Law Enforcement Data Request Guidelines

Overview

To ensure compliance with our SaaS Services Agreement and Privacy Notice, we respond only to law enforcement requests that adhere to established legal process and applicable law.

U.S. Legal Process Requirements

We disclose user information solely in accordance with our Agreement and applicable U.S. law, including the federal Stored Communications Act ("SCA"), 18 U.S.C. Sections 2701-2712. In accordance with U.S. law:

Subpoena

A jurisdictionally valid subpoena, issued in connection with an official criminal investigation, is required to compel the disclosure of basic user records, which may include:

• Name
• Length of service
• Credit card information (including billing address)
• Email address(es)
• IP address, if available

Court Order

A court order is required to compel the disclosure of certain records or other information related to a user account (not including contents of communications), which may include:

• Message headers and IP addresses
• Basic user records identified above

Search Warrant

A search warrant properly issued under the procedures described in the Federal Rules of Criminal Procedure or equivalent state warrant procedures, based on a showing of probable cause, is required to compel the disclosure of the stored contents of any account, which may include:

• Messages
• Attachments
• Other content of communications within a user's account

International Legal Requirements

A Mutual Legal Assistance Treaty (MLAT) request or letter rogatory may be required to compel the disclosure of the contents of a customer account in the case of requests from law enforcement outside of the U.S.

Data Protection and Privacy Laws

PathBuilder complies with applicable U.S. laws and, where relevant, international data protection and privacy regulations (such as the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA)), when responding to law enforcement requests. Requests originating outside the United States may be subject to additional requirements, including cross-border data transfer safeguards, and PathBuilder reserves the right to reject or limit any request that does not comply with such laws.

Account Preservation Requests

We will take reasonable steps to preserve account records in connection with official criminal investigations for a period of ninety (90) days pending our receipt of a formal legal request for user data. You may request the preservation of records via email, fax or mail as indicated below.

Information Required in Connection With Your Request

Your Contact Information:

• Requesting Agency's name
• Requesting Agent's name
• Requesting Agent's badge/identification number
• Requesting Agent's Agency-issued Email address
• Requesting Agent's telephone number, including extension
• Requesting Agent's mailing address (PO Box not acceptable)
• Requested response date (please allow at least 3 weeks for processing)

Data Request Information:

• Full (first and last) name of the PathBuilder User
• Email address(es) associated with the PathBuilder User's account
• A clear and specific description of the data being requested (we will be unable to process overly broad or vague requests)

Data Availability

We will search for and disclose data that is specified with particularity in an appropriate form of legal process and which we are reasonably able to locate and retrieve.

User Notification

PathBuilder's policy is to notify users of requests for their information, which includes a copy of the request, prior to disclosure so that they may have an opportunity to challenge such request unless:

• We are prohibited from doing so by law or court order
• There are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors
• Prior notice would be counterproductive (for example, if we believe that the account in question has been hijacked)

Law enforcement officials who believe that notification would jeopardize an investigation should obtain a proper court order or other appropriate process establishing that notice is prohibited. Please note that officer authored affidavits, cover letters or similar statements are not sufficient to preclude notice to our users.

In the event we are legally prohibited from notifying a user of a law enforcement request, PathBuilder will comply with such prohibition only to the extent required by applicable law or court order. Absent such prohibition, PathBuilder assumes no liability for any consequences resulting from user notification consistent with this policy.

Submitting Your Request

A data request may be served by certified mail, express courier, or in person at our corporate headquarters at the following address:

For questions about these or any PathBuilder policies, email us at help@pathbuilderapp.com.