Law-enforcement guideWe answer valid orders. There is very little to answer them with.
This is not a refusal page. Valid process from a court with jurisdiction over the entity served is reviewed by counsel and complied with. It is a page about what exists to be produced, which is an email address the customer chose and a ledger of amounts.
Step one
You are serving one company, not a brand.
Each region is operated by a separate company incorporated in that country. An order binding one of them binds one of them. This is the single most common reason process sent here achieves nothing, and it is entirely avoidable.
Reykjavík
Bucharest
Sofia
Chișinău
Zurich
Amsterdam
Panama City
SingaporeService is effected on the registered office of the entity, through the process its own jurisdiction provides for — each company’s registered address is on the public register named above, which is where service has to be directed to be good service in any case. Email to an abuse address is not service, and will be answered saying so.
The complete inventory
Everything that exists about a customer, why it exists and how long it lasts. There is no second list held back for a rainy day; this is the schema.
Never created
An order for a record that does not exist produces a letter.
Not a refusal — an explanation, in writing, of why the category is empty. These are not records we delete on receipt of process; they are records the systems have never been built to make. That distinction matters to a court, and it is the only version of this promise that survives contact with one.
The full retention schedule- Government identity documents, of any kind, at any tier
- Your legal name, address, country or telephone number
- Payment-card details, bank details or any KYC file
- A record of the addresses you sign in from
- IP history, session history or device fingerprints
- Netflow detailed enough to reconstruct who talked to whom
How a request is handled
Five steps, and the fifth is the one most providers leave out.
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01
Identify the right entity
There are eight companies in eight countries and they are genuinely separate. An order against the Panamanian company does not bind the Icelandic one, and asking the wrong one costs you the time it takes us to say so.
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02
Serve it through the register
Service is effected on the registered office of the entity, through the process its jurisdiction provides for. Email to an abuse address is not service and will be answered saying exactly that.
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03
Say what you want, precisely
An order naming a service, a period and a category of record can be answered. One asking for "all data relating to the account" produces a slow letter explaining that the category is mostly empty.
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04
We check it, then we answer it
Reviewed by counsel in the jurisdiction. Valid and within scope: we produce what exists, which is the inventory above. Invalid, overbroad or from a court without jurisdiction: we say so in writing and explain why.
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05
The customer is told
Before we produce anything, unless an order expressly forbids it. No such order has ever arrived, and the day one does the warrant canary stops being renewed.
164
Requests received, all time
54
Met the legal bar
31
Produced anything at all
0
Arrived with a gag
Counted from апрель 2019 and published quarterly in the transparency report. The last figure is the one the warrant canary exists to make checkable, because it is the one figure a provider under a gag order would be unable to correct.
Emergencies
Where there is a credible, immediate risk to someone’s life, the process above is too slow and we say so plainly rather than hiding behind it.
- Reviewed
- The hour it arrives, at any hour Mark it urgent and state the nature of the risk. A person reads it, not a queue.
- What we can do
- Act on what exists, quickly Which is still only the inventory above. Speed does not create records that were never made, and we will not invent a capability under pressure.
- Afterwards
- It is counted and published Emergency disclosures appear in the transparency report as their own line. An exception nobody counts stops being an exception.
- The customer
- Told afterwards, always An emergency justifies acting before telling them. It does not justify never telling them.
For counsel.
Will you comply with a valid court order?
Yes. An order from a court with jurisdiction over the entity served, reviewed by counsel in that jurisdiction and within its own scope, is complied with. We are a hosting business operating lawfully in eight countries, not a jurisdictional novelty, and a page claiming otherwise would be a page written for people who have never been to court.
Will a US subpoena reach an Icelandic or Panamanian entity?
Not on its own. A foreign judgment or order is not self-executing: it has to be recognised by a court in the jurisdiction of the entity before it binds that entity, through mutual legal assistance or the local recognition procedure. That is ordinary private international law and it applies to every foreign company, not only to this one.
Can you identify the person behind an account?
No, and not as a matter of policy — as a matter of what was collected. Sign-up takes an email address and nothing else. No identity document, no legal name, no address, no telephone number, no payment card. A cryptocurrency payment references a transaction the customer chose to make on a public chain, and we add nothing to it that was not already public.
What about IP addresses and access logs?
HTTP access logs are destroyed after 24 hours by a timer, and there is no IP history, session history or record of the addresses a customer signs in from. A request arriving on Thursday about activity on Monday cannot be met by anyone, including us — the data was gone on Tuesday.
Can you image a virtual machine or hand over its disk?
A hypervisor operator can technically copy a guest disk, and an order requiring it would be assessed like any other. What we cannot do is read a disk the customer has encrypted, because we hold no key to it, and we cannot produce contents from the storage tier for the same reason. We do not claim a technical impossibility where the honest answer is a legal one.
Do you issue a preservation hold?
On a valid request, for records that still exist at the moment it arrives. It cannot resurrect logs already destroyed, and we will not begin creating new categories of record because a preservation request asked us to. Preservation preserves; it does not commission.
Has any request ever come with a gag?
No. The figure is zero in every quarter since publication began, and the warrant canary is signed quarterly with a recent Bitcoin block hash so that the claim is falsifiable rather than merely asserted. If that ever changes, the canary stops being renewed — which is the only way the change could be communicated.