Legal Information

A. Legal notice

A.1 — Site publisher

This site and the application accessible at https://app.framegrading.com are published by:

FRAME, a simplified joint-stock company (SAS) with a share capital of €1,000.00.

• Registered office: Boulevard des 9 Clés, 71850 Charnay-lès-Mâcon, France
• SIREN: 101 990 877
• SIRET (registered office): 101 990 877 00017
• RCS: 101 990 877
• Intra-community VAT number: FR14101990877
• APE/NAF code: 7120B (Technical testing and analysis)
• President: JOLINA INVEST
• Contact email address: support@framegrading.com

A.2 — Publication director

The publication director is Théo Griezmann, in his capacity as representative of the company.

A.3 — Hosting

Frame's data and services are hosted within the European Union by the following providers:

• Application, interface, billing, and documents: The Constant Company, LLC (Vultr) — data center in Paris, France.
• Storage of videos, invoices and credit notes, and video processing: Amazon Web Services EMEA SARL (AWS) — Ireland (EU) region.

A.4 — Intellectual property

All elements of the site (text, graphics, logos, trademarks, software, structure) are protected by intellectual property law and remain the exclusive property of Frame or its partners. Any reproduction, representation, modification, or exploitation, in whole or in part, without prior written authorization, is prohibited and may constitute infringement.

A.5 — Liability relating to the site

Frame strives to ensure the accuracy and updating of the information published on its site, without however guaranteeing the absence of errors or interruptions. Frame may not be held liable for technical difficulties in accessing the site, nor for damage resulting from the use of the site or of third-party sites to which links may refer.

B. Privacy policy (GDPR)

Frame attaches particular importance to the protection of its clients' personal data, the confidentiality of which is of a sensitive nature given the value of the collectible items handled. This policy describes the personal data processing carried out, in accordance with Regulation (EU) 2016/679 ("GDPR") and the amended French Data Protection Act of January 6, 1978.

B.1 — Data controller

The data controller is the company FRAME (contact details in part A.1). Any request relating to personal data may be sent to: support@framegrading.com.

B.2 — Data collected

• Identity data: surname, first name, public name (pseudonym), date of birth, confirmation of legal age;
• Contact data: email address, telephone number, delivery and billing addresses;
• Order data: order history, information relating to the cards entrusted, grades assigned, certification identifiers;
• Videos and photographs: uploaded videos and extracted segments, photographs of the cards taken during grading;
• Payment data: processed exclusively by the payment provider (Stripe); no bank details are retained by Frame;
• Technical data: IP address, connection logs, session data.

B.3 — Purposes and legal bases

B.4 — Confidentiality and impartiality of grading

Frame implements a compartmentalization of access by role. The persons in charge of grading have, in principle, no access to the depositor's identification data, the cards being tracked by means of anonymized identifiers in order to prevent any bias, favoritism, or targeting of particular clients. Other staff (in particular shipping and support) access only the data strictly necessary for the accomplishment of their function.

Video surveillance and recording of operations — Frame may record by video the receipt, opening (unpacking), as well as the closing (repacking and sealing) of packages, for purposes of evidence and security. These recordings may be used as evidence in the event of a dispute. When such a recording is made, it is kept for a period of up to one (1) year, then deleted. In the event of a dispute, the recording concerned may be kept until its final resolution.

B.5 — Public verification page

The verification of a certified card is accessible by reading its NFC chip and/or via a public verification page consultable online. The public display of the video segment and certification information forms an integral part of the service. Frame reserves the right to activate or deactivate this public access at any time.

The only information likely to appear there relates to the certification of the card: video segment, card name, edition, year, grade, opening date, number of reads, certification status, and where applicable the opener's name.

The opener's name is freely entered by the client, who may include a pseudonym or their real name, under their sole responsibility. With the exception of the information that the client themselves chooses to enter in this field, no other personal data is made public.

B.6 — Recipients and processors

The data is intended for Frame's internal services and its processors, acting on instructions and within the framework of agreements compliant with Article 28 of the GDPR. All processors are located within the European Union / the European Economic Area; no data transfer outside the EU/EEA is carried out.

Frame does not sell or rent its clients' personal data to third parties for commercial purposes.

B.7 — Retention periods

B.8 — Rights of individuals

In accordance with the GDPR, the client has the following rights:

• Right of access and portability (Art. 15 and 20);
• Right of rectification (Art. 16);
• Right to erasure (Art. 17), subject to the exceptions below;
• Right to restriction of processing (Art. 18);
• Right to object (Art. 21).

Limits to the right to erasure — Certain data cannot be erased at the client's request: billing data (subject to a legal retention obligation) and the certification identifiers, grades, dates, and registers of certified cards, retained in order to preserve the integrity of the public certification register.

The client may exercise their rights by writing to support@framegrading.com. The client also has the right to lodge a complaint with the French Data Protection Authority (CNIL) — www.cnil.fr.

B.9 — Security

Frame implements appropriate technical and organizational measures in order to protect personal data against any loss, unauthorized access, alteration, or disclosure, in particular the compartmentalization of access, the anonymization of evaluation data, and hosting within the European Union.

C. Cookie policy

The Frame service uses only strictly necessary cookies for its operation. These cookies, known as "essential", are indispensable for the provision of the service expressly requested by the user and do not require prior consent within the meaning of the applicable regulations and the recommendations of the CNIL.

Frame does not use any audience measurement, statistics, or advertising cookies (such as Google Analytics or Meta Pixel). Consequently, no consent banner is necessary.

The user may configure their browser to refuse cookies; such a refusal is however likely to impair the operation of the service, in particular the connection to their account.

D. Transport and insurance

The conditions of transport, liability, and insurance are governed in their entirety by the General Terms and Conditions of Sale (Articles 7 to 9).