What Information We Collect
As a general matter, you can browse the Website without submitting your personal information to us. However, there are a number of circumstances in which you may need to provide us with your personal information. The following lists the most common ways in which we collect your personal information:
- When you sign up to receive email communications from us;
- In conjunction with processing your grant applications;
- When you register for and participate in our conferences, programs, initiatives, and events;
- When you request information or assistance;
- When you communicate with us through the Website;
- In conjunction with your employment inquiries or applications;
- When you participate in surveys, panels, or research;
- When you participate with social media accounts involving FRAME properties; and
- In conjunction with any other place on the Website where you knowingly volunteer personal information.
When you interact with any FRAME page or account on a social media platform, such as Twitter, Instagram, Facebook, YouTube, or LinkedIn, we may also collect the personal information that you make available to us on that page or through that account, including your account ID or “handle.”
In addition, when you interact with the Website, our servers may keep an activity log that does not identify you individually (“Non-Personal Information”). Generally, we collect the following categories of Non-Personal Information:
- We may collect certain demographic data such as age, gender, and five-digit zip code as part of collecting personal information;
- We collect and store certain device information about your computer, mobile device, or other device that you use to access the Website. This information may include IP address, geo-location information, unique device identifiers, browser type, browser language, and other transactional information;
- We collect and store additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses; and
- We collect and store your search terms and search results.
We also collect and store certain other information regarding our users’ use of the Website so that third parties may provide us with reports and analysis regarding usage and browsing patterns of the Website.
How We Combine Your Information
We may combine information gathered from the Website and information that we have received, gathered, acquired, or stored from other sources, both information collected offline by FRAME and information received from third parties—including information that currently exists in our files—into a single customer record. We also use and/or combine information that we collect offline or receive from third-party sources (e.g., contact information from government funders or grantor information) to edit, enhance, and/or check the accuracy of your customer record.
How We Use Your Information
We use the information we learn from you to help us personalize and continually improve your experience on the Website. We use your Personal and Non-Personal Information in the following ways:
- For editorial purposes;
- Responding to your inquiries;
- Communicating with you about your account or transactions with us and sending you information about features on our Website or about FRAME;
- Communicating with you about changes to our bylaws or policies;
- Sending you newsletters, mailings, and information about programs, grants, initiatives, and events by email or another medium;
- Processing your grant application or employment application;
- Conference or program registration; and
- Performing statistical, demographic, and marketing analyses of users of the Website and their usage patterns.
How We Share Your Information
FRAME adheres to the highest standards of ethical practices in all our operations and is dedicated to protecting the privacy of all visitors to our Website. Except as disclosed below, we don’t sell, barter, give away, rent, or permit anyone outside the network to use or access your personal information and in all cases we only share your personal information where it is in the legitimate interest of furthering the philanthropic aims of FRAME.
We occasionally use independent contractors and third-party agents, affiliates, and partners to perform functions such as marketing, analytics, providing customer service, etc., on our behalf. These entities have access to the personal information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of any personal information collected from the Website. They are restricted from using, selling, distributing, or altering this data in any way other than to provide the requested services to FRAME.
We may also use or disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) protect and defend our rights or property, the Website, or our users; and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, our agents, or the users of the Website or the public.
FRAME strives to protect the transmission and storage of any information submitted by visitors to the Website. But no transmission and storage of data is completely secure, and submissions are at your sole risk.
General Data Protection Regulation
The General Data Protection Regulation (GDPR) is a European Regulation concerning the use and processing of personal information. We are committed to processing your information in compliance with the GDPR upon its effectiveness on May 25, 2018.
We will use reasonable efforts to securely process all personal information in line with the rights specified under the GDPR, in particular those related to the following requests:
- Access to your personal information;
- Correction of the personal information that we hold;
- Deletion of your personal information;
- A restriction of processing of your personal information;
- Transfer of your personal information to another party; or
- Objection to processing of your personal information based on FRAME’S legitimate interest (or those of a third party) to use it and there is something about your particular situation that causes you to object to such processing.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- You can change your personal information by emailing us.
How we handle Do Not Track signals
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Children Online Privacy Protection Act
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify you via email within 7 business days.
We also agree to the Individual Redress Principle, which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
To be in accordance with CAN-SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
We consider that FRAME has a legitimate interest in collecting and processing your information. FRAME is dedicated to fostering exploration, understanding, and enjoyment of the visual arts of the United States and France for national and international audiences and pursuing these aims is not in conflict with your rights. This provides our lawful basis to use your personal information, within the limitations set forth herein.
If you have any questions or requests regarding this policy, if you would like to change your preferences, if you no longer wish to receive email updates from FRAME, or if you believe we have erroneous or incomplete information about you, please contact us using the information below.
FRAME North America
PO Box 5