COMPANYCAM, INC.
Law Enforcement Data Request Guidelines

CompanyCam, Inc. (“CompanyCam”) provides software tools for teams to collaborate in an online platform environment. These guidelines provide information to inform law enforcement officials seeking customer account records and customer content (“Customer Information”) from CompanyCam in response to valid legal process, consistent with our Privacy Policy and acceptable use policy. CompanyCam respects the rules and laws of the jurisdiction in which it operates, as well as the privacy and rights of its customers. Accordingly, CompanyCam provides Customer Information in response to law enforcement or other public authority requests only when we reasonably believe that we are legally required to do so. To protect our customers’ rights, we carefully review requests to ensure that they comply with the law and are within the powers of the requesting authority or law enforcement official.

To obtain Customer Information from CompanyCam, public authority and law enforcement officials must provide legal process appropriate for the type of information sought, such as a subpoena, court order, or a warrant. For example, CompanyCam will not provide non-public customer content unless served with a valid search warrant, issued on a showing of probable cause by a federal or state court authorized to issue search warrants, which requires CompanyCam to disclose the content. Please review these guidelines before submitting a law enforcement request to CompanyCam.

CompanyCam reviews all governmental requests for data. CompanyCam strictly construes requests for data and seeks to limit or object to requests that are overbroad or seek a large amount of information or affect a large number of users. CompanyCam also objects where production is prohibited or where the process served is insufficient to compel production of the requested data under the Electronic Communications Privacy Act, 18 U.S.C. § 2701, et seq. or other applicable law. CompanyCam reserves the right to appeal any request for information, where available, and shall not disclose the requested information until required to do so under applicable procedural rules.

These guidelines are intended to serve as an informational resource and do not create obligations or waive any objections concerning how CompanyCam will respond in any particular case or request. CompanyCam reserves the right to seek reimbursement for the costs associated with responding to public authority or law enforcement data requests, where appropriate.

User Notice Policy

CompanyCam’s policy is to notify customers of requests for their information and provide them with an opportunity to object to the disclosure 7 – 10 days prior to production unless such notification is prohibited by law (including where CompanyCam has been unable or unsuccessful at obtaining a waiver of such prohibition). CompanyCam may shorten the notice period in its discretion, but generally only does so in emergency situations. Public authority or law enforcement officials who believe that notification would jeopardize, for example, an investigation, should obtain an appropriate court order or other process that specifically prohibits customer notification, such as an order issued under 18 U.S.C. § 2705(b).

Further, if your request places CompanyCam on notice of an ongoing or prior violation of our acceptable use policy, we will take action to prevent further violation, including account termination and other actions that may notify the user that we are aware of the misconduct. If you believe in good faith that taking such actions will jeopardize an ongoing investigation, you may request that CompanyCam defer such action in your request. CompanyCam will evaluate such requests on a case-by-case basis. It is the responsibility of the requesting law enforcement official to make this request, as it is CompanyCam’s policy to enforce its Terms of Use.

Serving a Valid Law Enforcement Request & Contact Information

Email Address for Law Enforcement Questions and to Send Legal Process:

lawenforcement@​companycam.​com

Mailing Address for Law Enforcement Requests:

CompanyCam Inc.
 Attn: Legal Department
 300 Canopy Street, Suite 200
 Lincoln, NE 68508

While we agree to accept service of public authority and law enforcement requests by these methods, neither CompanyCam nor our customers waive any legal rights based on this accommodation.

Each request must include contact information for the authorized public authority or law enforcement agency official submitting the request, including:

• Requesting agency name
• Requesting agent name and badge/​identification number
• Requesting agent employer-issued email address
• Requesting agent phone contact, including any extension
• Requesting agent mailing address (P.O. Box will not be accepted)
• Requested response date (see details below for emergency requests)

Please note that requests seeking testimony must be personally served on our registered agent for service of process. We do not accept such requests in person or via email.

Available CompanyCam Customer Information

CompanyCam offers a variety of software tools on its platform that contain Customer Information. In addition, CompanyCam maintains certain Customer Information in internal systems as a matter of regular business processes. CompanyCam will review and respond to requests for Customer Information pursuant only to a valid, enforceable government request, court order and/​or warrant, depending on the type of information requested, which CompanyCam has determined has been made within the scope of the power of the requesting authority or law enforcement body.

The categories of Customer Information that may be available for law enforcement requests seeking basic customer account information, include, for example: email address, name, phone number, username and/​or billing contact information (in connection with paid accounts). Additional information regarding IP addresses, transactional records and other customer records may be available.

The categories of Customer Information that may be available to law enforcement requestors depends on which CompanyCam product is used by the customer about whom law enforcement seeks information. We encourage law enforcement officials making a request for CompanyCam Customer Information to review our product descriptions before preparing legal process and submitting your request, order, or warrant. 

Law Enforcement Preservation Requests

CompanyCam will preserve Customer Information for 90 days upon receipt of a valid law enforcement request. CompanyCam will preserve information for an additional 90-day period upon receipt of a valid request to extend the preservation. If CompanyCam does not receive formal legal process for the preserved information before the end of the preservation period, the preserved information may be deleted when the preservation period expires.

Preservation requests must be sent on official law enforcement letterhead, signed by a law enforcement official, and must include:

• The relevant account information identified below for the customer whose
• information is requested to be preserved;
• A valid return email address; and
• A statement that steps are being taken to obtain a court order or other legal

process for the data sought to be preserved.

Preservation requests may be sent to the contact information (mailing address or email account) provided above.

How to Request CompanyCam Customer Information

When requesting Customer Information, law enforcement requestors should provide as much of the following information as is available. Providing the following identifying information will facilitate CompanyCam’s ability to respond in an effective and timely manner:

• User’s Contact Information: full name and business name (if known), email
• address, and mailing address.
• A detailed description of the information being requested.

International Law Enforcement and Public Authority Requests

U.S. law authorizes CompanyCam to respond to requests for Customer Information from foreign law enforcement agencies that are issued via a U.S. court either by way of a Mutual Legal Assistance Treaty (MLAT) request or letter rogatory. It is our policy to respond to such U.S. court-ordered requests only when they are properly served, appropriately scoped, within the power of the requesting authority or agency, and in accordance with applicable legal process. CompanyCam will evaluate emergency requests from foreign law enforcement on a case-by-case basis, consistent with U.S. law and the laws of other countries, if applicable.

Emergency requests may be submitted directly to CompanyCam via the procedure described below.

Emergency Requests

CompanyCam evaluates emergency requests on a case-by-case basis. If you provide information that gives us a good faith belief that there is an emergency involving imminent danger of death or serious physical injury to any person, we may provide information necessary to prevent that harm if we are in a position to do so, consistent with applicable law.

Emergency requests may be submitted via email to lawenforcement@​companycam.​com with the subject line: ​“Emergency Disclosure Request” and completing and sending the Law Enforcement Request for Emergency Disclosure of CompanyCam Customer Information form attached hereto.