Information Regarding Law Enforcement Requests for Data

HODLTech OÜ appreciates the work of law enforcement agencies around the world and will assist law enforcement agencies where possible subject to applicable law and company policy.

This Law Enforcement Request Portal has been developed to ensure transparency and streamline the processing of legal requests for information where it pertains to production orders, preservation orders, and fund freezing and shall be effective starting on July 15th, 2019. HODLTech OÜ will not and does not voluntarily disclose non-public information to a requesting party. In accordance with EU and Estonian privacy law, HODLTech OÜ will only disclose non-public user information if it has received consent of the user and in response to a legitimate and an enforceable subpoena, court order or search warrant from a body that has jurisdiction to compel HODLTech OÜ to disclose that information.

HODLTech OÜ (“we”, “us” and “our”) takes data protection and security seriously. Please consult our Privacy Policy (http://hodltech.eu/pp.pdf) for more information.

General Guidelines:

• When law enforcement agencies request non-public information (such as a user’s personal or financial information), we will not share this information unless we have previously obtained consent from such user to disclose such type of information and an enforceable court order, subpoena or search warrant has been issued and received by us;
• We will notify affected users if we believe we are legally required to provide their personal or financial information to a law enforcement agency, unless we are prohibited by law from doing so;
• When law enforcement agencies request information about a user who is a merchant, we cannot and will not provide information about such merchant’s customers who are not our customers or platform users. We consider this information to be in the possession, control and custody of the merchant, who is the controller and processor of such information. If law enforcement agencies request this information, such requests for information should be directed to the relevant merchant and not HODLTech OÜ; and
• Only information specifically requested and clearly outlined in an enforceable court order, subpoena or search warrant will be disclosed by us.

This policy does not constitute legal advice or a promise or guarantee that we will respond to any requests for information in a specific way or at all. All legal requests for information will be dealt with on a case-by-case basis. We reserve the right to change this policy or these guidelines in our sole discretion at any time.

When requesting the confirmation of existence of data on our platform the law enforcement agency must be very specific about what information it is looking to obtain as HODLTech OÜ cannot entertain or respond to vague, ambiguous or blanket requests. Certain identifiers are helpful in determining whether we currently retain the requested information and blanket requests cannot be processed.

While HODLTech OÜ does provide virtual currency wallet services to merchants, it cannot and does not possess or control information with respect to merchants’ customers. We consider such information to be in the possession, control and custody of such merchants, who are the controller and/or processor of this information. If law enforcement agencies request this information from us, we will not be able to provide such information and will ask law enforcement agencies to contact merchants directly for such information.

Submitting a Request:

To aid the expeditious review of information requests, law enforcement officers should include at least the following information in the below form:

• Name of the law enforcement authority;
• Proof that the officer is authorized to request the information (proof of authority) and current position within the law enforcement organization;
• Proof of identification of the officer within the law enforcement organization (e.g. photo or other official ID which includes badge number, internal ID number);
• Email address from a government domain;
• Contact information (email address, number) from the governmental organization;
• The name of the legal entity that the request is addressed to;
• Details of the request, including:
  • Subpoena identifier-number in the subject line;
  • How we should authenticate the subpoena, such as call-back procedure;
  • Any public address or transaction IDs in text format or an Excel file (not PDF);
  • State a reasonable deadline;
  • Official and enforceable court order, subpoena or search warrant;
  • Reason for the requested information (ie. possible crimes in question, etc.); and
  • Mutual Legal Assistance Treaty request for cross-border law enforcement (if applicable).

HODLTech OÜ requires sufficient information to uniquely identify the user/customer. Unique identifiers include Blockchain Transaction ID or Receiving Virtual Currency Address, Payment ID or merchant email address.

A common name is not usually enough to identify an individual.

*Please note that failure to complete the mandatory sections of the below form may result in slow response times and/or no response.

*All legal requests must be submitted through this Law Enforcement Request Portal.