ABOUT OUR TRANSPARENCY REPORT
Brightidea, like many technology companies, may receive requests from law enforcement agencies in the United States and elsewhere, seeking subscriber information. Such requests may take the form of a subpoena, court order, search warrant, or National Security Process Letter. Brightidea must comply with valid governmental requests for personal information.
At the same time, Brightidea cares deeply about maintaining our subscribers’ trust. One way it does so is to inform Brightidea subscribers and the public about governmental requests to which it responds. To do so, we have prepared this Transparency Report.
This Transparency Report provides information relating to law enforcement requests for subscriber information that we received during the first half of 2024 (from January 1, 2024, through June 30, 2024). Brightidea will provide updated reports approximately every six months for the prior six-month period.
For more information regarding Brightidea’s approach to responding to requests for information from law enforcement and other government agencies, please see our Government Data Request Policy.
REPORT
Requests from United States Law Enforcement and Governmental Entities
Type of Request | Number of Requests | Content Data Disclosed | Non-Content Data Disclosed |
Subpoena | 0 | 0 | 0 |
Court Order | 0 | 0 | 0 |
Search Warrant | 0 | 0 | 0 |
Emergency Requests | 0 | 0 | 0 |
National Security Process
Under United States law, 50 U.S.C. § 1874, Brightidea is prohibited from providing certain details regarding requests issued under FISA or 18 U.S.C. § 2709 (National Security Letters or NSLs). Brightidea may only report the aggregate number of NSLs it receives in statutorily-specified bands, subject to a six-month delay. The following table provides information regarding national security process received by Brightidea in bands as permitted by the law subject to a six-month delay in reporting.
Reporting Period | Number of Requests | Number of Data Disclosures |
2022 - First Half | 0 | 0 |
2022 - Second Half | 0 | 0 |
2023 - First Half | 0 | 0 |
2023 - Second Half | 0 | 0 |
2024 - First Half | 0 | 0 |
Requests from Non-U.S. Law Enforcement and Governmental Entities
Although Brightidea is located in the United States, we may receive requests from non-U.S. governments. When we receive requests from non-U.S. governments, we work with U.S. and non-U.S. counsel to determine the validity of the request and our obligation to respond under United States and other applicable laws.
Type of Request | Number of Requests | Number of Data Disclosures |
Informal Requests | 0 | 0 |
Non-U.S. Governmental Requests Pursuant to an MLAT | 0 | 0 |
Definitions
- Content Data: Includes the contents of End-Users’ communications with an Account. Content data is generally considered Subscriber Data as defined in Brightidea’s Master Subscription Agreement.
- Non-Content Data: All data that is not Content Data. It can include Account Information as defined in Brightidea’s Privacy Notice (such as Account Owner name and contact information, Account billing information, length of Service, types of Services utilized, and account login information). This type of information is also called “Basic Subscriber Information” and must be produced in response to a valid government subpoena. Additionally, in response to a court order, Brightidea may also have to produce Non-Content metadata related to End-Users’ communications with an Account.
- Subpoena: A compulsory legal demand for the production of documents.
- Court Order: An order issued by a judge upon a finding that there are reasonable grounds to believe that the information sought is relevant and material to an ongoing criminal investigation.
- Search Warrant: An order issued by a court at the formal request of law enforcement and upon a finding of probable cause. A search warrant is required to obtain Content Data.
- MLAT: Stands for “mutual legal assistance treaty.” Brightidea requires that non-U.S. government entities use appropriate international legal process to obtain data processed by Brightidea on behalf of a subscriber.
- National Security Letters: A national security letter issued under 18 U.S.C. § 2709.
- FISA Orders: An order or request issued under the Foreign Intelligence Surveillance Act (50 U.S.C. § 1801, et seq.) for user information issued in the U.S.
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