Clearpoint Business Group, LLC. and its affiliates (“Clearpoint Business Group”) provide consulting services and technology products to business customers to accelerate growth and foster innovation. As a result of these services, Clearpoint Business Group periodically obtains information from and about our customers. Clearpoint Business Group recognizes its important obligation to protect the privacy and other rights of its customers while respecting and complying with the rules and laws of each jurisdiction in which it operates. For this reason, Clearpoint Business Group carefully reviews each request it receives from any law enforcement agency seeking customer information and provides such information in response to such requests only when Clearpoint Business Group reasonably believes that it is legally required to do so.
Customer Information Obtained/Retained by Clearpoint Business Group
Clearpoint Business Group obtains certain information from its customers that may be retained in its internal systems as a matter of regular business processes. That information may include names, email addresses, telephone numbers, usernames, billing contact information, or confidential business information. In some instances, Clearpoint Business Group may have additional information that includes IP addresses and transactional or other customer records.
To obtain information from Clearpoint Business Group, law enforcement officials must provide legal process appropriate for the type of information sought, such as a subpoena, court order, or a warrant. For example, Clearpoint Business Group will not provide non-public information unless served with a valid search warrant, issued on a showing of probably cause by a federal or state court authorized to issue such warrants, which requires Clearpoint Business Group to disclose the content.
These guidelines are intended to serve as an informational resource and do not create any obligations or waive any objections concerning how Clearpoint Business Group will respond in any particular case or request. Clearpoint Business Group reserves the right to seek reimbursement for the costs associated with responding to law enforcement data requests, where appropriate.
User Notice of Law Enforcement Requests for Information
Clearpoint Business Group’s policy is to notify users of requests for their information and provide them with an opportunity to object to the disclosure 7-10 days prior to the production, unless such notification is prohibited by law. Clearpoint Business Group may shorten the notice period in its discretion, but generally only does so in emergency situations. Law enforcement officials who believe that notification would jeopardize an investigation should obtain an appropriate court order or other process that specifically prohibits customer notification, such as an order issued under 18 U.S.C. § 2705(b).
Law Enforcement Preservation Requests
Clearpoint Business Group will preserve User Information for 90 days upon receipt of a valid law enforcement request. Clearpoint Business Group will preserve information for an additional 90-day period upon receipt of a valid request to extend the preservation. If Clearpoint Business Group does not receive formal legal process for the preserved information before the end of the preservation period, the preserved information may be deleted when the preservation period expires.
Preservation requests must be sent on official law enforcement letterhead, signed by a law enforcement official, and must include:
International Law Enforcement Requests
U.S. law authorizes Clearpoint Business Group to respond to requests for Customer Information from foreign law enforcement agencies that are issued via a U.S. court either by way of a Mutual Legal Assistance Treaty (MLAT) request or letter rogatory. It is our policy to respond to such U.S. court-ordered requests when properly served. Clearpoint Business Group will evaluate emergency requests from foreign law enforcement on a case-by-case basis, consistent with U.S. law and the laws of other countries, if applicable. Emergency requests may be submitted directly to Clearpoint Business Group via the procedure described below.
Emergency Requests
Clearpoint Business Group evaluates emergency requests on a case-by-case basis. If law enforcement provides information that gives us a good faith belief that there is an emergency involving imminent danger of death or serious physical injury to any person, we may provide information necessary to prevent that harm if we are in a position to do so, consistent with applicable law.
Requests for Production of Information
When requesting customer information, a law enforcement agency should provide as much of the following information as is available, as that will facilitate Clearpoint Business Group's ability to respond in an effective and timely manner: name, email address, physical address, phone number, dates of service, and if applicable, computing application or systems that are the subject of the request.
Each request must also include contact information for the authorized law enforcement agency official submitting the request, including the agency’s name, the requesting officer’s badge or other identification number, phone number, physical mailing address (P.O. boxes not accepted), and employer-issued email address. The request should also state clearly the requested response date.
Requests may be emailed to
[email protected] or mailed to Clearpoint Business Group, LLC., Attn.: Legal Department, 429 Fourth Avenue, Suite 300, Pittsburgh, PA 15219. While Clearpoint Business Group agrees to accept service of law enforcement requests by these methods, neither Clearpoint Business Group nor its customers waive any legal rights based upon this accommodation.
Please note that requests seeking testimony must be personally served on our registered agent for service of process. We do not accept such requests by email or postal service.
Revised: 06 October 2022