Law Enforcement Requests

OUR APPROACH TO LAW ENFORCEMENT REQUESTS

As a crypto assets services provider and an EU-based business, Itez is committed to principles of transparency and legality in all of our dealings. At the same time, we value the privacy of our clients. We abstain from disclosing information to third parties unless such disclosure is compliant with law or necessary to prevent or investigate illegal activities related to our services.

To ensure a transparent consideration process and full compliance with legal requirements, Itez handles all requests from judicial and law enforcement authorities regarding its clients 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), 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 client-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.

CONTENT OF LAW ENFORCEMENT REQUESTS

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

• be made in writing;
• be made or translated into English;
• designate the relevant authority submitting the request;
• be addressed to Beamloop UAB, the operator of the itez.com platform, which maintains its principal place of business at J.Savickio g.4-7, LT-01108 Vilnius, Lithuania;
• be signed by an electronic signature or have other means of document authentication (e.g. official seal);
• specify reasons for disclosure;
• specify legal grounds for disclosure by referring to a specific legal provision;
• clearly specify all data required;
• in case the request is related to transactions made by a bank card, specify the number of the bank card in question;
• in case of freezing requests, specify the duration of the freeze and if the freezing request can be disclosed to the client, otherwise, we will disclose the reason for such freeze to the client.

The requests shall be sent electronically at [email protected] from an email address with a government domain.

RESPONDING TO LAW ENFORCEMENT REQUESTS

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.

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

• does the request indeed originate from a law enforcement authority?
• is the request valid?
• are there legal grounds for disclosing personal data and what is the lawful basis under Article 6 Regulation (EU) 2016/679 (GDPR)?
• does the requested information constitute a special category of personal data under Article 9 Regulation (EU) 2016/679 (GDPR)?
• does the disclosure involve transferring personal data outside of the EEA?
• is disclosing the personal data necessary and proportionate for the requester’s purposes?
• any other relevant factors that must be considered under the circumstances.

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 or Itez along with the transmission adequacy.

In case where an international agreement, such as a mutual legal assistance treaty, is concluded between Lithuania 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 client 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.

EMERGENCY LAW ENFORCEMENT REQUESTS

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

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

COURT ORDERS

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.