Law Enforcement Requests

Datalink sp. z o.o. ("Itez", "we", "us", or "our"), Operating the platform at itez.com is a duly authorized Virtual Assets Service Provider established under the laws of the Republic of Poland. As an EU-based virtual assets service provider, we are committed to upholding principles of transparency, legality, and regulatory compliance in all our operations.

We do not disclose information to third parties unless such disclosure is compliant with law or necessary to prevent or investigate illegal activities related to our Services.

This Law Enforcement Requests Policy (the "Policy") establishes the framework and procedures governing how Itez processes and responds to information requests from judicial authorities, law enforcement agencies, regulatory bodies, and other competent authorities.

To ensure a transparent consideration process and full compliance with legal requirements, Itez handles all requests from judicial and law enforcement authorities regarding its users and/or the provided Services in accordance with this Law Enforcement Requests Policy.

DISCLOSURE CONDITIONS

When Itez receives a law enforcement request, it ensures compliance with Regulation (EU) 2016/679 (GDPR), and applicable national Polish acts regulating the Protection of Personal Data, Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Virtual Assets, as well as all other applicable Polish and European Union laws and regulations, as well as other legislation applicable to its activities.

Itez discloses the requested information only in certain instances, and always when it is not legally prohibited from doing so. As a general rule, Itez discloses user-related information strictly on the grounds and for the specific purposes listed in applicable law.

Thus, any information request can only be processed when it originates from a law enforcement agency, regulatory authority, or other competent body, and follows the requirements set out in this Law Enforcement Requests Policy or when the disclosure of the information is directly prescribed by law.

In practice, this implies that a request from a member of a law enforcement authority for some identifiable information about an individual does not grant them automatic entitlement to it.

Notwithstanding, Itez is committed to cooperating with law enforcement authorities in order to combat crime, including fraud, money laundering, and terrorist financing. Itez strives to respond to all such requests in accordance with this Law Enforcement Requests Policy.

The disclosure requests addressed to Itez shall meet the following criteria:

• The requests shall be sent electronically at [email protected] from an email address with a government domain.
• Any request is considered on the merits of its own facts and circumstances. Itez only shares the minimum necessary amount of relevant and adequate personal data.
• Each request must clearly state
  • the identity and official capacity of the requesting authority,
  • the legal basis for the request,
  • the specific purpose, clear identification of the user(s) or account(s) (name, email, account ID, full bank card number, transaction ID, or other identifying information),
  • the specific information requested,
  • the relevant time period, and
  • contact information for follow-up.

Having received a valid request in writing from a law enforcement authority, Itez makes the following considerations:

• In case the request originates from outside of the EEA and implies personal data transfer, Itez considers if such transmission of personal data outside the EU and the EEA may impose additional risks both for the personal data subject and Itez, along with the transmission adequacy.
• In case where an international agreement, such as a mutual legal assistance treaty, is concluded between Poland and the state of the law enforcement authority outside the EEA, Itez generally refers the requesting authority to the existing international agreements according to the rules of Articles 48 and 49 Regulation (EU) 2016/679 (GDPR) and Guidelines of the European Data Protection Board.

Itez does not disclose any user personal data upon unsolicited requests of private parties, such as banks or payment services providers, unless the subject of such personal data has provided informed and unambiguous consent to it.

We aim to answer law enforcement requests within 10 working days. However, we endeavor to address urgent matters within a shorter timeframe.

For heightened urgency, please include "URGENT REQUEST" in the subject line of the request.

This Law Enforcement Requests Policy does not apply in respect of Court Orders. Itez is obliged to provide the information specified in valid Court Orders addressed to Itez.

COOPERATION WITH INVESTIGATIONS

Itez is committed to cooperating with law enforcement authorities in the investigation and prosecution of criminal activities, including:

• Money laundering and terrorist financing
• Fraud and financial crimes
• Cybercrime and hacking
• Drug trafficking and organized crime
• Child exploitation and abuse
• Other serious criminal offenses

Such cooperation is balanced against our obligations to protect user privacy and comply with data protection laws, and is conducted in accordance with this Policy and applicable legal frameworks.