Effective Date: January 7, 2022
This policy is solely intended for use by law enforcement or official representatives of government agencies (“Requestor,” “You,” or “Your”) that have made or wish to make a request to Sovrn, Inc., or one of its affiliated companies (collectively, “Sovrn,” “we,” or “our”) for data we receive or process from our customers, partners, or other data providers (each, a “Sovrn Partner” and collectively, the “Sovrn Partners”), including individual personal data (collectively, “Protected Information”). This policy is not intended for requests for information by Sovrn customers, business partners, individuals, civil litigants or criminal defendants.
Sovrn is committed to the importance of trust and transparency pertaining to how we use and disclose Protected Information. Except as expressly permitted by the relevant contract with a Sovrn Partner, Sovrn will only disclose Protected Information: (a) pursuant to a valid legal request, or (b) in the case of an emergency where there is a danger of death or serious physical injury to a person that Sovrn may have information necessary to prevent.
To protect the rights of our Sovrn Partners, we carefully review requests to ensure that they comply with applicable laws. This policy is intended to serve as an informational resource and does not create obligations or waive any objections concerning how Sovrn will respond in any particular case or request. Please review this policy before submitting a request to Sovrn.
Legal Request RequirementsRequestors in the United States are required to provide a valid subpoena, court order or search warrant issued under the procedures described in the Federal Rules of Criminal Procedure or equivalent state warrant procedures upon a showing of probable cause. Requestors outside of the United States must use a Mutual Legal Assistance Treaty (MLAT) or letters rogatory processes to request Protected Information from Sovrn.
In order for Sovrn to process Your request, it must meet the following conditions:
- be sent by a law enforcement agency or official government entity via a registered email domain;
- include valid and enforceable legal process (e.g., a subpoena, court order, search warrant, or letters rogatory) that compels Sovrn to produce the Protected Information requested;
- contain the name and contact information of the individual law enforcement agent or government representative who is authorized to serve the request;
- contain the name of the law enforcement agency or official government entity;
- state with particularity the categories of records or information sought;
- in the case of Sovrn Partner accounts, include sufficient information regarding the Sovrn Partner, such as the name of the legal entity, in order for Sovrn to identify the account(s) at issue;
- indicate the specific time period for which information is requested; and
- Indicate the required response date (see below for emergency requests).
Emergency or Child Safety ConcernsConsistent with applicable law, Sovrn may disclose information to You in the case of an emergency necessary to prevent danger of death or serious physical injury to a person for whom Sovrn may have information. Sovrn will evaluate emergency disclosure requests on a case-by-case basis in compliance with applicable law.
In order for Sovrn to process Your emergency disclosure request, the request must:
- contain all available information as outlined above in the “Legal Request Requirements” section to assist Sovrn in evaluating the urgency of the request;
- include the circumstances of the request and the nature of the claimed emergency;
- explain why there is insufficient time to obtain and serve a valid and binding legal demand;
- explain how the information requested will assist in averting the claimed emergency; and
- include the following label in the email subject line: “Emergency Disclosure Request.”
Unless Sovrn is prohibited from doing so, or there is a clear indication of illegal conduct or risk of harm, it is Sovrn’s policy to notify affected Sovrn Partner(s) of Your request before disclosing any Protected Information so that the Sovrn Partner has an opportunity: (a) to process the request itself (in collaboration with Sovrn if necessary); (b) to assess the legality of the request; (c) to minimize the Protected Information that is disclosed to the minimum amount permissible as relevant to the specific request; and (d) to seek legal remedies. If Sovrn is legally prohibited from notifying the Sovrn Partner prior to the disclosure, then Sovrn will take reasonable steps to notify the customer of the disclosure after any relevant non-disclosure requirement expires.
Where To Send Requests
Requests should be sent to compliance [at] sovrn [dot] com. You may also use this email address for questions to Sovrn about this policy, though it is important to recognize that Sovrn cannot provide legal advice to Requestors. Please allow at least two (2) weeks for Sovrn to respond to your request. Sovrn may need additional time to respond to certain requests. In these cases, we will notify you and request additional time to prepare our response. Emails from any private person or entity or non-governmental email address may not receive a response.
Sovrn will also accept service of process at the following address:
Attn: Legal Department
5541 Central Ave, Suite 100
Boulder, CO 80301
While we agree to accept service of law enforcement requests by these methods, neither Sovrn nor our Sovrn Partners waive any legal rights based on this accommodation.