1. Scope and principles
This Policy describes how Frameleaf, Inc. handles law-enforcement requests, subpoenas, warrants, court orders, preservation demands and other legal requests for customer information. It applies to information within Frameleaf’s possession, custody or control. It does not give Frameleaf control over a customer’s independently operated Frameleaf Library, devices, hosting provider or Buddy Backup peer.
Frameleaf requires a valid legal basis for disclosure, evaluates each request individually, limits any response to the authorized and responsive information actually available, and protects customer confidentiality. A request does not create information we do not have or give us a decryption capability we do not possess. We do not provide unrestricted government access to customer accounts or systems.
2. Information and technical limits
2.1 Self-hosted Libraries and encrypted transport
Frameleaf Library and its local machine-learning containers run on infrastructure selected and controlled by the administrator. Using Frameleaf Cloud does not transfer the Library’s source-media collection or local database to Frameleaf. Our remote-access relay forwards the encrypted TLS session without decrypting its application payload; it does not maintain a readable record of the photographs viewed or other actions within that encrypted session.
Cloud services separately receive the account, server, operational and other information needed for the features a customer enables. The absence of readable relay payloads is not a statement that all Cloud interactions are unlogged or that no server characteristics are recorded.
2.2 Backup contents, keys and access
In the ordinary managed Cloud Backup protocol, the Frameleaf Cloud coordination service does not receive the usable customer backup-encryption key and cannot decrypt the stored backup contents without that key. Optional recovery escrow holds a passphrase-wrapped envelope, not a usable decryption key available to Frameleaf without the customer’s recovery secret. Buddy Backup encrypts recovery blocks and metadata on the source before transfer to a customer-operated peer; Cloud coordination does not ordinarily receive readable backup contents or usable vault keys.
Managed Cloud Backup uses storage-provider server-side encryption with customer-provided keys. The Library supplies its key over HTTPS to the storage endpoint for content operations, and the storage processor performs encryption and decryption. These limits on Frameleaf’s coordination service are not a representation that the storage provider never receives readable content or a usable key. Encrypted objects, wrapped escrow and backup metadata may remain within the scope of a valid request even where readable contents are unavailable.
Our policy is not to create or voluntarily provide a backdoor, universal decryption key, hidden remote-access mechanism or special bypass of customer encryption for law enforcement. We will have internal counsel assess and, where there are grounds, challenge demands to introduce such capabilities, weaken encryption or collect information prospectively. We cannot promise that every demand will be defeated, and we do not represent that these safeguards eliminate every administrative capability or the distinct processing required for Cloud AI.
2.3 Records that may be available
Depending on the services used and applicable retention periods, responsive information may include:
- Account identifiers, email address, supplied profile details, account dates, authentication and consent records, and subscription entitlements.
- Billing contact details, invoices, purchases, payment status, refunds, wallet transactions and limited payment-method information received from a processor or marketplace. Frameleaf does not ordinarily receive full card numbers or card security codes from direct card checkout.
- Linked-server identifiers, administrator-supplied names, software version, platform, capabilities, region, last-contact and health information, routing information and service settings.
- Backup bucket and object references, storage measurements, object counts, backup-run times and status, errors, credential-administration records and encrypted recovery envelopes where retained.
- Cloud operational and security records, including applicable IP addresses, timestamps, audit events, logs, traces, usage measurements and job-cost records.
- Support correspondence, reports and attachments submitted to Frameleaf, and records of related investigations or legal requests.
- Selected Cloud AI content only while it remains in an active processing worker. Uploads go directly to that worker and are deleted immediately when the job finishes; the container is destroyed. Frameleaf retains no completed-job upload archive and cannot recover a destroyed container or its uploaded content in response to a later request. Non-content job and billing records are separate. Cloud AI processes readable selected inputs while the job is active.
Consequently, Frameleaf’s available information is not limited to payment information, an account and an email address. We do not represent that no Library characteristics or customer interactions are ever recorded. Availability depends on actual collection, deletion, the service used and the scope of lawful control; this list does not mean every category exists for every customer. The Privacy Notice and Security, Retention and Deletion Schedule explain ordinary processing and retention.
3. Submitting and authenticating a request
Send legal requests to [email protected], with “Legal process” in the subject. Identify the requesting agency or party, responsible official or attorney, verifiable official contact information, issuing court or authority, case reference, applicable legal basis, specific account identifiers, requested record categories, relevant date range and response deadline. Include the complete process and any order restricting notice. Explain any claimed emergency or preservation requirement separately.
Frameleaf may authenticate the request through independently verified contact information and ask for clarification or additional documents. Do not send passwords, usable backup keys or unnecessary sensitive media. We will arrange an appropriate channel for any authorized production.
Our correspondence address and email facilitate receipt and coordination; listing them does not waive lawful service requirements, jurisdictional objections, privileges or other defenses. An acknowledgement is not acceptance of validity or a commitment to disclose. Address process to the entity that actually provides the relevant service.
4. Internal-counsel review and United States process
Frameleaf’s policy is to route all legal requests, including apparently lawful requests, to internal counsel for review. Internal counsel may engage qualified outside counsel where necessary. Ordinary support staff cannot authorize a legal production merely because a request appears official. Counsel assesses authenticity, jurisdiction, service, authority, scope, deadlines, notice restrictions, applicable privacy law and the information actually available.
For United States requests, Frameleaf applies the Stored Communications Act, including 18 U.S.C. §§ 2702–2705, where applicable, together with other governing law. The required process depends on the type of record and service. A subpoena for eligible subscriber records does not by itself authorize disclosure of protected communications content. Frameleaf’s policy is to require a valid search warrant for compelled disclosure of stored communications content protected by the Act, unless counsel determines another applicable legal authority permits or requires the disclosure.
Civil requests, including subpoenas under Federal Rule of Civil Procedure 45, are separately assessed for lawful service, scope, burden, privilege and statutory restrictions. A civil subpoena does not override a prohibition on disclosure under the Stored Communications Act or other applicable law.
Frameleaf may dispute notices or demands it finds deficient, seek clarification or narrowing, assert objections, request a protective order, or move to quash or modify process where warranted. Grounds may include lack of authority, inadequate identification, overbreadth, unreasonable burden, protected material, conflicting law or a demand for information we do not possess or cannot decrypt. We do not ignore binding process merely because we disagree with it; counsel will pursue available lawful remedies and any necessary stay.
5. Notice to affected users
Our policy is to notify the affected user before disclosing their information unless a court order or another binding legal prohibition restricts notice. Where lawful, notice will identify the requesting authority, the nature and scope of the request and the anticipated response deadline, and include a copy of the process or an adequate summary. We will provide a reasonable opportunity to seek legal protection where the applicable deadline permits. A user’s objection alone does not suspend a binding deadline or order; we will honor an applicable stay or other effective legal restriction.
An agency’s preference for secrecy or an unsupported confidentiality label is not by itself a legal prohibition on notice. Internal counsel reviews asserted restrictions, records their scope and duration, and may seek clarification, narrowing or relief from an unjustified restriction. We will provide delayed notice promptly after the restriction ends, unless another applicable prohibition remains in force.
In a genuine emergency involving danger of death or serious physical injury, notice may be delayed only for as long as it would materially increase that danger or prevent timely lawful protective action. Counsel will assess and document that basis. We will notify the user promptly once the danger no longer justifies delay, unless legally prohibited. Ordinary investigative convenience is not an emergency exception.
Notice is sent using an available account contact or another appropriate verified channel. A closed account does not itself remove this notice policy, although deleted or invalid contact information may prevent delivery. Notices will avoid unnecessary disclosure of another person’s protected information.
6. Preservation
A valid preservation request preserves specifically identified information already within our possession or control; it does not itself authorize disclosure. Where 18 U.S.C. § 2703(f) applies, the statutory preservation period is 90 days, with an additional 90 days upon a qualifying renewed request. Other valid obligations or orders may require a different period, which counsel will assess.
Preservation does not recover previously deleted information, supply a missing encryption key or automatically authorize future surveillance. We restrict access to preserved records and maintain the ordinary lifecycle for unrelated information. Once the lawful basis for a hold ends, applicable deletion and retention rules resume. Notice concerning preservation follows Section 5 to the extent applicable and legally permitted. Any stricter notification obligation under the DPA, mandatory transfer clauses or applicable law remains controlling; this Policy does not create an exception to it.
7. Emergencies and mandatory reporting
An emergency request must describe specific facts showing danger of death or serious physical injury, why disclosure cannot await ordinary process, the information needed and its relationship to the emergency, and a verifiable official contact. An “urgent” label is insufficient.
Internal counsel will evaluate emergency requests promptly under applicable law, including the emergency-disclosure provisions of 18 U.S.C. § 2702 where applicable. Any permitted disclosure is limited to information actually available and reasonably necessary for the emergency. The exception does not create a decryption capability or grant direct system access. This Policy also does not prevent disclosures or reports independently required by law. Frameleaf’s support contact is not a public emergency-response service; persons facing immediate danger should contact emergency services.
8. Requests from outside the United States
A foreign request is not automatically enforceable merely because it comes from a government or court. Counsel will assess jurisdiction, applicable international mechanisms, conflicts of law and any valid legal authority that applies to Frameleaf or the relevant records. Where necessary, the requester must use an appropriate mutual legal assistance, domestic judicial or other recognized process. Storage location alone does not resolve jurisdiction or eliminate applicable legal protections.
9. Production, accountability and contact
Before production, counsel will confirm the permitted scope and applicable notice requirements. Frameleaf will limit disclosure to responsive information lawfully required or otherwise lawfully justified, use an appropriately secure delivery method, and explain material technical limits where permitted. Frameleaf does not sell customer information to law enforcement or treat a legal request as consent to unrelated processing.
We retain an access-restricted record of the request, review, legal basis, notices, preservation and response as needed for accountability and applicable obligations. This recordkeeping is separate from monitoring a customer’s private Library contents. A response concerning Frameleaf’s records is not a certification of records held independently by a storage provider, payment provider, Library administrator or other third party.
Questions and legal-process correspondence: [email protected] or frameleaf.app. Telephone: +1 (332) 287-1911.
Postal correspondence: Frameleaf, Inc., 14 Wall Street, Suite 2000, New York, NY 10005, United States.