Law Enforcement Disclosure Policy

Last Updated: March 29, 2026
Effective Date: March 29, 2026
Applies To: Jyv Tech LLC, Delaware File Number 10316295, Los Angeles, CA 90012 (global entity) / Tanta Innovative Limited, CAC RC 1475301, Lagos, Nigeria (subsidiary)
Product: Chipon Alert — Preventive Safety Intelligence Platform

1. Purpose

Chipon Alert is committed to protecting user privacy while supporting lawful law enforcement objectives. This policy outlines how we handle requests for user data from law enforcement agencies, government authorities, and judicial bodies in Nigeria and internationally.

We believe that user trust is fundamental to our mission of building a community-sourced safety platform. We disclose user data only in response to lawful legal process and remain transparent about our practices.

2. Guiding Principles

Our approach to law enforcement requests is guided by four core principles:

1. Transparency — We disclose the fact and substance of legal requests to users whenever legally permissible, and we publish aggregate transparency reports on request volume and outcomes.

2. Legal Process Required — We require valid legal process (court orders, subpoenas, or emergency exceptions) before disclosing user data. Informal requests are declined.

3. Narrow Scope — We limit disclosures to the specific data and time period requested. We do not provide blanket access, bulk data exports, or information beyond what is legally required.

4. User Notification — We notify affected users of law enforcement requests unless legally prohibited by gag order, imminent danger exception, or explicit law.

3. Types of Requests We Accept

3.1 Court Orders

Nigerian Courts: Valid court orders issued by Nigerian state or federal courts pursuant to the Evidence Act 2011, Nigerian Cybercrimes Act 2015, or applicable criminal procedure law are accepted.

Requirements:

• Order must be signed by a competent judge or magistrate
• Order must specify the data requested, time period, and legal basis
• Order must be served on Chipon Alert through official channels (email to lawenforcement@chiponalert.com or registered legal counsel)

3.2 Subpoenas and Legal Process

Nigerian Subpoenas: Valid subpoenas issued by competent judicial, prosecutorial, or legislative authorities in Nigeria.

Requirements:

• Issued by authorized officer (judge, magistrate, attorney general, investigator with judicial authorization)
• Specific identification of user(s) and data sought
• Clear statement of legal basis (criminal investigation, civil proceeding, legislative inquiry)
• Reasonable timeframe for compliance (minimum 14 days)

3.3 Emergency Requests

Imminent Threat to Life: We expedite requests demonstrating an immediate and credible threat to human life or physical safety.

Criteria:

• Reasonable belief that death or serious physical injury is imminent
• Request must be made by sworn law enforcement officer
• Specific threat and victim identification required
• Expedited review within 24 hours by our legal team
• Minimum data disclosure necessary to address the emergency

Examples of Qualifying Emergencies:

• Active kidnapping or missing person with credible ransom/harm threat
• Active shooting or armed attack with named target
• Suicide prevention with imminent risk
• Child exploitation with immediate danger

3.4 Mutual Legal Assistance Treaty (MLAT) Requests

International Requests: Requests from foreign governments must be processed through Nigeria's MLAT procedures or the mutual legal assistance framework under Nigerian law.

Requirements:

• Request channeled through Nigerian Attorney General's Office
• Compliance with MLAT procedures and timeframes
• Legal basis must be equivalent to Nigerian law requirements
• Proper certification by requesting country's legal authority

4. What We Require

We will not process law enforcement requests that do not meet ALL of the following criteria:

1. Valid Legal Process — Genuine court order, subpoena, or properly documented emergency request from identified law enforcement officer (badge/ID verification available upon request).

2. Specificity — Request must identify:

   • Specific user(s) by phone number, account ID, or sufficient identifying information
   • Specific data category and time period (no blanket "all data" requests)
   • Legal basis and investigation/proceeding description
   • Responsible officer/agency name and contact information

3. Proper Jurisdiction — Request must originate from:

   • Nigerian federal or state law enforcement / judicial authority, OR
   • Legitimate MLAT/international legal assistance process

4. Official Channels Only — Request must be submitted:

   • Via email to lawenforcement@chiponalert.com, OR
   • Through registered legal counsel, OR
   • In-person to our Lagos offices with proper identification

5. No Blanket Requests — We decline requests for:

   • All users in a geographic area
   • All incidents in a time period without user identification
   • All search history or location data without temporal/user specificity
   • Backdoor access or system penetration

5. What We Can Disclose

With valid legal process, we may disclose the following categories of user data:

5.1 Account Information

• Phone number (primary account identifier)
• Display name / user profile name
• Account creation date and last login
• Device information (type, OS version, app version)
• IP address history and approximate geographic location
• Authentication method (OTP verification status)

5.2 Incident Report Data

• Incident text description / narrative
• Incident category (armed robbery, accident, protest, etc.)
• Incident severity classification
• Incident GPS coordinates and address
• Incident photos / media (if user-uploaded)
• Incident timestamp
• User-provided additional details
• Community verification status and count

5.3 Location and Routing Data

• Route searches (origin, destination, timestamp)
• Route selection history
• Map view history and areas searched
• GPS coordinates of searches
• NOT real-time location tracking (we do not track users in real-time)

5.4 Device and Access Logs

• IP address and connection logs
• Device identifiers (IDFA, Android ID)
• App version and session timestamps
• Approximate geolocation from IP
• Device type and OS information

5.5 Communication Records

• In-app notification delivery logs
• Push notification timestamps
• Report submission metadata

6. What We Cannot Disclose

The following data does not exist in our systems or is not disclosed under any circumstances:

6.1 Authentication Credentials

• We do not store passwords (authentication is OTP-only via SMS/phone verification)
• We do not store OTP codes after verification
• We do not have access to SMS messages or telecom carrier logs

6.2 Real-Time Location Tracking

• Chipon Alert does not track user location in real-time
• We do not maintain continuous GPS logs of user movement
• We do not have persistent location trails
• Location data is limited to incident report coordinates and search history

6.3 Encrypted or Private Content

• We do not store encrypted messages (we do not have a messaging feature)
• We do not have encrypted user notes or private data
• All user-submitted data is stored in plaintext for community safety purposes

6.4 Third-Party Integrations

• We do not have access to phone contacts, call logs, or SMS history
• We do not integrate with telecom providers or government databases
• We do not have access to financial data or payment information

7. User Notification

Principle: We notify users of law enforcement requests unless legally prohibited.

7.1 Standard Practice

We notify the affected user(s) after disclosing data unless we receive simultaneous notice that notification is prohibited.

Notification includes:

• Fact that a legal request was received
• Nature of request (type of order/process)
• Approximate time period of data requested
• Whether data was disclosed and what categories
• User's legal rights and avenues for challenge

Timing: Notification sent within 5 business days of disclosure, except where prohibited.

7.2 Notification Exceptions

We do not notify users if:

1. Gag Order — Explicit judicial order prohibits disclosure of the legal request itself
2. Imminent Danger Exception — Emergency disclosure to prevent death or serious injury (notification deferred pending legal review; user notified when restrictions lifted)
3. Law Enforcement Certification — Law enforcement submits written certification that notification would obstruct an active criminal investigation (maximum 60 days; renewable once for total 120 days)

7.3 Gag Order Process

If a gag order is lifted or expires, we re-engage our notification obligation for that request.

8. Emergency Requests

Expedited Process for Imminent Threat to Life

8.1 Activation

Emergency requests must be submitted via:

• Emergency Phone: +234 (1) 711-2000 ext. 7 (during business hours)
• Emergency Email: emergencies@chiponalert.com (monitored 24/7)
• Include "EMERGENCY" in subject line

8.2 Review Process

1. Law enforcement officer calls/emails with badge identification and threat details
2. Our legal team conducts good-faith review within 2 hours (best effort)
3. If approved: Data disclosed immediately; formal legal process requested retroactively within 5 days
4. If declined: Written explanation provided within 24 hours
5. Officer may escalate to our General Counsel if disagreement

8.3 Scope Limitations

Emergency disclosure is limited to:

• Data directly relevant to immediate threat
• Minimum necessary to protect the endangered person
• Typically: account status, incident reports from past 30 days, route searches related to threat

8.4 Retroactive Legal Process

If emergency data is disclosed, we require valid legal process (court order or subpoena) within 5 business days for the disclosure to remain valid. Failure to obtain retroactive process may result in deletion of disclosed data from law enforcement records (if enforceable).

9. Data Preservation Requests

9.1 Preservation Notice

Law enforcement may request that we preserve user data pending formal legal process.

Requirements:

• Submitted in writing to lawenforcement@chiponalert.com
• Specific user identification
• Clear legal basis (criminal investigation, active proceeding)
• Officer name, badge, and agency

9.2 Preservation Period

• Initial: 90 days from receipt of valid preservation notice
• Renewal: One additional 90-day renewal available upon renewed written request
• Maximum: 180 days of preservation without formal legal process

9.3 Beyond Preservation Limit

If formal legal process (court order/subpoena) is not received within 180 days, data will be deleted per our standard retention policies, unless:

• Legal process is pending or reasonably anticipated, OR
• User has requested data deletion (preservation lifted)

9.4 Notification of Preservation

Users are not notified of preservation requests during the preservation period. Users will be notified if:

• Legal process is served and data disclosed, OR
• Preservation period expires without legal process

10. Request Submission Process

10.1 Law Enforcement Contact Information

All law enforcement requests must be submitted to:

Email (Standard Requests): lawenforcement@chipon.io
Email (Emergency Requests): lawenforcement@chipon.io (24/7 monitoring)
Mailing Address:

Tanta Innovative Limited
Law Enforcement Requests
25 Segun Gbelee Street
Ikeja, Lagos, Nigeria

10.2 Required Information

All law enforcement requests must include:

1. Requesting Authority

   • Name and title of requesting officer
   • Badge/ID number
   • Agency name and jurisdiction
   • Contact phone and email

2. Legal Basis

   • Type of legal process (court order, subpoena, emergency, preservation)
   • Case/investigation number (if applicable)
   • Applicable statute or law
   • Date of legal authorization

3. Data Requested

   • Specific user identifier (phone number, account ID, or name with date of birth)
   • Data categories sought (account info, incident reports, location data, etc.)
   • Time period (specific dates, or "all available" if justified)
   • Purpose (brief description of investigation/proceeding)

4. Certification

   • Signature of requesting officer or authorized prosecutor
   • Certification of legal authority to make the request
   • Confirmation that information is needed for lawful purpose

10.3 Processing Timeline

10.4 Submission Process Details

Standard Requests:

• Email: lawenforcement@chipon.io
• Attach: Scanned copy of court order, subpoena, or legal authorization
• Allow: 14-21 days for processing

Emergency Requests:

• Email: lawenforcement@chipon.io (mark subject line "EMERGENCY - URGENT")
• Target: 2-hour review; data disclosed within 24 hours if approved

In-Person Delivery:

• Tanta Innovative Limited, Legal Department, Lagos (by appointment)
• Original court documents or certified copies accepted
• Officer must present valid ID

10.5 Compliance Confirmation

Upon disclosure, law enforcement receives:

• Written confirmation that data was/was not located
• Summary of data disclosed (categories and record count)
• Timeline of data preservation (if applicable)
• Notification status (user will/will not be notified; reason if prohibited)

11. Transparency Reports

11.1 Commitment

We commit to publishing semi-annual transparency reports detailing law enforcement requests and our response.

11.2 Report Contents (by country and request type)

• Total Requests Received — Count by country/jurisdiction
• Requests by Type
  • Court orders
  • Subpoenas
  • Emergency requests
  • Preservation notices
  • Renewal/modifications
• Requests by Data Category — Account info, incident reports, location data, device info
• Outcomes
  • Fully complied
  • Partially complied (scope narrowed)
  • Denied (reason: insufficient legal process, jurisdictional objection, etc.)
  • No data found
• User Notification — Number of users notified; number of notifications prohibited (without disclosing reason if gag order applies)
• Average Response Time — By request type

11.3 Aggregation and Privacy

• Reports aggregated by country; no individual cases identified
• No officer or agency names disclosed
• No case numbers or investigation details disclosed
• Published on website and reported to international transparency database

11.4 Inaugural Report

First transparency report scheduled for September 30, 2026, covering January 1 — June 30, 2026.

12. Nigerian Law References

This policy operates under and respects the following Nigerian laws:

12.1 Data Protection & Privacy

• Nigerian Data Protection Regulation (NDPR) 2019 — Rules user rights to personal data, legitimate processing, and law enforcement exceptions
• National Data Protection Bill (NDP Bill) 2024 — Pending; establishes data protection authority and law enforcement procedures

12.2 Criminal Law & Evidence

• Evidence Act, 2011 — Governs discovery of evidence, judicial authorization, and privilege
• Criminal Procedure Code (CPC) / Criminal Procedure Law (CPL) — Varies by state; governs investigation procedures and subpoena issuance
• Cybercrimes (Prohibition, Prevention, Etc.) Act, 2015 — Addresses cybercrime investigations and digital evidence

12.3 Constitutional Rights

• 1999 Constitution of Nigeria, Section 37 — Right to privacy; restricts arbitrary government searches and seizures
• Requires compliance with law and procedure before disclosure

12.4 Sector-Specific Laws

• National Information Technology Development Agency (NITDA) Guidelines — Guidance on data handling by tech platforms

13. International Requests

13.1 MLAT and Mutual Legal Assistance

Requests from foreign governments must follow the Mutual Legal Assistance Treaty (MLAT) framework or the International Mutual Legal Assistance Procedure.

Process:

1. Foreign government channels request through its own justice ministry/attorney general
2. Nigerian Attorney General's Office receives and reviews request
3. If approved, forwarded to Chipon Alert with Nigerian legal authorization
4. Chipon Alert complies with the forwarded Nigerian legal process (as though it were a Nigerian court order)

13.2 Direct Requests from Foreign Law Enforcement

We do not accept direct requests from foreign law enforcement. All requests must be routed through:

• Nigerian Attorney General's Office, OR
• MLAT designated authority in the foreign country, OR
• Interpol through Nigerian authorities

13.3 Extraterritorial Considerations

Data involving Nigerian users is protected by Nigerian law regardless of where servers are located. We do not disclose Nigerian user data to foreign authorities without:

• Valid MLAT process, OR
• Nigerian legal process, OR
• Explicit Nigerian government authorization

14. Contact Information

14.1 Law Enforcement Requests

General Inquiries & Standard Requests:

• Email: lawenforcement@chipon.io
• Response target: 14-21 business days
• Include "LAW ENFORCEMENT REQUEST" in subject line

Emergency Requests (Imminent Threat to Life):

• Email: lawenforcement@chipon.io (24/7 monitoring)
• Include "EMERGENCY - URGENT" in subject line; provide officer badge/ID verbally or in writing

Mailing Address:

Tanta Innovative Limited
Legal Department — Law Enforcement Requests
25 Segun Gbelee Street
Ikeja, Lagos, Nigeria

General Counsel Contact (for disagreements or escalation):

• Email: team@chipon.io
• Reference: "Law Enforcement Escalation"
• Response target: 5 business days

14.2 International / MLAT Requests

Nigerian Attorney General's Office:

• All international requests must be directed through the Nigerian AGO's international legal assistance unit
• Chipon Alert will cooperate fully with AGO-forwarded requests

Chipon Alert Point of Contact for MLAT:

• Designated point of contact: Legal Department
• Email: team@chipon.io

14.3 Transparency & Accountability

Transparency Reports & Public Inquiries:

• Email: team@chipon.io
• Published reports: www.chipon.io/transparency

15. Policy Updates and Amendments

This policy is effective as of March 29, 2026. We reserve the right to amend this policy in response to:

• Changes in Nigerian law or regulation
• Changes in law enforcement practices or international standards
• Updates to our data retention, security, or collection practices

Material amendments (e.g., narrowing of what we disclose) will be published on our website at least 30 days before taking effect. Law enforcement is not entitled to notice of policy changes.

16. Governing Law and Jurisdiction

This policy is governed by the laws of the Federal Republic of Nigeria. Any dispute regarding interpretation or application shall be subject to the jurisdiction of Nigerian courts.

This policy does not constitute legal advice. Law enforcement agencies seeking clarification on specific requests should consult Nigerian legal counsel or the Attorney General's Office.

Document Version: 1.0
Next Review Date: March 29, 2027
Owner: Jyv Tech LLC / Tanta Innovative Limited Legal Department
Last Updated by: Engineering & Legal Team