Law Enforcement Guidelines

These guidelines describe how August (Credicle Corporation) responds to legal requests for customer information from law enforcement agencies.

1. INITIAL CONTACT PROTOCOL

1.1 August will direct law enforcement requestors to contact customers directly to obtain relevant data whenever possible and legally permissible.

1.2 We prioritize customer notification and transparency in all law enforcement interactions.

1.3 August does not voluntarily provide Customer Data or Content to government agencies except as required by law.

2. CUSTOMER NOTIFICATION

2.1 August commits to informing customers about law enforcement requests for their data unless legally prohibited from doing so.

2.2 When notification restrictions exist (such as court-ordered gag orders), August will:

• Request a waiver of the prohibition

• Document that request in writing

• Notify the customer as soon as the restriction expires

2.3 August will provide customers with as much information as legally permitted about the nature and scope of the request.

3. DATA DISCLOSURE STANDARDS

3.1 August only discloses information when required to do so in compliance with valid legal process.

3.2 Our legal team carefully reviews the legality, scope, and validity of each request before any disclosure, including:

• Verification that the request is properly issued by a competent authority

• Assessment of whether the request complies with applicable laws

• Evaluation of any applicable legal privileges or protections

3.3 August may object to requests that are overly broad, burdensome, or legally deficient.

4. INTERNATIONAL REQUESTS

4.1 For non-U.S. government agencies, August limits responses to established legal mechanisms, including:

• Mutual Legal Assistance Treaty (MLAT) requests

• Letters rogatory

• Requests by qualifying foreign governments as defined by the CLOUD Act

• Other internationally recognized legal cooperation frameworks

4.2 August will not respond to informal requests from foreign governments that do not follow proper legal channels.

4.3 For requests implicating data of EU residents, August will consider GDPR requirements and may challenge requests that conflict with EU data protection law.

5. CHALLENGE AND MINIMIZATION

5.1 When challenging requests, August seeks interim measures to suspend the effects of the request until it has been decided on its merits by a competent court or authority.

5.2 August applies data minimization principles and discloses only the minimum necessary information required by valid legal process.

5.3 August maintains records of law enforcement requests received and our responses, subject to applicable legal restrictions on disclosure of such records.

Last updated: January 2026