Privacy Policy

Framewrk Privacy Policy

Effective Date: August 05, 2020

This United States Privacy Policy outlines how Framewrk, Inc. and its affiliates (collectively, the “Company,” “Framewrk,” “we,” “our,” or “us”) process the information we collect about you through our mobile apps, websites, direct mail, and other online services (collectively, the “Services”) and when you otherwise interact with us.

Please note that this policy only applies to the data we collect about individuals in the United States. If you are accessing our Services from the United Kingdom, please refer to our United Kingdom Privacy Policy. If you are a California resident, please also see the “Notice to California Residents” section below.

If you have a Framewrk account, or have taken steps to register for an account, you can also review our Consumer Privacy Notice for a summary of our practices regarding the information we collect about you.

I. What kinds of information do we collect?

To provide the Framewrk Software, we must process information about you. The types of information we collect depend on how you use our app. You can learn how to access and delete information we collect by visiting Framewrk Settings.

Things you and others do and provide.

Information and content you provide. We collect the content, communications and other information you provide when you use our Software, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created.

Our systems automatically process content and communications you and others provide to analyze context and what’s in them for the purposes described below.

Data with special protections:

You can choose to provide information in your Framewrk profile fields about your personal views, professional views, or other business related information. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) could be subject to special protections under the laws of your country.

Profile Data:

Includes your username and password, purchases or orders made by you, your knowledge assessment results, and your interests, preferences, feedback, and survey responses.

Networks and connections:

We collect information about the people and groups you are connected to and how you interact with them across our Software, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device (such as an address book or call log or SMS log history), which we use for things like helping you and others find people you may know and for the other purposes listed below.

Your usage:

We collect information about how you use our Software, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Software, and what posts, videos and other content you view on our Software.

Information about transactions made on our Software:

If you use our Software for purchases or other financial transactions, we collect information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details.

Things others do and information they provide about you:

We also receive and analyze content, communications and information that other people provide when they use our Software. This can include information about you, such as when other users send a message to you.

Device Information

As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Software, and we combine this information across different devices you use. For example, we use information collected about your use of our Software on your phone to better personalize the content (including ads) or features you see when you use our Software on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device.

Information we obtain from these devices includes:

Device attributes: information such as the operating system, hardware and software versions, and browser type.

Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

Identifiers: unique identifiers, device IDs, and other identifiers unique to Framewrk, Inc. Software associated with the same device or account).

Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.

Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, and connection speed.

Cookie data: data from cookies stored on your device, including cookie IDs and settings. Learn more about how we use cookies in the Framewrk Cookies Policy.

Additional Information: Information that you submit via focus groups, contests/sweepstakes, job applications, customer support, or other similar means. We may also collect any communications between Framewrk and you (including recording calls made to or by Framewrk) and any other information you provide to Framewrk.

II. How do we use this information?

We use the information we have (subject to choices you make) as described below and to provide and support the Framewrk Software and related services described in the Framewrk Terms. Here’s how:

Create and process your account and deliver the Services to you.

Allowing you to register for the Software and participate in interactive features and for Framewrk to authenticate your identity, handle billing and account management, fulfill our legal and regulatory obligations such as obligations. To send you transactional information, including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions with us. To communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, contact you about amounts owed, conduct surveys, respond to employment opportunities for which you’ve applied, notify you about upcoming events, or for any other purposes in connection with the Software.

Provide, personalize and improve our Software.

We use the information we have to deliver our Software, including to personalize features and content (including your Home Base, Partner Mode, Mastermind Groups, 1:1 Chats, Diagnostics, Stress Hub, Easter Egg, and ads) and make suggestions for you (such as business recommendations, personal recommendations, groups or events you may be interested in or topics you may want to follow) on and off our Software. To create personalized Software that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide); how you use and interact with our Software; and the people, places, or things you’re connected to and interested in on and off our Software.

Perform audits.

Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements.

Suggestions and recommendations.

Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you, such as providing you with advertisements based on your interests and activity on the Software.

Software research and development.

We use the information we have to develop, test and improve our Software, including by conducting surveys and research, and testing and troubleshooting new products and features.

Ads and other sponsored content.

We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Software, and promote safety and security on and off of Framewrk Software. For example, we use data we have to investigate suspicious activity or violations of our terms or policies, or to detect when someone needs help.

Enhance safety.

Enhance the safety and security of our Software, business, and users, and investigate or provide notice of fraud or unlawful or criminal activity.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Software, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Research and innovate for social good.

We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general demographics, technological advancement, public interest, and commerce.

III. How is this information shared?

Your information is shared with others in the following ways:

People you share and communicate with

When you share and communicate using our Software, you choose the audience for what you share. For example, when you post on Framewrk, you select the audience for the post, such as a group or a customized list of people. Similarly, when you use Framewrk to communicate with people, those people can see the content you send.

Public information can be seen by anyone, on or off our Software, including if they don’t have an account. This includes your Framewrk username; any information you share with a public audience. You, other people using Framewrk and we can provide access to or send public information to anyone on or off our Software, including in other Framewrk Company Software, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Software.

Content others share or reshare about you.

You should consider who you choose to share with, because people who can see your activity on our Software can choose to share it with others on and off our Software, including people and businesses outside the audience you shared with. For example, when you send a message to specific individuals or groups, they can screenshot, or reshare that content to others across or off our Software, in person or virtually. Also, when you comment on someone else’s messages or react to their content, your comment is visible to anyone who can see the other person’s content, and that person can change the audience later.

People can also use our Software to create and share content about you with the audience they choose. For example, people can share information about you in their messages. If you are uncomfortable with what others have shared about you on our Software, you can learn how to report the content.

Information about your active status or presence on our Software.

People in your networks can see signals telling them whether you are active on our Software, including whether you are currently active or when you last used our Software.

Sharing with Third-Party Partners.

We work with third-party partners who help us provide and improve our Software or who, which makes it possible to operate our companies and provide services to people around the world. We don’t sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Advertisers.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don’t share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers to help them better understand their audience. We also confirm which Framewrk ads led you to make a purchase or take an action with an advertiser.

Measurement partners.

We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

Google Analytics and Advertising. We use Google Analytics to recognize you and link your devices and when you use our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us.

We share a unique identifier with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here: www.google.com/policies/privacy/partners/.

You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, here: https://tools.google.com/dlpage/gaoptout/.

We may also use certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features let us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your use of our Software.

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

Partners offering goods and services in our Software.

When you subscribe to receive premium content, or buy something from a seller in our Software, the content creator or seller can receive your public information and other information you share with them, as well as the information needed to complete the transaction, including shipping and contact details.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Software is used, providing customer service, facilitating payments or conducting surveys.

Researchers.

We also provide information and content to research partners to conduct research that advances innovation that supports our business or mission, and enhances discovery and innovation on topics of general demographics, technological advancement, public interest, and commerce.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

IV. How can I manage or delete information about me?

We provide you with the ability to access, rectify, port and erase your data.

We store data until it is no longer necessary to provide our services and Framewrk Software, or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

When you delete your account, we delete things you have posted, such as your messages and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted. If you don’t want to delete your account but want to temporarily stop using the Software, you can deactivate your account instead. To delete your account at any time, please visit the Framewrk Settings.

V. How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Software, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Software), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Software.

Information we receive about you (including financial transaction data related to purchases made with Framewrk) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

VI. How do we operate and transfer data as part of our global services?

We share information globally, both internally within the Framewrk Companies, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the Framewrk Terms and to globally operate and provide our Software to you. We utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States and other countries.

Privacy Notice for California Residents

If you are a California resident, you can learn more about your consumer privacy rights by reviewing the California Privacy Notice.

VII. How will we notify you of changes to this policy?

We’ll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Software.

VII. How to contact Framewrk with questions.

You can learn more about how privacy works on Framewrk. If you have questions about this policy, you can contact us as described below. We may resolve disputes you have with us in connection with our privacy policies.

Children’s Privacy.

We do not knowingly collect or solicit any information from anyone under the age of 13 on this Software. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at beta@framewrkagency.com.

You can contact us online or by mail at:

Email Address

beta@framewrkagency.com

Mailing Address:

Framewrk, Inc.

ATTN: Data Privacy

520 Providence Road

Charlotte, NC 28207

Date of Last Revision: August 05, 2020