Data Request Guidlines

Protecting Your Privacy: PULSENTONE LLC's Data Request Guidelines

At PULSENTONE LLC, safeguarding your privacy and maintaining trust is a top priority. We understand the importance of free expression and respect for our customers. This document outlines the procedures for government agencies, law enforcement, and individuals involved in civil litigation when requesting customer data from PULSENTONE LLC.

Please note that these guidelines are for informational purposes and do not guarantee information provision. PULSENTONE LLC retains the right to respond or object to any Data Request as per applicable laws. These guidelines do not apply to customers requesting their own data; they should contact customer support for such requests at support@pulsentone.com.

Our Commitment to Privacy

In line with our commitment to protecting your privacy:

• Notification: We will, when legally permitted, notify customers or partners of any Data Request related to their data.
• Legal Review: We assess the legality of each Data Request, ensuring that the requesting party has a valid legal right. If inconsistencies or inaccuracies are identified, we will challenge the request within legal bounds.
• Limited Information: We provide the minimum necessary information allowed when responding to a Data Request.
• Reject Improper Requests: Requests that are improperly served, incomplete, overly broad, vague, or unduly burdensome will be rejected.
• Right to Object: PULSENTONE LLC reserves the right to object to Data Requests for any reason.

We may make exceptions in emergency cases where disclosing customer data can prevent imminent harm, and in such cases, we will notify the customer as allowed by law. Emergency requests are also reported in our transparency reports.

Types of Requests

PULSENTONE LLC considers the following types of requests, each requiring formal legal processes:

• Data Request: This pertains to official criminal or administrative investigations, legal proceedings, and civil actions. Examples include subpoenas, court orders, search warrants, and civil investigative demands, which can be from government agencies or private parties.
• Preservation Request: This asks PULSENTONE LLC to preserve customer data during an official investigation or proceeding. Preservation Requests must contain specific details outlined in Section V.
• Emergency Request: These are considered only if accompanied by a valid court order or submitted using the Emergency Data Request Form, primarily in cases of imminent bodily harm or death.
• Expedited Requests: PULSENTONE LLC may process a Data Request more quickly upon request, subject to fees and resource availability, but this is not guaranteed.

Submitting a Data Request

• Service of Process by Government Agencies or Law Enforcement: Government Data Requests should be submitted to subpoenarequest@pulsentone.com, including all required information. PULSENTONE LLC may accept certain legal processes via email but not for requests requiring PULSENTONE LLC representative testimony or appearance.
• Service of Process in Civil Matters: Civil process services should comply with California state or federal court laws.

Information to Include in Data Requests

All Data Requests must include the following details:

Telephone number or user identification number (UID)

A specific date or narrow date range (usually up to 2 months)

PULSENTONE LLC will not respond to Data Requests that infringe on other customers' privacy rights. For instance, requests for information about a specific telephone number may affect multiple users if not narrowly targeted. Depending on the data requested, a protective order may be required.

To verify official agency requests, PULSENTONE LLC requires specific information, including the requesting agency's name, agent's details, official email address, and other relevant information. A copy of the warrant, court order, or legal process is also necessary.

Civil Data Requests: Private litigants must provide the following details:

• Requesting party's name
• Counsel name and State Bar Number
• Contact information
• Requested response date
• A copy of the subpoena

Private litigants are encouraged to seek data directly from the PULSENTONE LLC customer or end user through automated account tools whenever possible.

B.Time for Response: We generally respond to Data Requests within 30 days, with priority given to emergency, law enforcement, and expedited requests.

C.Format of Response: Responsive information is typically provided via email in a compressed, password-protected file. For larger data volumes, download options via a secured PULSENTONE LLC Box account or FTP server may be available.

D.Information Available in Response to Data Requests

Government Requests: PULSENTONE LLC may provide Account Information, Call/Fax/SMS Log Data, or Content of Communications based on the type of valid Government Request. Content of Communications is shared only with customer consent or when legally compelled.

Civil Requests: As a general rule, PULSENTONE LLC cannot provide Content of Communications to private litigants. However, other Account Information or Call/Fax/SMS Logs may be provided in response to properly served Civil Requests.

PULSENTONE LLC may object to requests for Call/Fax/SMS Logs, considering the potential burden involved.

1.Requests from Non-US Authorities

Disclosure of data to non-United States authorities may require a Mutual Legal Assistance Treaty (MLAT), letters rogatory, or similar processes.

Limitations on Data Retention

PULSENTONE LLC takes steps to prevent data deletion or destruction but operates within established retention policies. Typically, data is deleted or de-identified within 30-45 days of account closure, and recovery is impossible once data is deleted.

Notification of Customers

We aim to notify customers about Data Requests unless prohibited by law or a valid nondisclosure order. If we can't notify them, we will work within legal limits to invalidate or waive the nondisclosure obligation and provide as much information as allowed.

Questions/Status Requests

For any questions or status requests regarding these guidelines or pending requests, please contact subpoenarequest@pulsentone.com.

Fees for Cost Reimbursement

To cover the costs of responding to requests, PULSENTONE LLC requires payment of specified fees for all Data Requests, subject to legal constraints. Additional fees may apply to unusual or burdensome requests, as outlined in Section XI.

Please note that all fees are in U.S. Dollars.