Privacy Policy

1. Scope and Controller

1.1 This Privacy Policy describes how Triton Agency, LLC, a South Carolina limited liability company doing business as FriendFrame (the "Company," "we," "us," or "our"), collects, uses, and discloses personal information in connection with the website located at friendframe.com, the web application located at my.friendframe.com, and the FriendFrame applications for television devices (collectively, the "Service").

1.2 The Company is the controller of the personal information described in this Policy. Capitalized terms not defined in this Policy have the meanings given in the Terms of Service.

1.3 By using the Service, you acknowledge the practices described in this Policy.

2. Information We Collect

2.1 Information you provide. We collect the following information when you provide it to us:

1. Account information: your name, email address, and password. Passwords are stored only as a salted PBKDF2 hash; the Company does not store or have access to your password in readable form.
2. Content: photographs you upload, captions you add, and records of the user who uploaded each photograph and the user who approved or declined it.
3. Frame and album information: the names and settings of frames (television displays) and albums you create, and the albums assigned to each frame.
4. Invitation information: the email address of each person you invite, the role assigned, and the identity of the inviting user.
5. Correspondence: the contents of messages you send to us.

2.2 Information collected automatically. We collect the following information when you use the Service:

1. Device information: for each television device paired to the Service, its platform, model, application version, pairing date, and the time it last contacted the Service. We do not collect information about other content viewed on the device.
2. Session information: the creation and last-use times of each signed-in session and the browser user-agent string associated with it.
3. Email delivery records: the recipient, subject, delivery status, and time of each email the Service sends.
4. Network information: IP addresses and request metadata processed by our hosting provider to deliver the Service and protect it against abuse.

2.3 Payment information. Payments for paid plans are processed by Stripe, Inc. ("Stripe"). Payment card details are submitted directly to Stripe and are not received or stored by the Company. We retain the subscription plan, billing status, renewal date, and Stripe customer and subscription identifiers associated with your account.

3. Photographs and Shared Content

3.1 Processing before upload. Before a photograph is uploaded, the Service resizes it within your browser and re-encodes it as a new JPEG file. This process removes embedded metadata, including EXIF data and GPS location. The Company does not receive or retain the original file.

3.2 Visibility. A photograph is visible to the members of the album or frame to which it is shared and is displayed on television devices paired to frames that show that album. Owners and managers of a frame or album may view, approve, decline, and remove photographs shared to it. Invitations are bound to the email address to which they were sent.

3.3 Approval. Photographs submitted by contributors who are not designated as trusted remain pending, and are visible only to the uploader and to the owners and managers of the destination album or frame, until approved.

3.4 Storage and access by link. Photographs are stored by Cloudflare, Inc. and served from cdn.friendframe.com at randomly generated addresses that are not published or indexed. Such addresses are not protected by authentication. Any person who obtains the address of a photograph can retrieve that photograph. You should not disclose photograph addresses publicly.

3.5 Deletion. When a photograph is deleted, it is removed from storage. Copies held in content delivery network caches or on television devices may remain retrievable for up to twenty-four (24) hours after deletion.

3.6 Restrictions on our use. The Company does not sell photographs, use them for advertising, use them to train machine learning models, or apply facial recognition to them.

4. Use of Information

4.1 We use personal information to:

1. create and administer accounts and authenticate users;
2. store photographs and display them to the users and devices with which they are shared;
3. pair, configure, and support television devices;
4. send transactional email, including email address verification, password reset, invitation, and access request messages;
5. process payments and administer subscriptions;
6. respond to support requests;
7. detect, prevent, and investigate fraud, abuse, and security incidents; and
8. comply with legal obligations.

4.2 Where the EU or UK General Data Protection Regulation applies, we process personal information on the following legal bases: performance of our contract with you (Sections 4.1(a) through 4.1(f)); our legitimate interests in operating a secure Service (Section 4.1(g)); and compliance with legal obligations (Section 4.1(h)).

4.3 The Company does not display advertising, does not sell or rent personal information, and does not share personal information for cross-context behavioral advertising.

5. Disclosure of Information

5.1 We disclose personal information only as follows:

1. To other users, to the extent you share content with them. Members of a frame or album can see the photographs, captions, and names associated with content shared to it.
2. To service providers that process personal information on our behalf under contractual obligations: Cloudflare, Inc. (hosting, database, file storage, and email delivery) and Stripe, Inc. (payment processing).
3. To Google LLC, which receives the IP address and browser information of visitors to my.friendframe.com when the application loads its typeface from Google Fonts. The website at friendframe.com does not load third-party fonts.
4. When required by law, subpoena, or other legal process, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of the Company, our users, or the public.
5. In connection with a merger, acquisition, financing, or sale of all or part of our business, subject to the acquirer's continued compliance with this Policy or notice to you of any material change.

5.2 The FriendFrame television applications operate on third-party platforms, including Roku. The platform operator's privacy policy governs its devices and application store. The Company does not provide your account information or photographs to platform operators.

6. Cookies

6.1 The web application at my.friendframe.com sets one cookie, ff_session, which is strictly necessary to keep you signed in. It is a first-party, HTTP-only cookie that expires thirty (30) days after last use and is removed when you sign out.

6.2 The website at friendframe.com sets no cookies. The Service does not use advertising cookies, tracking pixels, or third-party analytics. The Service does not respond differently to browser "Do Not Track" signals.

7. Data Retention

7.1 Account information, photographs, and frame and album settings are retained for as long as the account exists or until deleted by you or by an owner or manager with authority over the content.

7.2 Expired sessions, invitations, and single-use email links are retained only for as long as reasonably necessary for security and troubleshooting.

7.3 You may delete your account at any time from the account settings of the Service, upon confirmation of your email address and password. Deletion takes effect immediately and permanently removes (a) the account information; (b) every frame and album owned by the account, together with all photographs contained in them, including photographs contributed by other users; (c) all photographs uploaded by the account to frames and albums owned by others; and (d) the account's memberships, invitations, sessions, and notification records. Any paid subscription is cancelled at the time of deletion, no further charges are made, and the customer record held by our payment processor is deleted, subject to Section 7.4. A confirmation is sent to the email address associated with the account. Where a deletion request is instead submitted as described in Section 8.3, we complete the deletion within thirty (30) days. Residual copies in backups are deleted in the ordinary course of backup rotation, and cached copies of photographs expire as described in Section 3.5.

7.4 We may retain limited records for longer periods where required by law, including billing records required for tax purposes.

8. Your Rights

8.1 You may update your name, content, frames, and albums within the Service at any time.

8.2 You may obtain a copy of your personal information in a portable, machine-readable format (JSON) from the account settings of the Service, no more than once in any twenty-four (24) hour period. The export contains your account information; the frames and albums you own or that are shared with you; your memberships and the invitations you sent and received; and a list of the photographs you uploaded or that are contained in albums you own, together with their captions, dates, and links through which the photographs may be retrieved. Photograph files themselves are not included in the export. A link to the export is sent to the email address associated with the account and remains valid for seven (7) days, after which the export is deleted. You may delete your account as described in Section 7.3.

8.3 Subject to applicable law, you may also request that we provide a copy of, correct, delete, or export in a portable format the personal information we hold about you by writing to privacy@friendframe.com from the email address associated with the account. We may require verification of your identity before fulfilling a request and will respond within thirty (30) days or such other period as applicable law requires.

8.4 Residents of the European Economic Area, the United Kingdom, and certain U.S. states, including California, may have additional rights under applicable law, including the right to object to or restrict certain processing and the right to lodge a complaint with a supervisory authority. We will not discriminate against you for exercising any of these rights.

9. Children

9.1 The Service is not directed to children under thirteen (13) years of age, and the Company does not knowingly collect personal information from children under thirteen. If we learn that an account has been created by a child under thirteen, we will delete it. Parents or guardians who believe this has occurred may contact us at the address in Section 13.

9.2 A user who uploads photographs depicting other individuals, including minors, is responsible for having the right to share those photographs and for sharing them only with appropriate recipients.

10. Security

10.1 The Service encrypts data in transit using TLS. Passwords and session tokens are stored only as cryptographic hashes, television pairing uses short-lived single-use codes, and authorization to access frames and albums is verified on each request.

10.2 No method of transmission or storage is completely secure, and the Company cannot guarantee absolute security. In the event of a security breach affecting your personal information, we will notify you as required by applicable law.

11. International Transfers

11.1 The Company is located in the United States. Our service providers may process personal information in the United States and in other countries in which they operate. If you use the Service from outside the United States, your personal information will be transferred to, and processed in, countries whose data protection laws may differ from those of your country of residence.

12. Changes to This Policy

12.1 We may amend this Policy from time to time. The effective date at the top of this Policy indicates when it was last revised. If we make a material change, we will notify you by email or through the Service before the change takes effect.

13. Contact Information

13.1 Questions and requests regarding this Policy may be directed to: