Government request policy
1. Introduction
1.1 Welcome to VERYCHAT! We are committed to always adhering to relevant laws and cooperating with relevant government agencies. This policy outlines how we respond to requests from government agencies, but please note that we may respond to such requests in different ways as required by applicable laws.
1.2 We receive various requests related to VERYCHAT from government authorities. Such requests may:
a. Involve the disclosure of user data by law enforcement agencies or through legal processes (e.g., court orders, subpoenas, police investigations). In such cases, we will handle the requests in accordance with our Law Enforcement Data Request Guidelines.
Be made by government authorities in ways other than those described in (a). We will handle such requests in accordance with this policy. (All such requests under (b) are referred to as "requests").
Requests falling under provision (b) and covered by this policy include the following:
Requests from government agencies for the removal of promotional political content that does not comply with relevant laws or regulations (for detailed information, refer to Article 11 of the Acceptable Use Policy).
Requests from telecommunications regulatory agencies regarding content distributed on VERYCHAT.
Requests for participation in discussions with government authorities.
This policy applies to requests from government authorities. When a government agency is the requester, we encourage compliance with this policy to enable us to respond to requests promptly and reasonably within the confines of relevant laws.
1.3 We reserve the right to modify this policy at any time without prior notice. It is advisable to check for regular updates on this page.
1.4 In this policy:
a. "We" or "Verychat Inc." refers to the company Verychat Inc.
b. "Requests" refer to all requests covered under section 1.2 (b) of this policy.
c. "Requesting authority" or "authority" refers to the government agency making the relevant request.
2. Relationships with Third Parties
2.1 We regularly receive data disclosure requests that do not pertain to data owned or held by us. We wish to clarify the following:
a. We cannot support requests related to platforms or services other than VERYCHAT (whether such platforms or services hold or are associated with the data in question, regardless of whether they are accessed through VERYCHAT). It is the responsibility of the requesting authority to make appropriate requests to other platforms or services (and their operators) as necessary.
b. As Wepin is operated by the company IOTrust, we cannot support requests related to Wepin and/or accounts associated with it.
3. General Principles of This Policy
We apply this policy according to the following principles, with further details specified in the remainder of this policy.
3.1 We act upon requests when legally required to do so. The basis for requests we comply with is specific laws and regulations. Such actions may include:
a. Deleting, disabling, or blocking content in specific jurisdictions as requested.
b. Publishing notices specifying actions taken in response to requests.
3.2 We do not hold all user information and content, and such information and content may be periodically deleted, de-identified, and/or modified. Our end users have rights regarding their information, which we handle in accordance with our Terms of Service and Privacy Policy. This means that the information is not retained by us and may be modified or deleted at any time. Further details regarding data handling practices are outlined in our Terms of Service and Privacy Policy.
3.3 It is our aim to apply this policy consistently and fairly across all jurisdictions where VERYCHAT operates, adhering to all relevant laws and regulations and interpreting them internally when potential differences exist between jurisdictions.VERYCHAT is accessible internationally, and to this end, we strive to apply all terms (including this policy) fairly and consistently across all jurisdictions.
3.4 In addition to section 3.3, we reserve the right to deviate from the application of this policy for various reasons on an ad-hoc basis. This may include compliance with relevant laws and regulations or upon receiving professional advice.
3.5 We aim for transparency in how our actions are perceived by users. Prior to and/or after complying with requests (in accordance with the requests and relevant laws and regulations), we reserve the right to notify users of such requests (including actions required by the requests). This is to ensure users have the right to respond to requests. Additionally, where actions in response to requests may affect other users, we may also notify other users of relevant requests we have complied with. For example, if we comply with a request to delete content, we may publish a notification explaining the reason for the content's deletion to users instead of the deleted content.
3.6 We do not automatically comply with all requests. We always carefully review all requests to respect users' rights while ensuring our responses comply with all relevant laws and regulations. This may involve seeking appropriate internal and third-party expert advice.
4. Application of this Policy
As stated, our goal is to apply this policy internationally with fairness and consistency. Please note the following regarding the application of this policy:
a. Due to legal requirements in specific jurisdictions (or conflicts between legal requirements in different jurisdictions), we may be unable to delete information and/or content in those jurisdictions. Where necessary and possible, we may use geoblocking technology to comply with legal requirements related to the deletion of information in specific jurisdictions (excluding other jurisdictions).
b. We will carefully review all requests to ensure compliance with the law. Where relevant or necessary, we may request the requesting authority to provide appropriate legal and/or evidentiary documentation before complying with requests.
c. No provision of this policy shall waive or limit any of our rights under all relevant laws and regulations. We reserve the right to appropriately question all requests. This may include seeking governmental/judicial review of the request and obtaining legal opinions from third parties.
5. Overview of Our Request Handling Process
5.1 When we receive a request, we typically process it as follows (always in accordance with relevant laws and regulations):
a. Review the request to ensure compliance with all relevant laws and our requirements.
b. Determine whether notification to affected users is necessary and appropriate.
c. Respond to the requesting authority regarding the outcome of the request.
6. Types of Requests Responded to by Us
6.1 General Requirements
When a government agency is the requester, the request should meet the following criteria:
a. In the form of an official PDF document.
b. Submitted with the appropriate and authorized representative of the requesting authority signing on the official document template of the requesting authority - refer to section 6.2.
c. Include all information specified in section 6.3.
d. Sent in accordance with section 9.
e. In English original or translated into English.
f. Comply with all relevant laws and regulations. We expect the requesting authority to have obtained legal advice regarding whether the request meets these requirements.
Requests that do not meet the above requirements may not receive a response.
6.2 Requesting Authority
The appropriate requesting agencies may vary from jurisdiction to jurisdiction. Government agencies or other authorities (e.g., electoral commissions, telecommunications regulatory agencies, consumer protection agencies, etc.) may submit lawful requests depending on the jurisdiction. The authority of these agencies varies according to the respective jurisdiction. As mentioned, we review all requests in accordance with relevant laws and regulations.
6.3 Request Format
We only respond to requests that include the following information as well as any other information required by relevant laws and regulations:
a. Identity of the requesting agency.
b. Identification of specific officials and/or agents ("requesting officials") responsible for the request task - including rank, badge/identification number, and credentials.
c. Relevant authorization documents for specific officials and/or agents of the requesting agency, if applicable.
d. Contact details of the requesting official - including phone number, email address (belonging to the email domain of the requesting authority), and postal address.
e. Reasonable response date from VERYCHAT for the request.
f. VERYCHAT users related to the request - including all known information regarding the user (user ID/VERYCHAT ID/account details/email address). This aids in identifying the data subject.
g. Specific actions requested and their relationship to the request-related matters.
h. Basis of the request - including all legal provisions underlying the request, and if applicable or necessary, detailed information about the nature of the investigations, procedures, and/or processes conducted by the requesting authority.
Please note that we may not be able to respond to ambiguous or incomplete requests.
7. User Notification
We respect the rights and privacy of our users. As stated in section 3.5 above, we may notify relevant users about requests before processing them. However, this excludes cases prohibited by relevant laws or regulations, or conditions of legal procedures (e.g., gag orders), and where such action is reasonably believed to immediately jeopardize or pose risks to us or third parties. Through this notification, end users can seek appropriate protective measures.
If the requesting authority believes that such notification would jeopardize an ongoing legal investigation, they may obtain a court order or legal process specifically prohibiting notification to users. As such notifications could potentially jeopardize ongoing legal investigations, it is the responsibility of the requesting authority to request that we do not inform users of the request.
If your request relates to ongoing or prior violations of our Terms of Service, we will take measures to prevent further abuse, including notifying users of the unlawful activity. Except when believed in good faith that such measures would jeopardize an ongoing investigation, providing an appropriate court order or legal process prohibiting such notification, beyond requesting us to defer such actions, is the responsibility of the authorities.
We reserve the right to challenge secrecy requests or orders in accordance with relevant laws and regulations.
8. Cost Reimbursement
Within the limits permitted by relevant laws and regulations, we may request reimbursement of costs incurred in responding to requests from the authorities.
9. Where to Send Requests
All requests must be emailed to policy@verychat.io with the subject "Governmental Request (insert jurisdiction)".
Please note:
a. Requests sent to the above contact will not be responded to or may be delayed.
b. Correspondence sent to the above contact from entities other than governmental authorities will not be reviewed.
c. Acceptance of legal processes through the above contact is for convenience only and does not waive our rights or objections regarding appropriate services or jurisdictional deficiencies.
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