Frameo Privacy Policy

Changelog

If you do not agree to the updated Privacy Policy, you may terminate your account before the changes take effect on 28/08 - 2026.

Last Updated: 14/08 - 2026
In Force: 28/08 - 2026


Frameo A/S ("Company" or "frameo" or "we" or "us" or "our") operates http://frameo.net/ and http://frameo.com/ (the "Site") and provides the Frameo mobile app for Android and iOS (the "app") and the Frameo frame app (the "Frame"). Together these are referred to as the "Services". This policy describes what personal data we collect, why we collect it, and how we use it. You may find our Terms of Service here.

Types of personal data, purpose, and legal basis

As a general rule our Services are not directed to children under the age of 16 (or the minimum age of consent for data processing in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child below the applicable age of consent, we will delete the account and associated personal data promptly.

End-user

When using Frameo Sites

Data collected & purpose

When using our Sites we use strictly necessary cookies for functionality. Where you have given consent, we may also use cookies for analytics, user experience improvements, or targeting. You can withdraw consent through your browser or device settings. Third parties may also use cookies depending on your browser and device settings. If you use our support services, we store only the information needed to help you: your email, name, and anything you provide in a support request.

Legal basis

We only store personal data from your use of our Sites where you consent. You can withdraw your consent at any time by contacting us (see contact information below). You also have the right to access, rectify, erase, or restrict the processing of your personal data, or to lodge a complaint with the supervisory authority. In some cases, acting on your request may mean we can no longer provide our Services to you.

Deletion of data

Any data contained in cookies is deleted when the cookie expires or is deleted by you. Other analytical data such as IP addresses are deleted after 13 months. Personal data stored when using our support services will be stored for as long as you are a user, but for no longer than two years in order to provide you with the best support experience. Any attachments like pictures, videos etc. you may send to us will be deleted the day after receiving them.

When using Frameo apps

Data collected & purpose

To use our app you need to create an account with your name and email. You can also sign up using your Google, Apple, or Facebook account. If you do, we receive your name and email address from that provider to create your Frameo account. We do not receive your password. The provider may also record that you used their account to sign in to Frameo; please refer to the provider's own privacy policy for details on how they handle that information. Providing your name and email address is necessary to create an account and use the Services. If you choose not to provide this information, we cannot offer you the Services. If you subscribe to a paid plan, we add your subscription status to your account. Payment processing is handled entirely by Google Play or the App Store. We do not see, store, or collect your payment card information.

When you use the app, we store log data that may include your IP address, device identifiers, and information about which frames you are connected to. We use this data to maintain the Services and to improve them. IP addresses are anonymised wherever possible.

Where analytics data is processed outside the EU, it is handled by processors certified under the EU-U.S. Data Privacy Framework. In cases where a processor is not DPF-certified, we use Standard Contractual Clauses (SCCs) under Article 46(2)(c) of the GDPR.

We only use your data for marketing where you consent, and you can withdraw that consent at any time through the app or via the opt-out link in any marketing email. We do not have access to your photos, videos, captions, or reactions. All content shared between the app and the frame is end-to-end encrypted using double ratchet encryption. Content may be temporarily stored in encrypted form during transit on our encrypted cloud storage provider, but Frameo and the storage provider cannot decrypt or view it at any point.

Legal basis

We collect this information either with your consent, under Article 6(1)(b) of the GDPR where it is necessary to provide the Services under our contract with you, or under Article 6(1)(f) (legitimate interest) where we use log data to improve service quality and performance. You have the right to object to processing based on legitimate interest.

Deletion of data

For marketing, we keep your consent until you withdraw it or until it has not been used for one year. We may retain documentation of withdrawn consent for up to 2 years to defend against claims under the Danish Marketing Act (§ 37(3)) and the Danish Penal Code (§ 93(1)(1)). All other personal data is deleted when you delete the app, your account, and cancel any subscriptions, no later than two days after that point.

When using the Frame

Data collected & purpose

For the frame specifically we only store IP address and a unique ID used to facilitate communication between the frame and the apps, where you have given permissions to others to use your frame.

Legal basis

We process this information under Article 6(1)(b) of the GDPR, as it is necessary for the performance of the contract we have with you in order to keep the Services running.

Deletion of data

Any personal data is deleted whenever you delete the app, the account, and cancel any subscriptions you may have with us, no later than two days after this point. The data stored locally on the Frame, like your pictures and videos and all log data stored locally, can be deleted by factory resetting the Frame.

Third-party data processors

To provide our Services, we share certain personal data with third-party data processors in the following categories. All processors are engaged under data processing agreements and are required to process personal data only on our instructions and in accordance with applicable data protection law.

Category

Purpose

Cloud infrastructure and hosting providers

Storing and serving application data, user accounts, and backups

Analytics and monitoring providers

App performance, crash reporting, and log analysis

Customer support platforms

Managing and responding to support requests

Email and marketing communication providers

Transactional emails and, where you have consented, marketing communications

Encrypted cloud storage providers

Encrypted storage for content in transit between the app and the frame, and backup storage for Frameo+ subscribers who use the backup feature. Content is end-to-end encrypted; the provider cannot access it

In-app subscription optimisation

Testing and optimising subscription flows and paywall presentation within the app

Most of our processors are based in the United States. For transfers of personal data outside the European Economic Area, we rely on Standard Contractual Clauses (SCCs) adopted under Article 46(2)(c) of the GDPR, or, where the processor is certified, the EU-U.S. Data Protection Framework.

Payment processing

Subscription payments are processed directly by Google LLC (Google Play) and Apple Inc. (App Store). Frameo does not receive, store, or process your payment card information. Google and Apple act as independent data controllers for payment data; please refer to their respective privacy policies for details.

In-app subscription optimisation

We use a third-party service to test and optimise how subscription options are presented in the app. This processing involves device identifiers, subscription status, and interaction data (such as which screens you view and which options you select). It does not involve your photos, videos, or other content. Variant assignment is randomised and not based on individual profiling.

We process this data under Article 6(1)(f) of the GDPR (legitimate interest). Our interest is improving the clarity and relevance of our subscription offerings. You have the right to object to this processing by contacting us.

Anonymisation and product development

We use anonymised behavioural and usage data to improve our algorithms, generate statistics, and benchmark performance across our user base. This covers data like feature usage, session patterns, and app interactions. It never includes your photos, videos, captions, or reactions, which are end-to-end encrypted and inaccessible to us.

This data is aggregated and stripped of identifying information before it is used for product development. Once anonymised, it is no longer personal data under the GDPR and may be retained for as long as it is useful.

If you request deletion of your personal data, we will delete all data that identifies you. Anonymised data that has already been incorporated into our models or statistical datasets cannot be traced back to you and is not affected by deletion requests.

Legal basis

We process behavioural data for product development under Article 6(1)(f) of the GDPR (legitimate interest). Our interest is improving the quality and performance of our Services. You have the right to object to this processing by contacting us (see contact information at the bottom of this page).


Security

We protect your personal data with technical and organisational measures in line with GDPR Article 32, including encryption in transit and at rest and access controls limiting who within Frameo can access personal data. Your photos, videos, captions, and reactions are end-to-end encrypted. Frameo cannot access this content.

Data breaches

If we become aware of a personal data breach likely to affect your rights, we will notify the Danish Data Protection Agency (Datatilsynet) within 72 hours as required by GDPR Article 33. If the breach poses a high risk to you, we will also notify you directly without undue delay under GDPR Article 34.

Using Frameo in a business context

If you use our Services through an employer, Frameo remains an independent data controller. This applies whether your employer purchased Frameo for you or you signed up with a work email address. We process your personal data under this Privacy Policy, not your employer's instructions.

Your employer cannot instruct us on how we collect, use, or delete your personal data, and the employment relationship alone does not give your employer access to your account or data. Your data subject rights belong to you as an individual, regardless of how your account was set up or funded.

GDPR specific provisions and data subject rights

By signing up for our Services you enter into a contract with Frameo. The legal basis for each type of processing is stated in the relevant section above.

Retention and deletion of Personal Data

We have outlined how long and how we delete your personal data in the sections above.

Data subject rights

As a 'data subject' you have the following rights under the GDPR:

When you exercise your rights under the GDPR we do not use automated decision making.

How to exercise your rights

To exercise any of the above rights, please contact us by email at [email protected] or by submitting a support request at support.frameo.com. Please include your name, the email address associated with your Frameo account, and a description of the right you wish to exercise so that we can verify your identity and process your request efficiently.

We will respond to your request within one month of receipt. If your request is complex or we receive a high volume of requests, we may extend this period by a further two months. If we extend the deadline we will notify you within the first month and explain the reason for the delay, as required by GDPR Article 12(3).

There is no charge for submitting a request. If requests are manifestly unfounded or excessive, we reserve the right to charge a reasonable administrative fee or refuse to act on the request, in accordance with GDPR Article 12(5).

To lodge a complaint with the supervisory authority, please refer to the contact information at the bottom of this page.

California residents specific (CCPA & CPRA)

California residents have been afforded the following rights under the CCPA:

These were expanded under Proposition 24, also known as CPRA. The rights under the CPRA are as follows:

To exercise your rights, we will verify your identity using your email, name, and where applicable the QR code of a connected Frame.

We do not sell your personal information. We share data with third-party processors only where necessary to provide the Services, under data processing agreements aligned with the GDPR. If you opt out of this sharing, we may not be able to provide the Services.

You can opt out of marketing at any time through the app or via marketing emails. An authorised agent may also exercise your rights on your behalf by contacting us with the proper authorisations.

We only disclose sensitive information where required by law. For details on the categories of personal information we collect and the purposes for processing, see the sections above.

To exercise your CCPA/CPRA rights, contact us using the information at the bottom of this page. We respond within 45 days and will notify you if we need an extension of up to 90 days.

United Kingdom residents (UK GDPR)

Frameo A/S is not established in the United Kingdom. However, we offer our Services to residents of the United Kingdom and are therefore subject to the UK General Data Protection Regulation (UK GDPR), as retained in UK law by the Data Protection Act 2018.

Your rights

UK residents have the same data subject rights as described in the GDPR section of this policy. To exercise your rights, contact us using the information at the bottom of this page.

UK supervisory authority

If you are a UK resident and wish to lodge a complaint about our processing of your personal data, you may contact the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
United Kingdom
Tel: +44 303 123 1113
https://ico.org.uk/make-a-complaint/

EU Data Act

The Frameo Frame software qualifies as an integral part of a connected product (a Digital Photo Frame) within the meaning of Article 2(5) of the EU Data Act. In the context of the Frameo system the following qualify as related services within the meaning of Article 2(6) of the Data Act: the Frameo iOS app and the Frameo Android app. The data relevant to Data Act compliance that Frameo holds and controls are limited to those generated and transmitted by these three services.

Certain digital photo frames may be equipped with preinstalled OEM (original equipment manufacturer) systems that generate OEM data. Frameo does not receive or control such OEM data and is therefore not able to provide them. In these cases the OEM is the data holder within the meaning of the Data Act. This notice therefore concerns only the product data and related service data that are generated during the use of a photo frame running the Frameo software and that are accessible to and controlled by Frameo via the related services described above.

Part A: information about the connected product (Article 3(2) Data Act)

Type, format and estimated volume of product data

User content data (e.g. videos and photos transferred to a frame) is covered by GDPR in other privacy policy sections and is therefore considered outside the scope of the Data Act. Besides user content data, a Frameo frame generates primarily three categories of product data:

Continuous and real-time generation

The product is capable of generating data continuously (real-time) while it is powered on. This data is transmitted to our servers in near real-time when the product is connected to the internet. This allows for immediate analysis of performance issues and timely updates to improve your experience.

Storage and retention

The Frameo product is capable of storing data on-device and on remote servers. Specifically:

Access, retrieval and, where relevant, erasure

Data stored on device

Local data retrieval: Accessing local data on the Frame can be done through Android adb access, or by creating a backup of the Frame: https://support.frameo.com/hc/en-us/articles/360021672160--How-to-Make-a-Backup-of-a-Frame

Data erasure: Users can delete most data at any time. Clearing the data can be done by resetting the frame through the frame Settings. Some system and environment data may persist a factory reset (e.g. permanent device identifiers such as a serial number).

Data stored remotely

Cloud data requests: To obtain data stored on Frameo's servers, users should contact Frameo Support ([email protected]). Upon request, we will provide a complete copy of the user's data associated with their Frameo account (delivered to the user's registered email) within 30 days. There is no charge for such data requests.

Data erasure: Users can delete data at any time. To erase remote/server data, a user can delete their Frameo account via the app or request account deletion from support. After an account deletion, Frameo will erase all personally identifiable data from its servers as described in our Privacy Policy.

Part B: Information about related services (Article 3(4) DA)

Nature, estimated volume and collection frequency of product data obtained by related services

In practice, the Frameo Service apps collect system information from connected frames, e.g. screen size, and metadata about the relationship between the frame and app, e.g. user permissions granted from the frame. The data volumes are small – typically only a few kilobytes per frame per day under normal use. The Frameo Service transmits these product data to Frameo's secure cloud servers as they are generated.

Nature and estimated volume of related service data

The Frameo Service generates the following service data:

Storage arrangements and retention

All related service data generated by the Service is stored on Frameo's cloud servers. Same retention rules apply as described in A.3. Product data obtained by related services may be stored locally on-device. On-device data can be cleared by clearing the app data or uninstalling the app. Accessing the on-device data can be done by following the platform's (iOS or Android) standard methods for accessing app data.

Use of readily available data by Frameo and third parties

Frameo uses the data collected from the frame and Services for its internal service purposes. For instance, we analyze usage logs and system metrics to troubleshoot issues, optimize performance, bug fixing, and develop new features. Any use of data is in accordance with user agreements and privacy policies. By default, Frameo does not share user data with any external third parties for independent use. We do not sell or disclose personal usage data outside Frameo. The only exceptions are as required by law or with the user's explicit consent. If a user explicitly requests to transfer their data to a third-party service (for example, migrating their photos and logs to another platform), Frameo will enable that transfer as described below. Aside from such cases, Frameo ensures that all data use will be internal.

Identity and contact of the prospective data holder and other data processing parties

The Frameo Services are provided by Frameo A/S (Business registration number DK37206113) based in Denmark at Daugbjergvej 26B, 1.1, 8000 Aarhus C. Frameo is the sole data holder for the services; we also engage authorized cloud hosting providers as data processors under contract. Those providers store and process the data on Frameo's behalf but do not act as independent data holders. No other company controls the data we collect from the services.

Users can reach Frameo at:

These channels allow users to quickly contact Frameo about data, technical issues, or account questions.

How users can request data sharing

Frameo fully supports data portability: a user may ask Frameo to provide their data to another service (for example, if switching to a different photo-frame platform). To do this, the user should contact Frameo Support (e.g. via email) and specify which data to share and with which recipient. Upon request, Frameo will package the user's data (in a structured, machine-readable format) and transfer it to the indicated party, at no cost to the user.

Complaint right

Users have the right to lodge a complaint alleging an infringement of Chapter II of the Data Act with the competent authority designated pursuant to Article 37 of the Data Act.

Trade secrets

Data is not expected to contain trade secrets and as such Frameo does not treat the data as proprietary trade secrets. Should this however be the case, disclosure and access will be provided under safeguards that protect confidentiality, in accordance with the Data Act.

Terms of use and quality of service for access and transmission

Requests under the Data Act are handled without undue delay and free of charge. Data is provided in a structured, commonly used and machine-readable format (e.g. JSON). Availability of the access channel may be subject to maintenance windows and system uptime of the related services and backend systems.

Duration and termination of the contract between the user and the prospective data holder

The Frameo Service is offered under an ongoing user agreement. The user may terminate this contract at any time by deleting their Frameo account, uninstalling the app, and canceling any paid subscription (if applicable). After an account deletion, Frameo will erase all personally identifiable data from its servers as described in our Privacy Policy. Conversely, Frameo may terminate the service if the user violates the terms of use or for other reasons stated in our policies.

Changes to our privacy policy

We may update this Privacy Policy from time to time. Changes that clarify existing provisions, reflect new services or features, or are required by law will take effect upon posting to the Services. Changes that materially and negatively affect your rights will be notified to you at least 14 days in advance by email or in-app notice. The notification will describe the nature of the change and the reason for it, and will inform you of your right to terminate your account before the changes take effect. Your continued use of the Services after that notice period constitutes acceptance of the updated Privacy Policy.

Contact information

Frameo
Daugbjergvej 26B, 1.1
8000 Aarhus C, Denmark
[email protected]

Supervisory Authority
Danish Data Protection Agency or 'Datatilsynet'
Carl Jacobsens Vej 35
2500 Valby, Denmark
Tlf. 33 19 32 00
[email protected]

Last updated: 14/08 - 2026


Previous version

In force until: 27/08 - 2026


Frameo A/S ("Company" or "frameo" or "we" or "us" or "our") operates http://frameo.net/ and http://frameo.com/ (the "site") and provides the frameo mobile app for Android and iOS (the "app") and the frameo frame app (the "frame").

We take your privacy seriously and are committed to protecting the information we collect. We have written our privacy policy to be understandable for humans (not just lawyers). By using our app or frame, future products, services or features we develop and introduce, or our website (together the "Services"), you consent to the collection, processing and disclosure of data concerning you in accordance with this Privacy Policy.

You may find our Terms of Service here.

Data collection

Information we collect when you use our Services:

We collect some of the information generated by our services ("Log Data"). This Log Data may include information such as your device's Internet Protocol ("IP") address, browser type, browser version, the pages of our site that you visit, the time and date of your visit or use of the app or frame, the time spent on those pages, which IPs communicate together through our servers and other statistics. IP addresses are anonymized wherever possible.

Photos, videos and reactions shared through the app are never collected by us or third parties. Communication between app and frame is end-to-end encrypted which makes it impossible for us or any third party to see what you send, including your photos or videos.

This ensures your privacy when sending media through our Services.

Cookies and Similar Technologies:

Cookies are small pieces of data that are stored on your mobile phone, computer, or other device. Pixels, often used in connection with cookies, are small instances of code placed in web pages that do things like allow another server to measure how frequently web pages are viewed and used.

We use different categories of cookies and similar technologies on our Services. These include: (i) strictly necessary cookies required for functionality, (ii) analytics cookies to understand usage and improve the Services, (iii) functional cookies to enhance user experience, and (iv) advertising/targeting cookies. Except for strictly necessary cookies, we only place cookies where you have provided your explicit consent in accordance with the ePrivacy Directive and GDPR. You can withdraw or change your cookie preferences at any time using your browser/device settings.

Third parties may also use cookies to collect information about your activities on our website. Your browser or device may offer you control over the use of cookies or other technologies when you use the Services. For example, you may be able to set your browser or device to disable, clear, reset or block the use of cookies or similar technologies.

Information we collect when you create an Account:

When you create an Account in your Frameo app you may provide us with the following data: Name, Email address. No other personal information is collected from the creation of the user account.

Information we collect when you add a subscription to your Account:

None. The payment is handled by Google Payments or Apple Pay, so there is no need for Frameo to collect any personal information. Furthermore, information regarding your payment, such as credit card information, is not shared with Frameo by Google Payments or Apple Pay.

When adding a calendar to the Frame:

When using the calendar feature we request data from your calendar provider's API (such as Google or Microsoft) in order to deliver the service you have requested. We prioritize your privacy by only accessing the data required for the feature to function. The data from the calendar feature is not sold to a third party, and it flows through a connection directly between your calendar provider and the Frame. The data is only stored (cached) on the Frame in order to provide the service. We reserve the right to use anonymized analytics for the ongoing optimization of our services.

Third Party Data Processing

We use automated devices and applications to evaluate usage of our app, frame devices, the Frameo solution infrastructure and our website. We also may use other analytics to evaluate our Services. We use these tools to help us improve our Services, performance and user experience. We do not share your personal information with these providers. Some of our providers of these devices and applications are either located or have parent companies in the US. Where this is the case, our providers are certified under the EU-U.S. Data Protection Framework and all data transfer is protected with the necessary safeguards in accordance with GDPR art. 45.

For providers located outside of the EU who are not DPF certified, data processing agreements in accordance with the EU standard contractual clauses have been entered providing the necessary safeguards in accordance with the GDPR art. 46. If you wish to receive a copy hereof, you are welcome to contact us.

Joint controllership:

Frameo may from time to time use pixel technology such as Facebook Pixel, LinkedIn insight Tag and Google analytics. These tools allow us to measure and optimize our website and ads to make them more relevant to you. The collected data remains anonymous to Frameo since we cannot identify you from this data. However, the data may be saved and processed by Facebook, LinkedIn and Google for their own advertising purposes and they may in some cases be able to identify you by combining the data with data about you that they have previously obtained. It is Facebook, LinkedIn and Google who has the ultimate control of the information gathered through the mentioned pixel technology. You can opt-out of these technologies by declining tracking and performance cookies as well as targeting and advertising cookies on our website.

Legal basis for processing personal data

When we process your personal data, we always ensure that the processing is in accordance with the GDPR, namely that we always have a legal basis for the processing.

The legal basis for our processing of analytic data from cookies on our website is the GDPR art. 6(1)(a) and the Danish Executive Order on cookies section 3.

The legal basis for our processing of analytic data from our website and app, that is not derived from the use of cookies, is the GDPR Art. 6 (1)(f), as it is in our legitimate interest to make our Services available to you, including improving and optimising the user experience.

Lastly the processing of contact information such as e-mail addresses and names are processed based on the GDPR art 6(1)(f) as it is in our legitimate interest to be able to contact our customers. Where we use your contact information to send newsletters and other marketing material, this is based on GDPR Art. 6(1)(a) (your consent) and the Danish Marketing Act. You can withdraw your consent at any time by following the unsubscribe link in our emails or through the relevant settings in our app.

Our Services are not directed to children under the age of 16 (or the minimum age of consent for data processing in your jurisdiction). We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child without appropriate consent, we will delete such information promptly.

Your rights as data subject

You have the rights as described below which you can exercise by contacting us at the below mentioned contact information. Your request will be answered free of charge, as soon as possible and no later than one month after receipt, however, up to two months if necessary due to the complexity or number of requests. In the event of unfounded or excessive requests, we have the right to reject it or charge a reasonable fee for answering it.

Your specific possibilities are:

Deletion of data

Information required for newsletters is kept until the consent is withdrawn or the consent has not been used for one consecutive year. We keep documentation that you have withdrawn your consent for up to 2 years after the consent has been withdrawn, in order to be able to defend us against any claims made for violation of the Danish Marketing Act, cf. § 37, subsection 3 and the Danish Penal Code § 93, subsection 1, no. 1, however only if there is an actual risk that such a claim will be made.

Personal data contained in cookies is deleted when the cookie expires or is deleted by you. Other analytics data such as IP-addresses are deleted after 13 months.

Your personal data is kept until you choose to delete your Account. After the Account is deleted all personal data will be automatically deleted within 2 days.

Security

We take security of your information seriously and implement appropriate technical and organizational measures (TOMs) in accordance with GDPR Article 32 to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorised persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures. Also note that since frames are designed exclusively for home use, the media presented on them is not hidden behind a password screen and can therefore be physically accessed by anyone in the home.

Contact

Should you wish to exercise any of your rights or if you have any questions regarding our Privacy Policy, please contact us via email: [email protected]

Supervisory Authority

You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet) or your local supervisory authority if you believe that the processing of your personal data infringes applicable data protection law.

Changes to our Privacy Policy

We reserve the right to alter our Privacy Policy at any time. Where changes are material, we will notify you in advance with reasonable notice through the Services (such as by posting on our website, email, or in-app notice). If you do not agree to the altered Privacy Policy, you should stop using our Services before the changes take effect.

EU Data Act compliance

The Frameo Frame software qualifies as an integral part of a connected product (a Digital Photo Frame) within the meaning of Article 2(5) of the EU Data Act. In the context of the Frameo system the following qualify as related services within the meaning of Article 2(6) of the Data Act: the Frameo iOS app and the Frameo Android app. The data relevant to Data Act compliance that Frameo holds and controls are limited to those generated and transmitted by these three services.

Certain digital photo frames may be equipped with preinstalled OEM (original equipment manufacturer) systems that generate OEM data. Frameo does not receive or control such OEM data and is therefore not able to provide them. In these cases the OEM is the data holder within the meaning of the Data Act. This notice therefore concerns only the product data and related service data that are generated during the use of a photo frame running the Frameo software and that are accessible to and controlled by Frameo via the related services described above.

Part A: information about the connected product (Article 3(2) Data Act)

Type, format and estimated volume of product data

User content data (e.g. videos and photos transferred to a frame) is covered by GDPR in other privacy policy sections and is therefore considered outside the scope of the Data Act. Besides user content data, a Frameo frame generates primarily three categories of product data:

Continuous and real-time generation

The product is capable of generating data continuously (real-time) while it is powered on. This data is transmitted to our servers in near real-time when the product is connected to the internet. This allows for immediate analysis of performance issues and timely updates to improve your experience.

Storage and retention

The Frameo product is capable of storing data on-device and on remote servers. Specifically:

Access, retrieval and, where relevant, erasure

Data stored on device

Local data retrieval: Accessing local data on the Frame can be done through Android adb access, or by creating a backup of the Frame: https://support.frameo.com/hc/en-us/articles/360021672160--How-to-Make-a-Backup-of-a-Frame

Data erasure: Users can delete most data at any time. Clearing the data can be done by resetting the frame through the frame Settings. Some system and environment data may persist a factory reset (e.g. permanent device identifiers such as a serial number).

Data stored remotely

Cloud data requests: To obtain data stored on Frameo's servers, users should contact Frameo Support ([email protected]). Upon request, we will provide a complete copy of the user's data associated with their Frameo account (delivered to the user's registered email) within 30 days. There is no charge for such data requests.

Data erasure: Users can delete data at any time. To erase remote/server data, a user can delete their Frameo account via the app or request account deletion from support. After an account deletion, Frameo will erase all personally identifiable data from its servers as described in our Privacy Policy.

Part B: Information about related services (Article 3(4) DA)

Nature, estimated volume and collection frequency of product data obtained by related services

In practice, the Frameo Service apps collect system information from connected frames, e.g. screen size, and metadata about the relationship between the frame and app, e.g. user permissions granted from the frame. The data volumes are small - typically only a few kilobytes per frame per day under normal use. The Frameo Service transmits these product data to Frameo's secure cloud servers as they are generated.

Nature and estimated volume of related service data

The Frameo Service generates the following service data:

Storage arrangements and retention

All related service data generated by the Service is stored on Frameo's cloud servers. Same retention rules apply as described in A.3. Product data obtained by related services may be stored locally on-device. On-device data can be cleared by clearing the app data or uninstalling the app. Accessing the on-device data can be done by following the platform's (iOS or Android) standard methods for accessing app data.

Use of readily available data by Frameo and third parties

Frameo uses the data collected from the frame and Services for its internal service purposes. For instance, we analyze usage logs and system metrics to troubleshoot issues, optimize performance, bug fixing, and develop new features. Any use of data is in accordance with user agreements and privacy policies. By default, Frameo does not share user data with any external third parties for independent use. We do not sell or disclose personal usage data outside Frameo. The only exceptions are as required by law or with the user's explicit consent. If a user explicitly requests to transfer their data to a third-party service (for example, migrating their photos and logs to another platform), Frameo will enable that transfer as described below. Aside from such cases, Frameo ensures that all data use will be internal.

Identity and contact of the prospective data holder and other data processing parties

The Frameo Services are provided by Frameo A/S (Business registration number DK37206113) based in Denmark at Daugbjergvej 26B, 1.1, 8000 Aarhus C. Frameo is the sole data holder for the services; we also engage authorized cloud hosting providers as data processors under contract. Those providers store and process the data on Frameo's behalf but do not act as independent data holders. No other company controls the data we collect from the services.

Users can reach Frameo at:

These channels allow users to quickly contact Frameo about data, technical issues, or account questions.

How users can request data sharing

Frameo fully supports data portability: a user may ask Frameo to provide their data to another service (for example, if switching to a different photo-frame platform). To do this, the user should contact Frameo Support (e.g. via email) and specify which data to share and with which recipient. Upon request, Frameo will package the user's data (in a structured, machine-readable format) and transfer it to the indicated party, at no cost to the user.

Complaint right

Users have the right to lodge a complaint alleging an infringement of Chapter II of the Data Act with the competent authority designated pursuant to Article 37 of the Data Act.

Trade secrets

Data is not expected to contain trade secrets and as such Frameo does not treat the data as proprietary trade secrets. Should this however be the case, disclosure and access will be provided under safeguards that protect confidentiality, in accordance with the Data Act.

Terms of use and quality of service for access and transmission

Requests under the Data Act are handled without undue delay and free of charge. Data is provided in a structured, commonly used and machine-readable format (e.g. JSON). Availability of the access channel may be subject to maintenance windows and system uptime of the related services and backend systems.

Duration and termination of the contract between the user and the prospective data holder

The Frameo Service is offered under an ongoing user agreement. The user may terminate this contract at any time by deleting their Frameo account, uninstalling the app, and canceling any paid subscription (if applicable). After an account deletion, Frameo will erase all personally identifiable data from its servers as described in our Privacy Policy. Conversely, Frameo may terminate the service if the user violates the terms of use or for other reasons stated in our policies.

Last updated: 16/03 - 2026