, including to conduct analytics, measure trends, and streamline website usability. The technologies used for this purpose may include log files, cookies, web beacons, and social media plug-ins. One of the service providers we may use is Google Analytics. To learn more about how Google Analytics collects and processes data and the choices you may have to control these activities, you may visit https://www.google.com/policies/privacy/.

  • Fine Frame Studios does not knowingly collect or obtain from you or third parties, any “Sensitive Personal Data,” as defined under the GDPR. “Sensitive Personal Data” are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.

 

 

Children

 

  • Fine Frame Studios complies with the U.S. Children’s Online Privacy Protection Act (COPPA) and does not knowingly collect personal data from children under the age of thirteen (13) or from websites or online services directed to children under the age of thirteen (13).

  • If you are a visitor from the United Kingdom, the European Union (EU) or Switzerland, Fine Frame Studios does not process the personal data of a child younger than 16 years old. Fine Frame Studios makes reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility over the child, taking into consideration available technology.

  • Consumers should not create Fine Frame Studios accounts on our Website or license our services, unless they are legally old enough to from a binding contract and in any case are 18 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 18, who has registered with the Fine Frame Studios website or has licensed services from us, please contact info@fineframestudios.com to have your child’s personal data deleted.

 

 

Information Sharing and Disclosure

 

  • Fine Frame Studios does not sell, rent, or share personal data about you with other people or non-affiliated companies except to provide equipment or services that you have requested, when we have your permission, and under the following circumstances:

  • We provide the information to trusted partners and affiliates who work on behalf of or with Fine Frame Studios under confidentiality agreements. These companies may use your personal data to help Fine Frame Studios communicate with you about offers from Fine Frame Studios and our marketing partners and affiliates. However, these companies do not have any independent right to share this information;

  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or to defend against legal claims;

  • We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Fine Frame Studios’s terms of service, or as otherwise required by law;

  • We transfer information about you if Fine Frame Studios is acquired by or merged with another company. In this event, Fine Frame Studios will notify you before more information about you is transferred and becomes subject to a different privacy policy.

  • Fine Frame Studios may display targeted advertisements based on personal data. Advertisers (including ad serving companies) may assume that people who interact with, view, or click on targeted ads meet the targeting criteria.

  • Fine Frame Studios will not provide any personal data to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.

  • Fine Frame Studios advertisers may include financial service providers (such as banks, insurance agents, stock brokers and mortgage lenders) and non-financial companies (such a stores, airlines, and software companies).

  • If you are a franchisee or franchised business, Fine Frame Studios assumes that your franchise agreement requires you to disclose personal data about you and your business to your franchisor upon their request at any time. If Fine Frame Studios receives a request by your franchisor to disclose personal data about you or your business at any time, we will disclose such information solely to your franchisor and copy our account contact for your group on any such disclosure. Any such disclosure will be subject to your franchisor's privacy policy, rules and regulations as set forth in your franchise Operations Manual or on your franchisor's Website. and Fine Frame Studios will have no obligation or liability to you whatsoever with respect to such disclosure. 

 

Cookies

 

  • Fine Frame Studios and our partners use cookies and similar technologies on our website that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:

  • To gather metrics about your experience.

  • To make our services easier to use.

  • For security reasons.  We use cookies to authenticate your identity and confirm whether you are currently logged into Fine Frame Studios or determine if an incident impacts you.

  • To provide you with personalized content.  We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.

  • To improve our services.  We use cookies to measure your usage of our services and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimize the content we display to you (which may include marketing content).

  • To advertise to you.  Fine Frame Studios, or our service providers and other third parties we work with, place cookies when you visit our website and other websites or when you open emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, we evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive ads that are tailored to you based on your online activity, you may contact our customer service department and ask to “opt out”. Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.

 

Your Rights 

 

  • You have the right to access the information that Fine Frame Studios maintains about you, request deletion of your data, update your data, object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data and you correct or amend that information if it is inaccurate or has been processed in violation of privacy laws, to the extent allowed by United States or Canadian law.

  • If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

  • You have the right to opt-out from our marketing communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contacting Us” heading below.

  • You can choose to have Fine Frame Studios delete your record after account cancellation.  Some information may remain archived in our system records after your account has been deleted.

  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

To exercise these rights, please email info@fineframestudios.com.

Confidentiality and Security

 

  • We limit access to personal data about you to employees who we believe reasonably need to come into contact with that information to provide equipment or services to you or in order to do their jobs.

  • We have physical, electronic and procedural safeguards to protect personal data about you.

  • Your Fine Frame Studios account information is password-protected.

  • In certain areas Fine Frame Studios used industry-standard SSL-encryption to protect sensitive data transmissions.

  • Fine Frame Studios encourages our customers to use SSH and SCP (secure Telnet and FTP) programs in order to better safeguard customer data.

 

How Long Do We Keep This Information For?

 

  • Fine Frame Studios retains personal data we collect from you as long as we have an ongoing legitimate business need to do so (for example, to provide you with a product or Personal data is defined as information about you that is personally identifiable, such as your name, mailing address, email address, or other contact information, and that is not otherwise publicly available

  • Fine Frame Studios will delete or otherwise discard customer data or data we collect about you while using our services at our discretion or when you contact us to do so.  You can initiate such a request by contacting our customer service department at info@fineframestudios.com. 

 

International Transfers

 

  • Fine Frame Studios operates its technology from servers located in the United States and the information it collects through clients is processed solely in the United States. Laws governing the collection and use of data in the United States may not be equivalent to those in the country where you reside but Fine Frame Studios will at all times protect your data in accordance with this Privacy Policy.

  • Fine Frame Studios may share your information with our affiliates and other third parties described above who are based in countries outside of your country of residence. While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take all reasonable measures to protect your information in accordance with this Privacy Policy and all applicable legal requirements.

  • If any of the recipients is located in a country without the adequate legal protection or safeguards for personal data, Fine Frame Studios will make reasonable efforts so the recipient adopts the principles described in this Privacy Policy.

Visitors from Outside the United States

This Privacy Policy is intended to cover collection of information on the Fine Frame Studios website from residents of the United States of America. At the present time, Fine Frame Studios’ equipment and services are not intended for use outside of the United States. However, if you are visiting our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country or those of the GDPR. Please be assured that we seek to take reasonable steps consistent with United States law to ensure that your privacy is protected. By using our website, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

PRIVACY NOTICE FOR CERTAIN U.S. STATE RESIDENTS

This Supplemental Notice applies solely to residents of the States of California, Virginia, Colorado, Connecticut, and Utah who have interacted with us in the ways described in the introduction of this Privacy Policy, and who have certain privacy rights under the applicable laws in their state (respectively, the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act; collectively, “Certain State Privacy Laws”)

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We do not collect any “sensitive personal information” as defined under Certain Privacy laws. The length of time we retain this information is generally twelve months.  In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected [indicate “yes” or “no”]

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

 

B. Personal information categories

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

 

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

 

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

 

G. Geolocation data.

Physical location or movements.

 

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

 

I. Professional or employment-related information.

Current or past job history or performance evaluations.

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

 

K. Audio, electronic, visual, or similar information

Recording of service calls

 

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from users of our website when the user or their agent provides personal information to us.

  • Indirectly from you.  For example, by observing your interactions on our website and by using cookies.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: Personal Information categories.

Category D: Commercial Information

Category F: Internet or other similar network activity.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes other than those set forth in our Privacy Notice without providing you notice.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our Affiliates.

  • Service providers and business partners.

  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information of consumers collected from the Website as defined by Certain Privacy Laws.

We have shared personal information with our Affiliates and service providers as disclosed above.

Your Rights and Choices

Certain Privacy Laws provide their residents with specific rights regarding their personal information. This section describes your rights if you are a resident subject to the Certain Privacy Laws and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you.

  • The categories of personal information sold, the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and

  • The categories of personal information disclosed for a business purpose.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Opt-Out Request Rights

You have the right to opt-out of the sharing of your personal information that we collected from you. Once we receive and confirm your verifiable consumer request to delete your personal information, we will delete (and direct our service providers to delete) your personal information from our records and stop sharing it, unless an exception applies. 

Right to Request Correction of Inaccurate Information

You have the right to request correction of inaccurate information.  Once we receive and confirm your verifiable consumer request, we will correct any inaccurate information identified in the request our records, unless an exception applies.

Right to Appeal

If you are a Virginia, Colorado or Connecticut resident and we were unable to fulfill your request, we will notify you. You may appeal our decision by emailing us at [e-mail address of client] within fourteen calendar days, including “Appeal Request” in the subject line, with a detailed reason for your appeal, as well as your state of residence. If you are dissatisfied with our decision on your appeal, you may contact your applicable state Attorney General:

Virginia:

202 North Ninth Street

Richmond, Virginia 23219

Colorado:

1300 Broadway, 10th Floor

Denver, CO 80203

Connecticut:

https://www.dir.ct.gov/ag/complaint/

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either:

  • Calling toll free at [toll-free telephone number of company] or by submitting a request to [e-mail address of company].

  • Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request, to process and fulfill the request, and for necessary record keeping.

Process Used to Verify an Access and/or Deletion Request

You will be required to submit 4 pieces of information including your name, address, email, and phone number. We will use this information to search our systems and determine if we have information about you. If we are able to locate information about you, we will fulfill your access and/or deletion request. If we are not able to match all 4 pieces of information you submit, we may provide you with a report that includes the categories of personal information we collect, use, disclose, and sell.

Response Timing and Format

We try to respond to a verifiable consumer request within 45 days of its receipt, unless a shorter time period applies under Certain Privacy Laws.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Certain Privacy Laws.

Changes to this Privacy Policy

Fine Frame Studios may revise this policy at any time. You can review the most current version of the Privacy Policy at any time at this page.

We reserve the right, at our sole discretion, to update, change or replace any part of this Privacy Policy by posting updates and changes to our website. It is your responsibility to check our website periodically for changes. Your continued use of or access to our website or any product or service procured using our website following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.

Questions and Suggestions

 

If you have questions or suggestions, please contact us at info@fineframestudios.com.

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