Legal Document

Chameleon Privacy Policy

Last updated: October 4, 2026

Chameleon Frames offers a variety of features that allow users to select their favorite photos and transform them into high-quality photo frames (the “Services”).

This Privacy Policy describes how Chameleon Frame Technologies, LLC and its subsidiaries and affiliates, including 963 Vibes, LLC (collectively “Chameleon Frames”, “we”, “our” or “us”) collect, store, use and disclose personal data of individuals (“you” or “your”) who:

visit or otherwise interact with our websites available at https://www.chameleonframes.com and www.963vibes.com (the “Sites”), blogs or other similar forums, online ads and content, surveys, emails or other communications under our control;
use the Services through our Sites;
serve as contact persons at our current or potential business partners or service providers with whom we interact in the course of our business activities.

Specifically, this Privacy Policy describes our practices regarding:

Data Collection
Data Uses & Business Purposes
Data Location
Data Retention
Data Disclosure
Cookies and Tracking Technologies
Communications
Data Security
Data Subject Rights
Opt-Out of Sale/Sharing/Targeted Advertising
Additional Information and Contact Details

We respect your privacy and are strongly committed to making our practices regarding your personal data transparent and fair.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may be unable to provide you with the full range of our Services or deliver the best user experience. If you prefer not to share your personal data or have it processed by us or any of our Service Providers (defined in Section 5 below), please refrain from providing it, visiting or interacting with our Sites, or using our Services. You may also submit a request to exercise your rights, as explained in Section 9.

1. Data Collection

When we use the term “personal data” (or “personal information” under certain data protection laws such as the California Consumer Privacy Act (CCPA)) in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. It does not include aggregated, de-identified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Specifically, we collect or generate the following types of personal data through the Sites and Services:

Direct interactions and communications with us: personal data contained in any forms and inquiries that you may submit to us, including form submissions, emails, as well as recordings of calls and chat conversations (e.g., for customer service and support).
Data collected from your use of the Services: Personal data we collect when you use the Services or make a purchase as a guest. Because our digital storefronts operate through licensed e-commerce platforms, your transaction, contact, shipping, and billing data is collected by and shared with our core service providers, including Shopify, to facilitate order fulfillment. This includes your shipping address, order history, and payment method details. We do not store full payment card details; these are securely passed directly to our integrated third-party payment processors.
Images: our Services enable you to select and upload Images, either from your device's photo library or through connecting the Services to other apps or services (such as Google Photos, Facebook, or Instagram, as available). To upload Images from your device, you will need to grant us permission to access your photos – upon first use, you will be asked via your device’s photo access permission mechanism whether you allow Chameleon Frames to access specific photos or your entire photo library (you can change Chameleon Frames access permissions at any time through your device Settings). Please note we may employ automatic features to enhance, edit, or otherwise alter your images for the purpose of improving their quality. Below are additional details regarding certain features that may process your images. Subject to your consent or other lawful grounds, we may also use the photos processed under this feature to help us improve the service. You may opt-out of such processing by contacting us at contact@chameleonframes.com.
Creative Wall Art: You may upload Images to create personalized frame borders, AI-generated wall art, such as custom portraits of your family members or pets, or artistic illustrations of your favorite places. Depending on the feature you use, we will process the Images you upload, as well as related information you provide meant to help us accurately depict your desired artwork, such as names, ages, gender, interests, places, and additional text; as well as the AI-generated images created through the Services.
Usage and Device Information: when you interact with our Sites (as visitors) or use our Services, we may collect certain connectivity, technical and aggregated usage data. This may include your IP address and non-precise location derived from it, browsing history and interaction with our Sites and Services, and device information (including operating system, device ID, browser version, language settings used), activity logs, cookies and pixels installed on your device, and inferred or presumed data generated from your use of the Sites and Services.

We collect the above personal data either through your interaction with us or our Sites and Services, automatically through cookies and other tracking technologies (as further detailed in Section 6 below), from our Service Providers (as further detailed in Section 5 below), or through third party services, social media, and other business initiatives.

For the purposes of the California Consumer Privacy Act ("CCPA"), in the last twelve (12) months, we have collected the following categories of personal information, as defined in the CCPA: identifiers; commercial information; customer record information; internet or other electronic network activity information; geolocation data; visual or similar information, sensitive personal information, and inferences.

2. Data Uses & Business Purposes

We use personal data as necessary for the performance of our Services (“Performance of a Contract”); to comply with our legal and contractual obligations (“Legal Obligations”); to support our legitimate interests in maintaining and improving our Sites and Services, e.g., understanding how they are used and how our campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; promoting our Services; providing customer services and technical support; and protecting and securing our Sites and Services, ourselves and the organizations and individuals we engage with (“Legitimate Interests”); and with your consent (“Consent”) such as to inform you about our offers and products in which you have expressed interest.

If you reside or are using the Sites or Services in a territory governed by privacy laws which determine that Consent is the only or most appropriate legal basis for the processing of personal data as described in this Privacy Policy (either in general, based on the types of personal data you expect or elect to process or have processed by us or via the Service, or due to the nature of such processing), your continued interaction with us and our Services will be deemed your acceptance of our Terms of Service (“Terms”) and of this Privacy Policy and will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to withdraw such consent, please contact us at contact@chameleonframes.com.

Specifically, we collected and used personal data in the last twelve (12) months for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

Purpose	Legal basis for processing
To facilitate, operate, enhance, and provide usage of our Sites and Services.	Performance of a Contract Consent Legitimate Interests
To provide you with optimal assistance and support, including analysing and improving our customer support services.	Performance of a Contract Legitimate Interests Consent
To develop, customize and improve the Sites and Services and enhance the user experience, including based on common or personal preferences, experiences, difficulties and feedback.	Performance of a Contract Consent Legitimate Interests
To provide, enhance, and optimize the AI features within our Services, including, if applicable, evaluating the photo selection feature by comparing its suggested outcomes with the Images you ultimately selected.	Consent Legitimate Interests
To accurately crop, enhance, upscale or adjust the Images you upload or recommend the best frame designs from our library.	Performance of a Contract Consent
To manage relationships with partners and service providers.	Performance of a Contract
To contact you with general or personalized service-related messages (such as password-retrieval or billing); or with promotional messages that may be of specific interest to you (as further described in Section 7 below); and to facilitate, sponsor and offer certain events and promotions.	Performance of a Contract Consent (as required) Legitimate Interests
To facilitate and optimize our marketing campaigns and ad management, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications.	Legitimate Interest Consent
To use the content you contribute as part of our promotional initiatives in our marketing and advertising campaigns across digital and social media platforms.	Consent
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.	Performance of a Contract Legal Obligations Legitimate Interests
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services or for any other business purpose.	Legitimate Interests
To enforce our Terms, resolve disputes, and protect our business interests and the interests and rights of third parties.	Legitimate Interests
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards.	Performance of a Contract Legal Obligations Legitimate Interests

3. Data Location

We and our Service Providers (defined below) maintain, store and process personal data in the United States and other locations as reasonably necessary for the proper performance and delivery of our Sites and Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Chameleon Frames and its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction from which such data originated.

4. Data Retention

We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether those purposes can be achieved through other means, as well as applicable legal requirements.

Please note that we do not retain your payment information, it is transferred directly to the relevant Service Provider. We only retain a token of such payment information (which cannot be used to reidentify it) and the chosen payment method.

Images uploaded to the Services will be deleted after a specified period of inactivity unless you instruct us otherwise, in line with our data retention policy.

You also have the right to request the deletion of your personal data at any time, as further described in Section 9 below.

If you have any questions about our data retention policy, please contact us at contact@chameleonframes.com.

5. Data Disclosure

We may disclose your personal data in the following instances:

Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Sites and Services.

Service Providers: we engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include hosting services, manufacturing, printing and shipping services, payment processing, data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, chatbot services, AI service providers, performance measurement, data optimization and marketing services, social and advertising networks, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Sites and Services, and may only use the data as determined in our agreements with them.

Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Services. If you wish to remove your public review, please contact us at contact@chameleonframes.com. If you choose to send others an e-mail or message recommending and inviting them to use the Services, we will use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.

Protecting Rights and Safety: we may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Chameleon Frames, any of our users, visitors, or any members of the general public.

Third-Party Websites and Services: our Sites and Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are beyond the scope of Chameleon Frames’ Terms and Privacy Policy and will therefore be governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services.

Chameleon Frames Licensees, Subsidiaries, and Affiliated Companies; Change of Control: We share personal data seamlessly within our corporate group, brand umbrella, and authorized e-commerce licensees (including 963 Vibes, LLC). This cross-brand data sharing is strictly utilized to facilitate customer support, analyze platform performance, coordinate third-party print manufacturing, and troubleshoot order processing across our unified ecosystem. Any licensee or affiliate accessing this data is contractually required to maintain its confidentiality and protect it in accordance with this Privacy Policy. In addition, should Chameleon Frames or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of its assets, your personal data may be shared (to the extent necessary and customary) with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via any of the means of communication available to us.

Additional Sharing: we may share your personal data in additional manners, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

When we disclose personal data for a purpose listed above, we enter into a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except in accordance with our contracts with them.

For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed the following categories of personal information to the recipients listed above: identifiers; commercial information; customer record information; internet or other electronic network activity information; geolocation data; visual or similar information, sensitive personal information, and inferences. We did so in pursuit of the business and commercial purposes described in Section 2 above.

6. Cookies and Tracking Technologies

Our Sites utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide and monitor them and our Services, ensure that they perform properly, analyze our performance and marketing activities, for product development and improvements, and to personalize your experience.

Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address.

Some cookies are removed when you close your browser tab or window. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

Some cookies are necessary for the Sites and Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, may be optional depending on your location when accessing the Sites. You may opt in to or opt out from the use of optional cookies through the “Your Privacy Choices” feature available on our website, or through your browser or device settings.

Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the cookie preferences you initially set-up, so you will need to re-establish these preferences/choices.

7. Communications

We engage in service and promotional communications, through social media, e-mail, phone, surveys, SMS and notifications.

Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of order summaries and shipping updates, to inform you of changes or updates to our Services, billing issues, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to provision of the Services (like shipment updates or billing notices, payment issues etc.).

Promotional Communications: subject to applicable regulations, we may also notify you about new features, current offerings, events, special opportunities or any other information we think you will find valuable. We may provide such notices through any available contact means (e.g., SMS, messaging apps, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. Please note that we may use photos from previous orders or your abandoned cart to send you personalized emails. Photos used for this purpose will be saved and deleted in accordance with our data retention practices described in Section 4 above.

If you wish not to receive such promotional communications via SMS, notifications or e-mail, you may notify Chameleon Frames at any time by e-mailing us at contact@chameleonframes.com or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions contained in the promotional communications you receive.

8. Data Security

In order to protect personal data held with us, we and our Service Providers implement industry standard physical, procedural and technical measures designed to secure personal data and minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Sites and Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at contact@chameleonframes.com.

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at contact@chameleonframes.com if you wish to exercise your privacy rights under any applicable law, including the CCPA and other applicable state law.

Such rights include, to the extent available to you under the laws which apply to you, but are not limited to: the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Chameleon Frames, or to restrict or object to such personal data processing (including, for US residents, the right to direct us to limit the use and disclosure of sensitive personal information to what is necessary to perform the services, or the right to direct us not to “sell” or “share” your personal information, or process it for “targeted advertising”, as explained below), to obtain a copy or port such personal data, or the right to equal services and prices (e.g. freedom from discrimination).

To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

When you or an authorized agent ask us to exercise any of your rights under this Privacy Policy or applicable law, we may request you to provide us with certain additional information to verify your identity, prevent the disclosure of personal data relating to other individuals, and better understand the nature and scope of your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, or proof of request fulfillment), in accordance with Section 4 above.

You may also have the right to lodge a complaint with the relevant supervisory authority, applicable to the processing of your personal data.

10. Opt-Out of Sale/Sharing/Targeted Advertising

Under some US data protection laws, our disclosure of certain internet activity and device information to third parties through cookies may be considered a “sale” or “sharing” of personal information, or processing of personal information for “targeted advertising” (as such terms are defined in applicable data protection laws). We do so in pursuit of the business and commercial purposes described in Section 2 above.

For the purposes of the CCPA, in the last twelve (12) months we have "sold" or "shared" internet or other electronic network activity information, geolocation data, and commercial Information with our analytics and advertising partners. Chameleon Frames has not knowingly sold or shared the personal information of individuals under the age of 16.

California

In California, we only activate cookies that may result in a “sale” and/or “sharing” of your personal information if you have directed us to do so by activating such cookies and storing them on your device. By default, these cookies will not be used by Chameleon Frames.

If you wish to opt in to Chameleon Frames' use of such cookies, you can click the “Allow Sale & Sharing of Personal Information” button on the cookie banner.

To the extent the opt-in activation of such cookies is considered a “sale” or “sharing” of your personal information under the CCPA, you may exercise your right to opt out again at any time by the following ways:

Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party advertising cookies.

Other US States

You may opt out of all cookies that may result in a “sale” and/or processing of personal information for “targeted advertising” in the following ways:

Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising or other cookies.

Please note: If you visit us from a different device or browser, or clear cookies, then you need to re-perform the above descriptions to re-select your preferences.

11. Additional Information and Contact Details

Updates and amendments: we may update and amend this Privacy Policy from time to time by posting an amended version on our Sites. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us. After such notice period, all amendments shall be deemed accepted by you.

External links: while our Sites may contain links to other websites or services, we are not responsible for their privacy practices and we encourage you to pay attention and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Sites and Services.

Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a child is using the Services, we will attempt to prohibit and block such use and to promptly delete any personal data stored with us which we deem to relate to such child. If you believe that we might have any such data, please contact us at contact@chameleonframes.com.

Privacy Inquiries and Contact Details: If you have any questions or inquiries regarding our US privacy practices, or would like to exercise your rights under any applicable US state privacy laws, you can contact us by email at contact@chameleonframes.com or by post at:
Chameleon Frames (Attn: Legal)
221 S.E. Third Street, Suite 700
Evansville, IN 47708, United States

Questions, Concerns or Complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Chameleon Frames, you can contact us at contact@chameleonframes.com.