Law Enforcement Guidelines

1. Introduction

Online Commerce Hub, LLC DBA SpontiCoupon ("SpontiCoupon," "we," "us," or "our") is committed to protecting the privacy of our users while cooperating with valid legal processes. These guidelines describe the policies and procedures SpontiCoupon follows when responding to requests for user data from law enforcement agencies, government authorities, and other public authorities.

These guidelines are intended for use by law enforcement officials and government agencies. They do not create any rights for third parties, including users or other non-governmental entities.

2. Types of Data We May Hold

SpontiCoupon is a deal marketplace that connects local businesses (vendors) with customers. Depending on the user and their activity on the platform, we may hold the following categories of data:

2.1 Basic Account Information

• Name (first and last)
• Email address
• Account creation date
• Account role (vendor, customer, or admin)
• Last sign-in date and time

2.2 Vendor-Specific Information

• Business name and business address
• Phone number
• Business category
• Deal listing history
• Subscription tier and status

2.3 Customer-Specific Information

• Deal claim and redemption history
• Approximate location data (city-level, based on IP address)

2.4 Transaction Records

• Deal claims and redemption codes
• Timestamps of claims and redemptions
• Subscription payment records (processed by Stripe)

2.5 Technical Data

• IP addresses associated with account access
• Browser and device information (user agent strings)
• Server logs (retained for a limited period)

Important: SpontiCoupon does not process or store credit card numbers, bank account numbers, or other direct payment instrument data. All payment processing is handled by Stripe, Inc. Requests for payment card data should be directed to Stripe.

3. Legal Process Requirements

SpontiCoupon requires valid legal process before disclosing user data to any law enforcement or government agency. The type of legal process required depends on the nature of the data requested:

3.1 Subpoena (Civil or Grand Jury)

A valid subpoena issued in connection with an official investigation may compel the disclosure of basic account information (Section 2.1 above).

3.2 Court Order (18 U.S.C. § 2703(d) or equivalent)

A court order meeting the requirements of 18 U.S.C. § 2703(d) — or an equivalent order issued under state law — may compel disclosure of basic account information plus transaction records, technical data, and other non-content records.

3.3 Search Warrant

A search warrant issued under the procedures described in the Federal Rules of Criminal Procedure (or equivalent state warrant procedures), based on a showing of probable cause, is required for content data or comprehensive account data.

3.4 Emergency Requests

In cases involving imminent danger of death or serious physical injury, SpontiCoupon may voluntarily disclose user data to law enforcement without a court order, consistent with 18 U.S.C. § 2702(b)(8) and (c)(4). Emergency requests must be submitted via the contact information in Section 8 and should include: the nature of the emergency, the identity of the person(s) at risk, the specific data requested, and why the data is necessary to address the emergency.

4. Review of Legality

SpontiCoupon reviews every government and law enforcement data request for legal validity before producing any user data. Our review process includes:

• Facial validity check: We verify that the request is properly issued by an authorized agency, bears proper signatures, and identifies the specific data sought.
• Jurisdictional review: We confirm that the requesting authority has jurisdiction over the matter and that the legal process is appropriate for the type of data requested.
• Scope review: We assess whether the request is appropriately scoped and not overly broad.
• Legal counsel consultation: Requests that raise novel legal questions, seek unusually broad data, or involve sensitive circumstances are referred to legal counsel for review before any disclosure.

We will not produce data in response to requests that do not meet applicable legal standards.

5. Challenging Unlawful Requests

SpontiCoupon is committed to protecting user privacy and will challenge requests that we believe are legally deficient or overly broad. Our provisions include:

• Objection to overbroad requests: If a request seeks data that is not relevant to the stated investigation or is broader than legally permitted, we will object and seek to narrow the scope of the request.
• Motion to quash: Where appropriate, SpontiCoupon may file a motion to quash or modify a subpoena or court order that we believe is legally invalid, overly burdensome, or seeks data beyond what the law permits.
• Notification to affected users: Unless legally prohibited (e.g., by a court-issued non-disclosure order or gag order), we will notify affected users of the request so they may exercise their own legal rights to object.
• Delayed compliance: When we object to a request or seek to have it narrowed, we will not produce data until the legal dispute is resolved, unless compelled by court order.

6. Data Minimization

SpontiCoupon follows strict data minimization principles when responding to legal requests:

• Narrow production: We disclose only the specific data responsive to the valid legal request. We do not provide bulk data, unrelated account information, or data beyond what the request specifically identifies.
• No voluntary over-disclosure: We do not voluntarily provide more data than is legally required, even if we possess additional data that might be of interest to the requesting agency.
• Time-bound responses: Where a request covers a specific time period, we limit our production to records within that timeframe only.
• Redaction: When possible and appropriate, we will redact information about uninvolved third parties from responsive records.
• Platform-level minimization: As a general business practice, SpontiCoupon collects only the data necessary to operate the platform. We do not retain data indefinitely — see our Privacy Policy (Section 6) for our data retention schedule.

7. Documentation & Transparency

SpontiCoupon maintains records of all government and law enforcement data requests. Our documentation practices include:

• Request log: We maintain a log of all requests received, including the requesting agency, date received, type of legal process, data requested, our response, and date of response.
• Outcome tracking: We document whether each request was complied with in full, in part (narrowed), objected to, or withdrawn.
• Annual review: We conduct an annual review of all requests received to identify trends, assess our processes, and improve our policies.
• Transparency reporting: SpontiCoupon reserves the right to publish an annual transparency report summarizing the number and types of government data requests received and our responses, to the extent permitted by law.

8. How to Submit a Request

Law enforcement and government agencies should submit requests to:

All requests must include:

• The name and badge/ID number of the requesting official
• The agency name and a direct contact phone number
• A valid email address from an official government domain
• The legal authority for the request (subpoena, court order, warrant, etc.)
• The specific account(s) or data being requested, identified as precisely as possible (email address, account ID, date range, etc.)

We will acknowledge receipt of the request within 5 business days. Response times depend on the complexity and volume of data requested.

9. Preservation Requests

Law enforcement may request that SpontiCoupon preserve records relating to a specific account pending the issuance of formal legal process, pursuant to 18 U.S.C. § 2703(f). Preservation requests must identify the specific account(s) and the specific data to be preserved. We will preserve the specified records for 90 days, renewable upon request for an additional 90-day period. Preservation does not constitute disclosure — formal legal process is still required to obtain the data.

10. International Requests

SpontiCoupon is a U.S.-based company. International law enforcement agencies must submit requests through a Mutual Legal Assistance Treaty (MLAT) or letters rogatory, unless an applicable international agreement (such as the CLOUD Act) provides an alternative mechanism. We will cooperate with properly authorized international requests to the extent permitted by U.S. law.

11. User Notification

SpontiCoupon will notify affected users of law enforcement requests for their data unless we are legally prohibited from doing so by a valid court order or other applicable law. If notification is initially prohibited, we will notify the user when the prohibition expires.

If you are a user and believe your data has been requested by law enforcement, you have the right to seek legal counsel and challenge the request independently.

12. Updates to These Guidelines

SpontiCoupon may update these guidelines from time to time. The "Last updated" date at the top of this page reflects when these guidelines were most recently revised.

13. Related Policies

• Privacy Policy
• Terms of Service
• DMCA / Copyright Policy