Guidelines for Law Enforcement

These guidelines are intended for law enforcement authorities seeking information about imo accounts. imo discloses data to law enforcement in accordance with applicable laws, our Terms of Service, Privacy Policy and these guidelines. These guidelines are not intended to provide legal advice, nor do they create any enforceable rights against imo. imo reserves the right to update or change these guidelines without notice to law enforcement or governmental agencies.

For U.S. Legal Process

imo requires U.S. law enforcement and governmental agencies to follow U.S. law, typically the Stored Communications Act, 18 U.S.C. § 2701-2712, in order to obtain any imo account information. In order for imo to disclose certain types of information, a valid subpoena, court order, or search warrant is required, depending on the specific legal process issued.

For Non-U.S. Legal Process

Non-U.S. law enforcement and governmental agencies must typically request imo account information via the Mutual Legal Assistance Treaty or letters rogatory processes. At our discretion, we may provide limited non-content information to non-U.S. law enforcement and governmental agencies in response to duly authorized legal process from the requesting country.

It is important to note that some information we store is collected automatically, while other information is provided at the user’s discretion. Though we do store this information, we cannot guarantee its accuracy. imo doesn’t require real name use, email verification, or identity authentication.

Emergency Requests

imo, at its discretion, may voluntarily disclose imo account information consistent with 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) when we believe in good faith that an emergency involving a threat of imminent death or serious bodily injury requires the immediate disclosure of such information.

In a situation where there is an emergency involving threat of imminent death or serious bodily injury, law enforcement can submit an emergency request for the disclosure of imo account information by completing and submitting the Emergency Disclosure Request Form as attached in Annex 1.

We will review and respond to emergency requests on a case-by-case basis.

We will only respond to emergency requests from law enforcement. If you are not law enforcement and are aware of an emergency situation, please contact your local law enforcement.

Preservation Requests

For U.S. law enforcement, we will preserve information in accordance with 18 U.S.C. § 2703(f). When we receive a preservation request, we will attempt to preserve any available account information associated with any identified imo account(s) within the date range specified in the request. We will preserve this information for 90 days, and we can extend the preservation for another 90 days with a formal extension request.

For non-U.S. law enforcement, imo may, at its discretion, preserve available imo account information for up to 90 days while the Mutual Legal Assistance Treaty or letters rogatory process is undertaken. imo may extend such preservation for one additional 90 days period with a formal extension request. Preservation requests must be sent on law enforcement letterhead in a non-editable format, be signed by the requesting official, have a valid return official email address, and must clearly identify the specific user data to be preserved.

Users Notification

imo's policy is to notify users of requests for their information prior to disclosure, except (i) where providing such notice is prohibited (a) by a court order issued under 18 U.S.C. § 2705; or (b) by other legal authority; (ii) in exceptional circumstances such as (a) such notice could create a risk of injury or death to an identifiable individual(s); or (b) cases that involve potential harm to minors; or (c) when notice would be counterproductive. Law enforcement officials who believe that notification would meet any of the above criteria should indicate that notice is prohibited. If a request includes a nondisclosure order, imo will notify the affected user as soon as the order is overturned or expires on its own terms.

Other Information Requests

Please note that we cannot accept service of legal process through email if you are not affiliated with a law enforcement or governmental agency and are seeking information for criminal or civil discovery. You must properly serve such legal process on imo or our registered agent for service of process.

Law Enforcement Requests Requirements

In order for imo to respond to your request, your request must be signed, dated, sent on law enforcement letterhead and include the following information:

• Legal basis for the request:
  i. An applicable valid document served through the legal process described above;
  ii. The specific context, offences under investigation or the event or action in which the data subject is involved;
  iii. User notification. Please indicate whether user notification is permitted.
• Details of requesting law enforcement authority
  i. The name and location of the law enforcement or governmental agency;
  ii. Requesting officer or agent name, badge/identification number;
  iii. Official mailing address;
  iv. A valid return email address from an official government domain.
• Details of information requested
  i. The requested imo account registered phone number(s) with country code or user ID;
  ii. The specific information requested including the date range.

We will reject requests that do not include the above information. We will also reject requests that we believe are not facially or substantively valid or if we believe the requests are overly broad, vague, unclear, or unduly burdensome. If the formal request is not in English, we encourage the law enforcement to provide an English translation. Absent exceptional circumstances, we will not disclose more user information than is necessary to comply with a valid request which imo is obliged to comply with as a matter of law.

User Consent

If a law enforcement requests information about a user who has provided consent for the official to access or obtain the user’s account information, the user should be directed to obtain that information on their own from their account.

How to Submit Legal Process

We encourage law enforcement or government agencies to contact us via email at legalprocess@imo.im regarding the availability of user information before serving the formal request.

Legal process should be addressed to:

And sent via email to legalprocess@imo.im

Acceptance of legal process by email is only for convenience, and by doing so imo does not waive any objections, including lack of jurisdiction or proper service.

Certificate of Authentication or Expert Testimony

We may provide a certificate of authentication, but we generally are not able to provide in-person or expert witness testimony.

Cost Reimbursement

imo may seek reimbursement for costs associated with responding to law enforcement requests for information as permitted by law and may charge additional fees for costs incurred in responding to unusual or burdensome requests.

Annex 1 PAGEBITES EMERGENCY DISCLOSURE REQUEST FORM

Please be advised that ordinarily PageBites only responds to valid legal process issued by a U.S. governmental entity or U.S. court and properly served on it in the U.S. However, in rare emergency circumstances PageBites may choose to make an exception where there is an imminent threat to a person’s safety.

If you are a sworn law enforcement official and believe that PageBites may have information to assist in averting a specific and imminent threat to life, please answer all questions in this form as completely as possible and provide your contact information and signature and the contact information and signature of another officer with whom you work at the bottom of the form. The information provided will assist PageBites in determining whether to exercise its discretion to disclose information to you pursuant to 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4).

1. Are you seeking information in connection with an emergency involving danger of death or serious physical injury to a person that requires disclosure, without delay, of information relating to the emergency? (Yes or No)
2. Please describe the nature of the emergency involving death or serious injury?
3. Whose death or serious physical injury is threatened?
4. What is the imminent nature of the threat? (i.e., do you have information that suggests that there is a specific deadline to receive the information before the act indicated in response to Question 2 will occur (i.e., tonight, tomorrow at noon).
5. Please explain why the normal disclosure process (including any statutory emergency procedures) would be insufficient or untimely in light of the deadline set forth in Question 4.
6. Please specify the IMO account number(s) you are requesting information about, how the account(s) are connected to the emergency, and what specific information in PageBites’ possession related to the emergency are you seeking to receive on an emergency basis? (Please be as specific as possible, as requesting all information in PageBites’ possession will likely result in delay or denial of this request.)

I certify that the foregoing is true and correct and I understand that PageBites and/or its agents may rely on the information provided when determining whether to make an emergency disclosure of information to law enforcement.