This Law Enforcement Guide ("Guide") is made available for review by law enforcement agencies and officials to assist with their discharge of law enforcement functions and investigations. ReelFans cooperates with law enforcement efforts globally. Nothing included herein is intended as legal advice. Please review this Guide before submitting a law enforcement request to ReelFans.
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General Inquiries
General inquiries from law enforcement, military, or government officials (not requesting deletion, preservation, or disclosure of account information/content) can be submitted through our Contact Form. All other official requests should be sent through our Law Enforcement Request Form in accordance with the instructions below.
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Content Removal Requests
On a case-by-case basis in our sole and absolute discretion, we may process a law enforcement request to remove content that is illegal or otherwise violates our Terms of Service. All law enforcement requests to remove content must be submitted through our Law Enforcement Request Form using a valid official return email address, the name and position of the requesting official, a link to the content sought to be removed, and the legal basis for removal. Such requests will be forwarded to our content removal and legal teams for evaluation and response.
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Available Account Information
Our data collection, protection, and retention policies are described in our Privacy Policy. The type and scope of information collected, manner of collection, and length of retention varies depending on a variety of factors, including the type of account and the user’s activities.
For example, Fans are not required to provide the same level of account registration data as Creators, and Creators are subjected to robust age and identity verification procedures. Some users may have live broadcasting capabilities. We do not store, or only briefly store, live broadcasts.
Certain stored profile content is readily accessible to law enforcement by viewing and/or subscribing to the user’s profile. This information may include the user’s username, display name, profile photo, profile bio, profile URL, subscription offers, tip requests, and posts, which may include text, photos, videos, and/or comments.
Additional non-public account information may be available to law enforcement upon receipt of formal legal process. Depending on the jurisdiction of origin and the records sought, this legal process may take the form of a subpoena, production order, judicial authorization, search warrant, or court order. Available non-public account information may include the user’s registration information (such as the email address associated with the account), identification documents, tax forms, linked social media accounts, billing and revenue information, subscribers, private messages, and captured user activity which may include IP address logs and other data.
Importantly, users control all stored profile content and private messages, so profile content and private messages may be unavailable if they are deleted by the user, prior to our processing of a valid law enforcement request. Some profile content cannot be preserved in real time without suspending an account. Account suspension is in the sole discretion of ReelFans.
Please note that ReelFans is located and operated in the United Kingdom. All user data is therefore located in the United Kingdom. We do not maintain offices or addresses in other countries.
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Preservation Requests
In appropriate legal circumstances, ReelFans accepts temporary, informal preservation requests from law enforcement if the records are relevant evidence in a legal proceeding or investigation. All preservation requests must be submitted through our Law Enforcement Request Form using a valid official return email address, the name and position of the requesting official, the preservation period, a description of the information to be preserved, and its relation to your investigation, along with at least one of the following user identifiers:
- Username
- Profile URL
- Email address
- Legal name
- Telephone number
- Billing address
- Credit card information (must include first six and last four numbers of the credit card, dates and times of suspected transactions, and the legal name of the account holder)
We cannot process overly broad, vague, or untimely preservation requests. For any preservation request exceeding a ninety (90) day preservation period, we may require formal legal process. In appropriate circumstances we may agree to extend the preservation period upon request from a law enforcement agency. Any request to extend the preservation period should be submitted as a separate request.
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Requests for Non-Public Account Information
Requests for non-public account information from law enforcement will not be granted except in response to appropriate legal process such as a subpoena, production order, judicial authorization, search warrant, court order, other valid legal process, or in response to a valid emergency request, as described below. The type of legal process required depends on the categories of user data requested, and applicable law. While law enforcement requests may be addressed to Fenix International Limited, 9th Floor, 107 Cheapside, London, EC2V 6DN, all requests for account information and questions about legal process should be submitted through our Law Enforcement Request Form using a valid official return email address, the name and position of the requesting official, the response deadline, a description of the information to be disclosed and its relation to your investigation, and at least one of the following user identifiers:
- Username
- Profile URL
- Email address
- Legal name
- Telephone number
- Billing address
- Credit card information (must include first six and last four numbers of the credit card, dates and times of suspected transactions, and the legal name of the account holder)
We cannot process overly broad or vague requests for non-public account information. Further, we may refuse requests that seek only stored profile content that is readily accessible to law enforcement by viewing and/or subscribing to the user’s profile, absent special circumstances.
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Emergency Requests
In certain emergency situations determined by us on a case-by-case basis in our sole and absolute discretion, we may grant a law enforcement request for non-public account information without formal legal process if we are provided with a good faith basis to conclude that there is an imminent threat of death or serious physical injury to a person. Responses may be limited to any information necessary to prevent that harm. All emergency requests must be submitted through our Law Enforcement Request Form using a valid official return email address, the name and position of the requesting official, the response deadline, the nature of the emergency (e.g., assault, kidnapping, trafficking, etc.), the identity of the person who is in danger of death or serious bodily harm, a description of the harm to be avoided, a description of the information to be disclosed and a how that information is necessary to avoid harm, any pertinent posts or messages, and at least one of the following user identifiers:
- Username
- Profile URL
- Email address
- Legal name
- Telephone number
- Billing address
- Credit card information (must include first six and last four numbers of the credit card, dates and times of suspected transactions, and the legal name of the account holder)
We cannot process overly broad, vague, or routine inquiries as emergency requests.
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Cost Reimbursement
ReelFans may seek reimbursement for costs associated with all preservation and information requests as permitted by law.
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Responses
We will process all routine requests within seven (7) business days from receipt. However, response times may be affected by the nature of the request and the current volume of requests. Please refrain from submitting multiple follow-ups, as this may delay the overall response time.
We only provide responsive records in electronic format that may be viewed using typical office software, unless otherwise agreed to by us.
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Records Affidavits and Certifications
An appropriate records custodian affidavit or foreign business records certification will be made available, depending on your specific jurisdiction. If such an affidavit or certification is sought, please include the request with your legal process.
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Disclosure of Requests
ReelFans does not disclose law enforcement requests to users.
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Mutual legal assistance treaties
Our policy is to promptly respond to requests that are issued via a mutual legal assistance treaty ("MLAT") or letters rogatory, upon proper service of process. When submitting requests through an MLAT procedure, please make clear that the request is coming by way of MLAT and include the name of the originating country. In most circumstances, a MLAT is not required to process a law enforcement request.
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English Language
All law enforcement requests should be in English or accompanied by an official English translation. Requests submitted in foreign languages or using foreign characters may be delayed or refused, in our discretion.
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No Waiver
Transmission and receipt of correspondence as described above is for convenience purposes only and does not waive any objections, including the lack of personal jurisdiction or defective service of process. Law enforcement agencies that do not submit legal requests through our Law Enforcement Request Form should anticipate longer response times.