Law Enforcement Guidelines
1. INTRODUCTION
These Guidelines are intended for law enforcement authorities and competent government authorities (collectively, "Authorities") seeking information from Offline Studio, a French société par actions simplifiée unipersonnelle (SASU) registered under SIREN 106879430, with its registered office at 61 rue de Lyon, 75012 Paris, France ("Offline Studio", "we"), in connection with the Pulp service (the "Service").
2. LEGAL FRAMEWORK
Offline Studio is a French entity subject to the laws of the French Republic and the European Union. Requests for information will be processed in accordance with applicable law, including the French Code de procédure pénale, Regulation (EU) 2016/679 (GDPR), Regulation (EU) 2023/1543 (e-Evidence Regulation), and mutual legal assistance treaties (MLATs) for requests originating from non-EU jurisdictions.
3. HOW TO SUBMIT A REQUEST
All requests must be submitted in writing, on official letterhead, and signed by a duly authorized representative of the requesting Authority.
By email (preferred): contact@pulp-app.io
By post:
Offline Studio
61 rue de Lyon
75012 Paris, France
Requests must include:
- (a) full identification of the requesting Authority (name, function, agency, jurisdiction, contact details);
- (b) the legal basis of the request (specific statutory provisions or judicial order);
- (c) a precise description of the data sought;
- (d) precise identification of the user(s) concerned;
- (e) the timeframe covered by the request;
- (f) any confidentiality obligation applicable to the request.
Requests that do not meet these requirements may be delayed or declined.
4. TYPES OF DATA POTENTIALLY AVAILABLE
Subject to applicable retention periods, Offline Studio may hold: account information (email, registration and last activity dates), profile information (display name, age, photographs, biographical information, declared intentions), technical information (IP addresses, device identifiers, session logs), communications metadata and, subject to applicable law, content, approximate location data, and transaction records.
Payment card details are processed by third party payment processors (including Stripe) and are not stored by Offline Studio.
5. USER NOTIFICATION
Offline Studio's policy is to notify users of requests for their data prior to disclosure, in order to enable the user to challenge the request through appropriate legal channels, unless notification is prohibited by law, court order, or would create a risk of harm to any person, or would prejudice an ongoing investigation.
6. EMERGENCY DISCLOSURE REQUESTS
In cases involving an imminent risk of death or serious physical injury, Offline Studio may voluntarily disclose data to Authorities without prior legal process, in accordance with Article 6(1)(d) of the GDPR.
Emergency requests must be submitted to contact@pulp-app.io with the subject line "EMERGENCY DISCLOSURE REQUEST" and must include the identity of the requesting officer, the nature and imminence of the risk, the users concerned, and the specific data required.
Offline Studio reserves the right to verify the authenticity and urgency of any emergency request before responding.
7. CROSS-BORDER REQUESTS
Requests from Authorities outside the European Union must be transmitted through Mutual Legal Assistance Treaties (MLATs) or equivalent international judicial cooperation mechanisms, unless the request falls within the scope of the EU e-Evidence Regulation.
8. RESPONSE TIME
Offline Studio will use reasonable efforts to respond to lawful requests in a timely manner. Response times vary depending on the complexity and volume of the request. Emergency requests are handled with priority.
9. CONTACT
For any question regarding these Guidelines, Authorities may contact Offline Studio at contact@pulp-app.io.
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End of the Law Enforcement Guidelines.