Sfanti Grup Solutions SRL (hereinafter, “Company”, “we”, “us” or “our”) maintains operational policies prohibiting the disclosure of user data without the user’s express consent except as required to comply with a pending criminal investigation, a court order, search warrant, summons, subpoena, or other valid legal process received by the Company.
We are based in the European Union, and we do not maintain offices in the United States or Canada. As such, any formal request for user data must be coordinated through EU authorities. However, in an effort to voluntarily cooperate with legal investigations, law enforcement and legal counsel may submit requests for user data to email@example.com that comply with this Subpoena & Law Enforcement Request Policy (“Policy”).
Law Enforcement Requests
We support law enforcement efforts to fulfill their duties, protect the public, and put an end to criminal activity. This is especially true in cases concerning non-consensual sexual activity or abuse of a minor. In an effort to aid law enforcement and other governmental agencies in meeting these goals, we will comply with valid investigatory requests and generally provide such data as required or permitted by law.
While we will typically preserve or provide available user data in response to valid law enforcement requests, we reserve the right to insist on receipt of a valid preservation request, subpoena, warrant, or court order when necessary or appropriate. Please review applicable law before submitting requests for user data.
We endeavor to respond within thirty (30) days to valid law enforcement inquiries. However, in some cases, additional time is required.
If your case involves exigent circumstances where time is of the essence, please inform us of the circumstances, and we will expedite your request in an effort to respond as quickly as possible.
Requests by Legal Counsel
We require a preservation request, subpoena, or court order sent by legal counsel before providing user data to private parties. We endeavor to respond to such requests within thirty (30) days. However, in some cases, additional time is required. We reserve the right to request additional information from the requesting party, including without limitation, authenticated copies of court pleadings, in order to verify that the requested information is relevant to any civil or administrative matter.
To ensure we preserve and provide accurate user data in response to your request, please send your request with supporting documentation to firstname.lastname@example.org, including:
Identifiers such as the Post ID, link, IP address, email, or phone number,
The types of data requested, including associated email addresses, phone numbers, IP addresses, posts, and other account data, and
Whether the post was accessed by law enforcement before or after May 05, 2021.
Please note that in-person testimony is not available in connection with responsive data sets, however a records custodian certification can be provided upon request.
Requests for Communications
There is no direct messaging feature on the website, and we do not have any record of communications between users and advertisers.
Further, we are prohibited by a variety of privacy laws from providing the contents of emails or other electronic communications except under very limited circumstances.
Requests for Billing Data in the United States
We provide free services to users in the United States, so no billing or payment data exists in relation to advertisements in the United States.
Requests for Age Verification Data
We do not receive or maintain age verification data or user identification documents as age verification services are provided by a third party vendor.
Retention of User Data
We do not guarantee the existence, accuracy, or regularity of our storage or backup services. Notably, all posts automatically expire after ninety (90) days of inactivity. Due to data storage capacity and security concerns, all content contained on the website and any archival copy of the same, are subject to deletion and destruction at any point. This material is permanently and irrevocably deleted, and such files can thereafter no longer be recovered under any circumstances. In the event of receipt of a legal preservation request, we will undertake our best efforts to preserve the data identified in such request, to the extent required by applicable law.
Notification to Users
We reserve the right, but do not undertake the obligation, to notify the affected user prior to responding to a civil or administrative subpoena and to delay compliance for up to ten (10) calendar days, in order to allow the user to move to quash the subpoena or obtain a protective order from a court of competent jurisdiction, excepting emergency circumstances or where otherwise required by law. Confidentiality is typically maintained when complying with criminal investigations. Nothing in this Policy is intended as legal advice. Please direct any questions regarding legal procedures to your private attorney.
Costs of Compliance
We may condition compliance with civil or administrative subpoenas only upon payment of our expenses, as follows:
€75.00/hour for research
€0.25/page for copies
Actual cost for media storage devices (such as CDs, DVDs, and portable drives)
Actual cost for mail and document delivery
Actual costs determined as incurred for all other costs and expenses
We also reserve the right to charge an administration fee to the affected user, the amount of which is within our sole discretion.
Release of User Data in Other Circumstances
Notwithstanding the foregoing, we reserve the right to disclose user data when, in our sole discretion, we believe that it is reasonable to do so. Such circumstances include, but are not limited to the following:
Satisfy any legal obligation
Identify, contact, or bring legal action against someone who may be violating any of the user agreements and/or policies governing the access or use of this website
Investigate fraud or deceptive activity
Maintain the security of the website’s systems, servers, datacenters, or properties
Operate the website’s services properly
Protect ourselves, our users, and the general public
Aid law enforcement in the investigation of illegal use of the website
Nothing contained in this Policy shall constitute a waiver of formal legal process or consent to jurisdiction of the courts and/or the legal system in any particular state, province, or country.
Nothing in any response sent in compliance to this Policy is intended to waive any rights or objections under U.S. or foreign law, all of which are specifically preserved, including objections to personal jurisdiction and to disclosure of stored communications under the Stored Communications Act.