Privacy Policy

Last Revised and Effective Date: September 2022

Framework Co. and our subsidiaries and affiliates (collectively, “Framework”, “we”, “us” or “our”) care about the processing, confidentiality, and safety of your personal data.

The aim of this Privacy Policy is to provide you with information about how we collect, use, share, and safeguard your personal data. This Privacy Policy also tells you about your rights and choices with respect to your personal data, and how you can reach us to get answers to your questions. You can jump to particular topics by going to the headings below:

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I. What is personal data?

The term “personal data” refers to any information about an identified physical person or a physical person that may be directly or indirectly identified.

II. What personal data do we collect and when do we collect it?

We collect information about you in a variety of ways depending on how you interact with us and our products and services, including through our websites, media channels, online and mobile applications, and advertisements.

· The following provides examples of the type of personal data that we collect from you and how we use that information.

Information we collect:
If you contact us, such as via our website, customer service center, or social network pages, we collect your name, contact information (email and/or phone number) as well as any other information you provide to us in order to reply.

Primary Purpose for Collection and Use of Information:
We have a legitimate interest in managing customer relations with respect to any requests for information or complaints that we receive. We also have a legitimate interest in responding to inquiries related to support, employment opportunities, and other requests.

III. For what purpose is your personal data collected and used?

In addition to the purposes and uses described above, we use data in the following ways:

· To identify you when you visit our websites.

· To manage our relationships as well as for internal administrative purposes.

Although the sections above describe our primary purpose in collecting your personal data, in many situations we have more than one purpose. As a result, depending on the requirements of applicable privacy laws, our collection and processing of your personal data is based in different contexts upon your consent, our legal or regulator obligations, and/or our legitimate interest in conducting our business.

IV. Who are the recipients of your personal data?

In addition to the specific situations discussed elsewhere in this Privacy Policy, we share personal data in the following situations:

· Affiliates. We may share personal data with our corporate affiliates (e.g., parent company, subsidiaries, and brands) when those entities are processing personal data on our behalf.

· Business Transaction. If another company acquires, or plans to acquire, our company, business, or our assets, we will share personal data with that company, including at the negotiation stage for the purposes of evaluating or completing the transaction. Personal data may also be included as a part of the purchased assets.

· To Provide a Service You Request. We may share your personal data to comply with your request for the provision of services by a third party intermediary.

· Other Disclosures with Your Consent. We may ask if you would like us to share your personal data with other third parties who are not described elsewhere in this Privacy Policy.

· Other Disclosures without Your Consent. We may share personal data with third parties in response to subpoenas, warrants, court orders, or other requests from legal or regulatory authorities; in connection with any legal process; or to comply with relevant legal, regulatory or treaty obligations. We may also share your personal data in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

· Service Providers. We share your personal data with service providers. Among other things, service providers help us to administer and maintain our websites, and send communications,

V. International transfers of personal data

As a company we transmit information between and among our affiliates and may also use service providers that are located outside of your country of residence. As a result your personal data may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal data using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal data to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.

VI. How do we protect your personal data?

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal data from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal data. In the event that we are required by law to inform you of a breach to your personal data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

VII. What are your choices and how can you exercise them?

You may have the following choices regarding your personal data:

· Access to Your Personal Data. You may request access to your personal data, including a copy of your personal data, by following the instructions described in the “Contact Details” section below. If required by law, upon request, we will grant you reasonable access to the personal data that we have about you.

· Changes to Your Personal Data. We rely on you to update and correct your personal data. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain personal data, you may contact us at the address described in the “Contact Details” section below.

· Deletion of Your Personal Data. Typically we retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of personal data, or request that we delete your personal data by following the instructions described in the “Contact Details” section below. If required by law we will grant a request to delete personal data, but you should note that in many situations we must keep your personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

· Objection to Certain Processing. You may object to our use or disclosure of your personal data by contacting us at the address described in the “Contact Details” section below.

· Revocation of Consent. If you revoke your consent for the processing of personal data then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described in the “Contact Details” section below.

· Online Tracking. We do not currently recognize or respond to automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Please note that to protect your personal data we must be able to verify your identity before we can process your request to exercise any of the choices described in this section. We may conduct the verification process by email or phone, and we will ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship. We will then match this to the information we maintain in our records.

In some circumstances, certain individuals may designate an authorized agent to submit requests to access or delete personal data. We will require verification that the authorized agent has permission to make such a request.

VIII. Cookies and Similar Tracking Technologies

We may use a variety of technologies such as cookies, web beacons, clear GIF, pixels, internet tags, and browser/web logs to gather information when you visit or interact with our websites, mobile apps, and email communications. We may use this information for a variety of purposes, such as to make our websites work properly, to make a user’s experience more efficient, and to understand how visitors interact with our websites.

Cookies are small text files that are placed on your computer or mobile device by websites you visit. Cookies are either “persistent cookies” or “session cookies.” Persistent cookies allow websites to remember your information and settings when you return to the website or interact with our services repeatedly. Persistent cookies stay on your browser until you delete them or they expire. Session cookies only last for as long as your session and are erased when you close your browser.

The following information explains the cookies we may use and why:

· Necessary and Functional. Some technology is needed for the operation of our website. This may include cookies that enable basic functions such as page navigation and access to secure areas of the website. Because our website cannot function properly without this technology, it is always active. Note that while you can set your browser to block this type of technology, doing so may cause some parts of our websites to not work.

You can set your browser to refuse some or all cookies, or to indicate when a cookie is being sent to your computer. However, this may prevent our websites or services from working properly. You can also set your browser to delete cookies every time you finish browsing. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

IX. Contact Details

You can exercise any of the rights described above in the “What are your choices and how can you exercise them?” section above by sending an email to jpincu@frameworkco.com, by mailing a non-registered letter with a document proving your identity to the below address:

Frameworkco.

Attention: Jenny Pincu

9255 W. Sunset Blvd., 2nd Floor

Los Angeles, CA 90069

If you are submitting a request on behalf of another person, you must provide proof that you have been authorized by the individual to act on his or her behalf. In certain circumstances, we may ask the individual to verify his or her own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. For all questions relating to the collection and processing of your data by Framework, you can contact Jenny Pincu at jpincu@frameworkco.com.

X. Additional Information for California Residents

California law indicates that organizations should disclose whether certain categories of personal data are collected, “sold,” or disclosed for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share about online visitors and customers and how we share that information here. If you would like more information concerning the categories of personal data (if any) we share with third parties or affiliates for those parties to use for direct marketing, please contact us

using the information in the “Contact Details” section above. We do not discriminate against California consumers who exercise any of their rights described in this policy.

XI. Miscellaneous

The following additional information relates to our privacy practices:

· Changes To This Privacy Policy. We may change our privacy policy and practices over time. You can check the legend at the top of this page to see when this Privacy Policy was last revised. To the extent that our Privacy Policy changes in a material way, the policy that was in place at the time that you submitted personal data to us will generally govern that data unless we receive your consent to the new privacy policy.