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 we reasonably deem necessary to assist in, or as legally required to comply with, a pending criminal investigation, a court order, search warrant, summons, subpoena, or other valid legal process received by the Company.
To request user data, please send an email to [email protected] that (1) complies with the limitations and requirements herein, and (2) contains, as described in detail below: (a) the requested search identifiers, and (b) the categories of user data requested.
Please do not send user service requests or unrelated documents to our Legal Contact. 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. Please note that the Company is based in the European Union, and we do not maintain offices in the United States, Canada, or elsewhere.
Law Enforcement Requests
We balance the privacy rights of our users with our respect for law enforcement efforts to combat crime - particularly trafficking and abuse of minors. In an effort to assist law enforcement and other governmental agencies in meeting these goals, we strive to assist in pending criminal investigations by providing available user data within two (2) weeks. In some cases, additional time is required. In limited scenarios involving an imminent threat of death or bodily injury, we may prioritize certain requests to expedite a response, in our discretion.
While we will typically provide available user data in response to requests from all law enforcement officers and government attorneys, we reserve the right to insist on receipt of a court order, search warrant, summons, subpoena, or other valid legal process when necessary or appropriate. Please review applicable law before submitting requests for user data.
Non-Law Enforcement Inquiries
If you are aware of any user engaging in activities that violate our policies, please contact us and provide as much detail as possible, including a URL or post ID, a description of the offense, the date and time of identification, the reason we should remove the offending materials or investigate the activities, and a statement certifying the accuracy of the information you provided to us.
If you are concerned about illegal activities by any of our users, please contact local law enforcement. As noted above, we voluntarily assist in law enforcement investigations into abuse of our services.
We typically require a subpoena or court order from a court of competent jurisdiction before providing user data to private parties including private investigators and non-governmental attorneys. We further reserve the right to request additional data from the requesting party, including without limitation, authenticated copies of court pleadings, in order to verify that the requested data is relevant to any civil or administrative matter. If you wish to send us a subpoena for user data, please transmit the document to [email protected].
Search Identifiers
We can search for available user data using any of the following search identifiers:
URL
Post ID number (found at the end of the URL)
Email address
Telephone number
If a URL or Post ID is provided, please include the date the URL or post ID number was collected. Failure to provide an accurate date that the URL or post ID number was collected may result in providing inaccurate user data or our inability to process the request.
Categories of Available User Data
Responsive user data may include registration information and available posts. Please contact us with any questions regarding data that may be available in response to any particular request.
Certifications and Testimony: Where specifically requested, we will also provide a Certificate of Authenticity of Foreign Business Records for records authentication purposes. Please note that the Company is based in the European Union, and our employees are unable to appear for live testimony in the United States, Canada, or other foreign jurisdictions.
User Communications: Please note that we do not offer a direct messaging feature, so there are no records of any communications between users. Any communications between our Publishers and the individuals who view their posts occur on third-party services. We do not have knowledge of or access to any communications between users, and records of such communications can only be requested from the relevant third-party service providers, not us.
Data Retention
We maintain user data for no more than ninety (90) days from the date the associated account was last active. We do not guarantee the existence, accuracy, or regularity of our storage or backup services. Due to data storage capacity and security concerns, all user data and any archival copies 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 preservation request from law enforcement, 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 our 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 assisting 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:
Research: €75.00/hour
Copies: €0.25/page.
Media Storage Devices (e.g. – CD, DVD, portable drives, etc.): Actual cost.
Mailing / Document Delivery: Actual cost.
Other Costs: Rate determined as incurred.
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:
To satisfy any legal obligation;
To identify, contact, or bring legal action against someone who may be violating any our policies;
To investigate fraud or deceptive activity;
To maintain the security of our system(s), servers, datacenters, or properties;
To operate our services properly; and
To protect ourselves, our users, and the general public. In reflection of our continued support of law enforcement, we specifically reserve the right to disclose any and all necessary data to law enforcement in the event of ongoing criminal activity involving our system, illegal use of our system, and/or active human trafficking investigations.