Government Requests Transparency Report

Overview

We are pleased to offer our transparency report for January 1, 2023, through June 30, 2023. This report provides insight into how Snap V1 Video Communications, Inc. ( Snap V1) responds to requests for user data from law enforcement agencies and government authorities globally. At Snap V1, transparency is critical to building trust and fostering the free and open exchange of ideas.

As detailed in Snap V1’s Privacy Statement and in line with our commitment to user privacy, user data is only provided to governments in response to valid and lawful requests that adhere to our Government Requests Guide.

Snap V1 employs a three-pronged approach to handling government requests: (1) our Government Requests Guide outlines requirements for law enforcement agencies and government authorities to submit a compliant and tailored request; (2) all government and law enforcement requests are submitted and responded to through our newly developed Law Enforcement Response System – LERS; and (3) our Law Enforcement Response Team efficiently evaluates and processes each request.

On the back end, we have a centralized system for tracking requests, and we categorize the data associated with each request in our case management system. With the help of our policy team, we have also developed internal guidelines and quality control processes that govern our work. All of these features were built with an eye toward transparent reporting.

This updated transparency report adheres to relevant legal requirements and provides a summary of the requests we have processed from January 1, 2023, through June 30, 2023, as well as information on our responses.

Definitions

We use several terms in this report that have specific legal meanings in this context. The absence of a particular kind of request or outcome from the charts means that there weren’t any of that type in this period. Civil litigation requests are not reflected in this report.

  • Account Location – the location of the target account based on billing address or registration IP address if the billing address is unavailable.
  • Account Type
    • Basic: Accounts that are subscribed to our plans that are free of charge.
    • Business: Accounts subscribed to our Business plans.
    • Education: Accounts used by students, faculty, staff, and alumni for pedagogical interaction within a classroom environment or the administration thereof.
    • Enterprise: Accounts subscribed to our Enterprise plan.
    • No Account: The target user does not have any account with Snap V1.
    • Pro: Accounts subscribed to our Pro plan.
    • Snap V1 Phone: Accounts subscribed to our Snap V1 Phone plans.
  • CLOUD Act Request – a request made under the CLOUD Act. Requests made pursuant to the CLOUD Act can demand content
  • Content – can include video content, chat logs, transcripts, meeting titles, or profile pictures; essentially, any media that depicts what a person said, wrote, or did. When we report disclosing “content,” that means we disclosed both content and non-content.
  • Delayed-notice order (U.S. only) – an order signed by a judge preventing Snap V1 from notifying one or more users of a government request for their information for a specified period.
  • Emergency Request (U.S. or international) – a request for user data without standard legal process because there is a danger of death or serious physical injury to a person.
  • General information – means we provided general information about the law enforcement request process but not content or non-content.
  • Letters Rogatory – requests from courts in one country to the courts of another country requesting the performance of an act.
  • MLAT Request (International only) – a request made by a foreign country through the U.S. Department of Justice under a Mutual Legal Assistance Treaty. Requests made pursuant to MLATs can demand content.
  • Non-content – metadata or information about content. Non-content can include things like the dates and times of meetings, the IP address of a user, or information about their platform. When we report disclosing “non-content,” that means we disclosed non-content only.
  • Order (U.S. only) – any other type of order issued by a court. Orders cannot demand content.
  • Other – any other kind of request or resolution. For example, if a law enforcement officer seeks user data without a subpoena, search warrant, or court order, or where the data owner gives written authorization to disclose their data to law enforcement.
  • Preservation Request (U.S. or international) – a request to preserve (but not disclose) user information for a period of time, usually 90 or 180 days.
  • Rejected – includes rejections for invalid service or legal invalidity, instances where there was no responsive data or instances where the agency did not provide enough information for us to locate the requested data.
  • Search Warrant (U.S. only) – a request for a search, signed by a judge, in which a prosecutor alleges that there is “probable cause” to believe that a crime has occurred or is about to occur. Requests made pursuant to search warrants may demand content or non-content.
  • Subpoena (U.S. only) – a request made by a government entity with investigative powers, such as a grand jury. Requests made pursuant to subpoenas need not be signed by a judge and cannot demand content.
  • U.S. National Security Requests – requests made under the Foreign Intelligence Surveillance Act (FISA) for non-content or content, or National Security Letters (NSLs) for non-content.
  • Withdrawn – means that the requester withdrew the request before we made a determination on it.
  • Withhold Access Request – a government request to restrict an individual’s access to any aspect of Snap V1's product or to prevent or terminate a particular meeting.

A note about Account Location and Type: We disclose account location and type solely when fulfilling a government request. Therefore, the account location and type reflected in the report correspond to the completed requests within the reporting period.

A note about Withhold Access Requests: Many countries have laws that may restrict their residents from participating in or hosting particular Snap V1 Meetings or Webinars. If Snap V1 receives a legally valid and appropriately scoped request from a legitimate government agency demanding that Snap V1 restrict one of its residents from using Snap V1, we will carefully review it.

In no event will Snap V1 restrict users’ access to the platform who are outside the requesting country and/or the jurisdiction of the requesting government agency or who are otherwise not subject to applicable local law. If the meeting is hosted outside the requesting jurisdiction, we can employ a geoblock to restrict the access of a jurisdiction’s users from a particular meeting based on geography. This means that we can comply with valid requests from local authorities while protecting access to the meeting in question for participants outside those borders.

We comply with Withhold Access Requests selectively, as we balance our commitment to promoting the free and open exchange of ideas against our legal obligations.