Law Enforcement Guidelines

These guidelines are for law enforcement officials, government agencies and parties to civil or criminal litigation who want information about Clairitea users. They explain what information exists, what legal process we require, how we handle emergencies, and when we notify users. They are not legal advice, and they do not create rights for anyone. Users can read them to understand how their information is protected.

Clairitea is operated by [FOUNDER: company legal name]. Our user records are subject to the Stored Communications Act, 18 U.S.C. § 2701 and following ("SCA"), and other applicable law.

1What information exists

Clairitea is an iOS app and website where adults post first-hand experiences about people they have dated or met. It has no private messaging between users. What we hold, and for how long, is set out in our Privacy Policy. In summary:

Account records (non-content):

• the account's creation date, status, metro area, and whether it confirmed it is 18 or older;
• how the account signs in: Sign in with Apple, Google or phone number. Our app database holds only a keyed one-way hash of the phone number or sign-in identifier. Our sign-in system holds the phone number, or the provider's identifier and any email address the provider shared, while the account exists and for up to 90 days after it is deleted;
• hashed device identifiers, device platform, app version, time zone and push notification token;
• subscription status and App Store or web transaction identifiers (we do not hold payment card details; web payments are processed by Stripe through RevenueCat);
• a record of pages the account opened, kept for 90 days;
• the account's rule-violation record.

We do not store IP addresses in our app database. Our hosting and network providers' request logs record them and are kept for up to 30 days. We do not hold precise location, contact lists, government ID images, selfies, biometric data or voice recordings. Posts do not show who wrote them, and there is no private messaging between users.

Content:

• posts, questions, comments, replies, ratings, flags and reactions, with the account that made them;
• photos, and screenshots in both their original (metadata removed) and redacted form;
• reports, appeals, support messages and disputes the account filed.

Deleted data. When a user deletes their account or content, most of it is deleted on the schedule in our Privacy Policy. Removed posts and comments are kept for 90 days and then reduced to a one-way hash. Hashed identifiers are kept for 90 days after an account is deleted. We generally cannot recover data after those periods.

2Legal process we require

We disclose user information only in accordance with our Terms of Service, our Privacy Policy and applicable law.

Posts that are published on Clairitea can be seen by other users. That does not change what process we require to disclose which account wrote them.

Requirements for every request. Requests must be in writing, on official letterhead or issued by a court, and must identify the account as specifically as possible. The best identifier is the link to the page and a description of the post or comment, including its approximate date. A name alone is usually not enough, because many people share names and posts do not show who wrote them. Requests must include the requesting official's name, agency, badge or identification number, email address and phone number, and must set out the legal authority for the request.

Scope. We interpret requests narrowly. We may object to or narrow requests that are overly broad, vague, unduly burdensome or not supported by valid legal process, and we may ask a court to quash or modify them.

Verification. We verify the authenticity of legal process, including by contacting the issuing court or agency.

Reimbursement. We may seek reimbursement for the costs of responding, as the law allows.

3Preservation requests

We will preserve records for 90 days in response to a formal preservation request from a government entity under 18 U.S.C. § 2703(f), pending receipt of formal legal process, and will extend preservation for one further 90-day period on a renewed request. Preservation requests must identify the account as described in Section 2 and be signed by the requesting official. Civil litigants who believe information is relevant to anticipated litigation should send a preservation letter to the address in Section 7. We will review it and preserve information as the law requires.

4Emergency requests

If a government entity believes that an emergency involving danger of death or serious physical injury to any person requires disclosure without delay, we may disclose information under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4). Send emergency requests to legal@clairitea.com with the subject line "EMERGENCY DISCLOSURE REQUEST", and include:

1. the nature of the emergency, and who is at risk;
2. why the emergency requires disclosure without the delay of normal legal process;
3. the specific information sought, and the account (as described in Section 2); and
4. the requesting official's name, agency, badge number and a phone number we can call to verify the request.

We evaluate emergency requests case by case and may ask for legal process afterward. Emergency requests are for law enforcement only. Anyone else in danger should call 911.

5User notice

Our policy is to notify users before we disclose their information in response to a request, and to give them a copy of the request, so that they can seek legal advice and object.

• Civil requests: we notify the user and give them at least 14 days to tell us they have filed a motion to quash or otherwise object in court before we disclose anything. We do not disclose while a timely objection is pending. This includes subpoenas and petitions to identify an anonymous poster before a lawsuit is filed, such as a petition under Texas Rule of Civil Procedure 202. We may ask the court to require the requester to show a valid claim before we identify anyone.
• Government requests: we notify the user unless we are prohibited from doing so by a court order issued under 18 U.S.C. § 2705(b) or other legal authority, or unless we believe in good faith that notice would create a risk of death or serious physical injury to any person, or would be counterproductive in a case involving child sexual exploitation. If a non-disclosure order ends or the emergency passes, we notify the user then.
• Requests should state any legal prohibition on notice. A request that does not state one may be disclosed to the user.

6Child safety

We report apparent child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC) as required by 18 U.S.C. § 2258A, and we preserve the related information as that law requires. Clairitea does not allow users under 18 or content about anyone under 18.

7How to send a request

Legal process and preservation requests: legal@clairitea.com, or by mail or service to [FOUNDER: company legal name], c/o [FOUNDER: registered agent name and address].

Emergency requests: legal@clairitea.com, subject line "EMERGENCY DISCLOSURE REQUEST".

We accept service of legal process by email only as a courtesy for law enforcement requests. Accepting a request by email does not waive any objection, including objections based on jurisdiction or improper service.

8Requests from outside the United States

Clairitea is operated from the United States. Foreign governments should seek information through a Mutual Legal Assistance Treaty request, letters rogatory, or another process recognized under U.S. law, such as an agreement under the CLOUD Act. In an emergency involving danger of death or serious physical injury, foreign authorities may use the process in Section 4.

9Testimony

We do not provide expert testimony. Records we produce are accompanied by a certificate of authenticity where the law provides for one, which should make the testimony of a records custodian unnecessary.