Law Enforcement Guide

This Law Enforcement Guide ("Guide") is for law enforcement agencies and government officials who need information from, or assistance with, PlayHouse (https://playhouse.fans), which is owned and operated by Vallara, Inc. ("Vallara", "we", "us" or "our"), a US company. Please read it before you submit a request. Nothing in this Guide is legal advice, and it does not create any rights for any person. For an overview of how we work with law enforcement, see Assisting Law Enforcement.

Contents

1. How to submit a request
2. What every request must include
3. Identifying the account
4. What information may be available
5. What we cannot provide
6. Requests for records
7. Preservation requests
8. Emergency requests
9. Content removal requests
10. Requests from outside the United States
11. Notice to Users
12. Records certifications
13. Cost reimbursement
14. Format and language
15. No waiver

1. How to submit a request

1.1 Submit every request, including legal process, preservation requests and emergency requests, through our legal request form, and choose "Law enforcement". Then choose the type of request:

• Civil subpoena;
• Civil court order;
• Criminal search warrant or court order;
• Criminal subpoena, judicial authorization or production order;
• Emergency disclosure request;
• Preservation request; or
• Other (including content removal requests).

1.2 Law enforcement requests are handled by a dedicated team with restricted access. Emergency requests are escalated to that team immediately.

1.3 Please submit each request once. Sending the same request more than once, or through several channels, can slow down our response.

1.4 If you have a general question that is not a request for records, preservation, emergency disclosure or removal, you can also use the legal request form.

2. What every request must include

2.1 The form asks for:

• the name of your agency and your name and position;
• an official email address and a telephone number (we may not act on requests sent from personal email accounts);
• your agency's address and location;
• the type of request;
• whether there is a risk of imminent harm to a person;
• a description of your request, including the information you are asking for, the time period it covers and how it relates to your investigation;
• a link to the PlayHouse account or Content concerned; and
• a link to your legal process or supporting documents, for example a secure file-sharing link.

2.2 Please also give any response deadline, and tell us if the request is subject to a non-disclosure order (see section 11).

2.3 We may contact you to confirm that a request is genuine before we act on it.

3. Identifying the account

3.1 Each request must identify the account or accounts concerned with at least one of:

• the username or profile URL (for example, playhouse.fans/username);
• the email address linked to the account; or
• for Creators, the Creator's legal name together with another detail, such as their date of birth or country.

3.2 If you have only payment details, give the date, amount and description of each transaction and the last four digits of the card used. We may be able to match these to an account, but cannot guarantee it.

3.3 Requests must be specific. We cannot process requests that are overly broad or vague, or that do not identify an account.

4. What information may be available

4.1 What we hold depends on the type of account and how it has been used. Our Privacy Policy describes the information we collect and how long we keep it.

4.2 Publicly available information. Some information, such as a username, display name, profile photo, bio and public posts, can be seen by anyone who views the profile. Content behind a subscription or paywall can be seen by subscribers or by Fans who pay to unlock it. We may decline requests for information that is readily available to you in this way, absent special circumstances.

4.3 Non-public information may include, depending on the account:

• for all accounts: the email address linked to the account, account creation date, sign-in records (see 4.4), and records of subscriptions, purchases, tips, wallet top-ups and refunds;
• for Creators: first and last name, date of birth, country, mobile number, the outcome of identity verification, earnings and payout records, and the bank details saved for payouts;
• for Agencies: the Agency account, its team members, the Creators linked to it, and its earnings and payout records; and
• content: posts, stories, media and messages that are stored on PlayHouse.

4.4 Sign-in records. For each sign-in we record the IP address, the approximate location derived from it (city, region, country and approximate coordinates) and the type of device. We remove the IP address and the precise location after 90 days, and keep the country and the time of each sign-in. The account also keeps its most recent sign-in location. If you need IP addresses, send a preservation request promptly (see section 7).

4.5 We collect more information from Creators than from Fans. Fans are not asked for their name or date of birth when they sign up.

5. What we cannot provide

• Card numbers. Card payments are processed by our payment processor, which holds the card details. We do not hold card numbers.
• Identity documents and biometric data. Identity documents, selfies and the face matching and age estimation used in verification are collected and held by our identity verification provider, and are not copied into our systems. We keep the verification results. If you are seeking identity documents, say so expressly in your request, and we will tell you whether and how they can be produced.
• Recordings of livestreams and video calls. We do not record livestreams or video calls.
• Deleted content. Content that a User has deleted, or that was removed when an account was deleted, may no longer be available. Send a preservation request as early as possible (see section 7).

6. Requests for records

6.1 Except in an emergency (see section 8), we disclose non-public information only in response to valid legal process. As a US provider, we are subject to the Electronic Communications Privacy Act, including the Stored Communications Act (18 U.S.C. §§2701–2713). In general:

• Subpoena: a valid subpoena, such as an administrative subpoena or a grand jury or trial subpoena, may be used to obtain basic subscriber information, as described in 18 U.S.C. §2703(c)(2);
• Court order: a court order under 18 U.S.C. §2703(d) is needed for other non-content records, such as activity and transaction records; and
• Search warrant: a search warrant issued under the procedures in the Federal Rules of Criminal Procedure, or equivalent state warrant procedures, upon a showing of probable cause, is needed for the contents of messages and other stored Content.

6.2 Civil matters. The Stored Communications Act does not allow us to disclose the contents of communications in response to a civil subpoena or other civil process. Parties to civil proceedings who need a User's content should ask the User, who can obtain a copy of their own data through our legal request form.

6.3 We review every request for legal sufficiency. We may object to, narrow or decline requests that are overly broad, unclear or not supported by the right legal process, and we may ask you for more information.

7. Preservation requests

7.1 Under 18 U.S.C. §2703(f), a government entity may ask us to preserve records and other evidence in our possession while it obtains legal process. We will preserve the records identified in a valid request for 90 days. On a renewed request, we will extend preservation for one further 90-day period.

7.2 To send a preservation request, choose "Law enforcement" and the request type "Preservation request" on the legal request form. Include:

• the account identifiers (see section 3);
• the records you want preserved and the time period they cover; and
• a short description of the investigation they relate to.

7.3 Send a request to extend preservation as a separate "Preservation request" before the first 90 days end, and refer to your original request.

7.4 Preservation is not disclosure. We will disclose preserved records only when we receive valid legal process for them.

7.5 We preserve material we report to NCMEC's CyberTipline for at least one year after the report, as 18 U.S.C. §2258A requires. If you need it kept for longer, send a preservation request that refers to the CyberTipline report.

8. Emergency requests

8.1 Under 18 U.S.C. §2702(b)(8) and (c)(4), we may disclose information to a government entity without legal process if we believe in good faith that an emergency involving danger of death or serious physical injury to any person requires disclosure without delay. We decide each emergency request on its facts, and we may limit what we disclose to the information needed to prevent the harm.

8.2 To send an emergency request, choose "Law enforcement" and the request type "Emergency disclosure request" on the legal request form, and answer "Yes" to the question about a risk of imminent harm. Emergency requests are escalated immediately and handled ahead of all other requests. Include:

• the nature of the emergency (for example, a threat of suicide, kidnapping, assault or trafficking);
• the identity, if known, of the person at risk;
• why the emergency requires disclosure without delay, and why normal legal process would be too slow;
• the specific information you need and how it would help prevent the harm;
• any relevant posts or messages; and
• the account identifiers (see section 3).

8.3 We cannot treat routine requests as emergencies. If you believe someone is in immediate danger, contact your local emergency services first.

8.4 Where we ourselves become aware of information that gives rise to a suspicion that a criminal offense involving a threat to the life or safety of a person has taken place, is taking place or is likely to take place, we escalate it immediately and promptly inform the relevant law enforcement or judicial authorities, including, for the European Union, the authorities of the Member State concerned as Article 18 of the Digital Services Act requires.

9. Content removal requests

9.1 We may remove Content that is unlawful or breaks our Terms of Service or Acceptable Use Policy. To ask us to remove Content, choose "Law enforcement" and the request type "Other" on the legal request form, and include a link to each item of Content and the legal basis for removal.

9.2 We review each removal request and decide on it case by case. If you also need records relating to the Content, send a preservation request at the same time, because removing Content can affect what remains available.

10. Requests from outside the United States

10.1 Vallara is a US company. US law, including the Stored Communications Act, generally prevents us from disclosing the contents of communications directly to authorities outside the United States.

10.2 Officials outside the United States who need content should use a mutual legal assistance treaty (MLAT) or letters rogatory, or, where one applies, an agreement between their country and the United States under the CLOUD Act. When you submit a request through an MLAT, say so and name the requesting country.

10.3 We may respond to requests from authorities outside the United States for non-content information, preservation or emergency disclosure, where US law allows it and the request is consistent with the law of the requesting country, internationally recognized human rights and our policies.

11. Notice to Users

11.1 We may notify a User before disclosing their information, unless the law, a court order or the circumstances (for example an emergency or child-safety case) prevent it.

11.2 For example, we will not notify a User where a court order issued under 18 U.S.C. §2705(b), or a similar order, prohibits it, and we may decide not to notify a User where the request is an emergency request, where the matter involves the sexual exploitation of a child, or where we believe that notice would create a risk of harm to any person.

11.3 If your request is subject to a non-disclosure order, include a copy of the order or a link to it with your request. A request that only asks us not to notify the User, without a legal basis, may not prevent notice.

12. Records certifications

12.1 On request, we may be able to provide a certification of authenticity for records we produce, such as a certification under Federal Rule of Evidence 902(11) or a foreign business records certification. Include this with your request.

12.2 We do not usually provide witness testimony. A request for testimony requires valid legal process.

13. Cost reimbursement

We may seek reimbursement of the costs of responding to requests where the law allows it, including under 18 U.S.C. §2706. We may waive these costs, for example in cases involving danger to a person or the exploitation of a child.

14. Format and language

14.1 We provide records in an electronic format that can be read with common software, unless we agree otherwise.

14.2 Please submit requests in English, or with an official English translation. Requests in other languages may be delayed.

15. No waiver

Accepting a request through our legal request form is for convenience only. It does not waive any objection Vallara may have, including an objection to lack of jurisdiction or to improper service. Nothing in this Guide creates any obligation on Vallara to any third party.