Data Request Policy

• Privacy Notice. Please see VPSLink's Privacy Notice for further information on what type of information VPSLink collects, how it is used and when it may be disclosed. Subject to VPSLink's Privacy Notice, this Data Request Policy describes the types of requests for data that VPSLink may receive and how VPSLink may respond to such requests.
• Types of Requests. VPSLink receives the following types of requests concerning Subscriber data:
  • Data Requests. A data request is a request for information or documents relating to Subscriber accounts in connection with official criminal investigations or other official legal proceedings. Except in limited emergency situations (see below), VPSLink requires data requests to be made through formal U.S. legal process and procedures, and we respond to such requests as required by law. Examples of data requests include:
    • Subpoenas
    • Court Orders
    • Search Warrants
    • Legal process received from outside the United States may require a Mutual Legal Assistance Treaty (MLAT) with the United States
    • Other forms of legal process such as Civil Investigative Demands
  • Preservation Requests. A preservation request asks VPSLink to preserve Subscriber account records in connection with official criminal investigations or other official legal proceedings. Preservation requests must include the following information:
    • Identification of the account(s) at issue (as further described in Section 4 below);
    • Identification of the investigating agency and/or specific pending official proceedings (requests must be signed on law enforcement letterhead);
    • Assurances that the requesting agency or individual is taking steps to obtain appropriate legal process for access to the data that VPSLink is being asked to retain; and
    • A valid return email address and phone number.
  • Emergency Requests. An emergency request is only appropriate in cases involving imminent serious bodily harm or death. We respond to emergency requests when we believe in good faith that such harm may occur if we do not respond without delay.
• Notice to VPSLink Subscribers. VPSLink's policy is to notify its Subscribers of requests for their data unless VPSLink is prohibited from doing so by statute or court order.
• Information to Include in a Request. The following information must be included in a request for Subscriber data:
  • First and last name of the customer and email address associated with the account; and
  • Domain name and/or IP address associated with the account.

  VPSLink may not be able to respond to a request without this information.

  Additionally, VPSLink reserves the right to request a copy of the complaint and any supporting documentation that demonstrates how the information requested is related to the pending litigation and the underlying subpoena.

• Sending a Request to VPSLink. VPSLink is located in Burlington, Massachusetts and all Requests should be sent to that location or mailed or faxed to:

  VPSLink
  Legal Department
  10 Corporate Dr.
  Suite 300
  Burlington, MA 01803

  Phone: (602) 716-5396 (M-F 7am - 3:30pm MST)
  Fax: (781) 998-8277
  E-mail: legal@vpslink-inc.com

  IMPORTANT NOTE: IN THE EVENT YOU SEND US A NOTICE OF ANY KIND VIA EMAIL AND DO NOT RECEIVE A RESPONSE FROM US, PLEASE SUBMIT A DUPLICATE COPY VIA PAPER AND/OR FAX (FAX # 781-998-8277). DUE TO THE VAGARIES OF THE INTERNET AND EMAIL COMMUNICATION IN PARTICULAR, INCLUDING WITHOUT LIMITATION THE BURDENS OF SPAM AND THE OCCASIONAL UNINTENDED EFFECTS OF SPAM FILTERS, SENDING AN ALTERNATE FORM OF NOTICE, WILL HELP ASSURE THAT YOUR NOTICE IS RECEIVED BY US AND ACTED ON IN A TIMELY MANNER.

• Fees. VPSLink may seek reimbursement for costs in responding to requests as provided by law and may charge additional fees for costs in responding to unusual or burdensome requests.
• Available Information. Depending on the type of formal legal process provided, VPSLink may be able to respond with one or more of the following types of data:
  • Non-Content. VPSLink will produce non-content information such as basic Subscriber information which may include the following subject to a valid request:
    • Name
    • Email addresses
    • Date and time of account creation
    • Billing information
    • IP Logs
  • Content. VPSLink will only produce Subscriber content (such as website files and email content) pursuant to a valid search warrant from an entity with proper jurisdiction.

This file was last modified on September 24, 2020.