Law Enforcement Guidelines

Snug is committed to the privacy and safety of the people who use our service. We also recognize our responsibility to cooperate with law enforcement in connection with lawful investigations.

These guidelines explain how law enforcement officials can request information from Snug Technology, Inc. (“Snug”) and what legal process is required for different categories of data. We produce information only when we receive valid legal process, and we review every request for legal sufficiency. We object to requests that are overbroad, vague, or legally deficient.

These guidelines apply to requests from law enforcement in the United States. They do not create any enforceable rights against Snug, and they do not waive any legal objection Snug may raise. Snug may update these guidelines at any time.

All law enforcement requests must be made in writing, on official letterhead, signed by the requesting official, and sent from an official law enforcement email address.

Send requests to:

Email: safety@joinsnug.com

To help us respond, every request should include:

• The name of the requesting agency and official, and a direct callback contact.

• The specific account identifier you are seeking records for, such as an email address, phone number, or Snug username.

• The specific categories of information requested.

• The legal basis for the request.

• A response deadline that allows a reasonable time to process.

Requests that do not identify a specific account with enough detail for us to locate it may not be actionable.

Snug follows the framework of the Stored Communications Act (18 U.S.C. § 2701 et seq.). The type of legal process determines the categories of information we can disclose.

Subpoena. With a valid subpoena, Snug may disclose basic subscriber information where available, which can include the name, email address, phone number, account creation date, and IP address used at registration. Snug does not disclose full payment card numbers.

Court order under 18 U.S.C. § 2703(d). With a valid 2703(d) order, Snug may disclose the categories above plus certain non-content records and account activity where available, such as connection logs and message metadata. This does not include the content of communications.

Search warrant. With a valid search warrant issued on a showing of probable cause, Snug may disclose stored content where available, which can include message content, photos, and profile content associated with an account.

Snug produces only information it actually possesses and retains at the time of the request. See Data Availability and Retention below.

If Snug receives a request from law enforcement involving a risk of imminent death or serious physical harm to any person, Snug may voluntarily disclose information to the extent permitted under 18 U.S.C. § 2702(b)(8) and (c)(4).

Emergency requests should be clearly labeled as an emergency and sent to safety@joinsnug.com. The request should describe the nature of the emergency, the specific harm and person at risk, and why the information sought is needed to prevent that harm. Snug evaluates each emergency request in good faith and reserves the right to require formal legal process where an emergency does not exist.

Snug will honor valid preservation requests made under 18 U.S.C. § 2703(f). On receipt of a proper request, Snug will preserve available records associated with the identified account for 90 days, and will extend that period once for an additional 90 days on a renewed request. A preservation request does not require Snug to disclose any information. Disclosure requires the appropriate legal process described above.

Snug’s policy is to notify users about requests for their information before disclosure, so that they may seek to protect their rights, unless we are prohibited by law from doing so or a clear exception applies. Exceptions include a valid court order or statute prohibiting notice, an emergency involving a risk of death or serious physical harm, and matters involving child safety. Where a nondisclosure obligation has a defined term, Snug’s policy is to notify the user on expiration of that term.

Snug takes steps to verify that requests originate from legitimate law enforcement sources before disclosing any information. We may contact the requesting agency through independently verified channels. Requests that cannot be authenticated will not be processed.

Snug can only produce information that exists and that we retain in the ordinary course of business at the time we process a request. We do not create records that do not already exist, and we do not retain all data indefinitely. If the requested information is not available, we will indicate that where permitted.

Snug reports apparent child sexual abuse material to the National Center for Missing and Exploited Children (NCMEC) as required by 18 U.S.C. § 2258A. We cooperate with investigations involving the exploitation or endangerment of minors.

Law enforcement authorities outside the United States should generally proceed through a Mutual Legal Assistance Treaty (MLAT), a letter rogatory, or another recognized channel for cross-border legal assistance, so that a request can be served through appropriate United States legal process.

Snug reserves the right to seek reimbursement for costs incurred in responding to legal process, to the extent permitted by law.

Nothing in these guidelines waives any objection Snug may assert, or any right Snug may have, in response to a request for information. Snug may decline requests that are not supported by valid legal process.