Law Enforcement Legal Process Guidelines

Introduction

These guidelines are provided for use by government and law enforcement agencies within Gibraltar when seeking information from IVPN Limited (“IVPN”) about users of the IVPN service (“IVPN users”).

These guidelines do not apply to requests made by government and law enforcement agencies outside Gibraltar. IVPN does not respond to requests from governments or law enforcement agencies outside of Gibraltar, all requests must originate from a government agency with jurisdiction in Gibraltar.

IVPN has a centralized process for receiving, tracking, processing, and responding to legitimate legal requests from government and law enforcement from when they are received until when a response is provided. Our legal department reviews and evaluates all requests received, and requests which IVPN determines to have no valid legal basis or considers to be unclear, inappropriate or over-broad are challenged or rejected.

The information contained within these Guidelines is devised to provide information to government and law enforcement agencies within Gibraltar regarding the legal process that IVPN requires in order to disclose electronic information to government and law enforcement agencies within Gibraltar. These Guidelines are not intended to provide legal advice.

Nothing within these Guidelines is meant to create any enforceable rights against IVPN and IVPN’s policies may be updated or changed in the future without further notice to government or law enforcement.

About IVPN

IVPN provides a VPN service “IVPN” for consumers and small teams to improve their security and privacy whilst using the Internet. We develop the client software required to connect securely to our servers and manage a large network of servers through which IVPN users traffic is routed.

User information is held by IVPN in accordance with the IVPN privacy policy and the applicable terms of service. IVPN is committed to maintaining the privacy of the IVPN users of the IVPN service. Accordingly, information about IVPN users will not be released without valid legal process.

Legal process

IVPN accepts service of subpoenas, search warrants, and court orders by email from government and law enforcement agencies, provided these are transmitted from the official email address of the government or law enforcement agency concerned. Government and law enforcement personnel submitting a legal request to IVPN should transmit it directly from their official government or law enforcement email address to legal@ivpn.net. This mailbox is intended solely for use by government and law enforcement personnel.

When government or law enforcement has served legal process on IVPN by email, a duplicate hard copy must be personally served at the IVPN headquarters at:

IVPN Limited, 5 Secretary’s lane, GX11 1AA, Gibraltar.

Where possible, IVPN will notify IVPN users when their IVPN account information is being sought in response to legal process from government, law enforcement, or third parties, except where providing notice is explicitly prohibited by the legal process itself, by a court order IVPN receives.

Information available from IVPN

Customer records

IVPN has no need to collect or store personal personally identifiable information relating to our customers and therefor no personally identifiable information is requested, collected or stored when a customer signs up for our service. Each customer is assigned a randomly generated identifier which they use to authenticate themselves to our service.

If a payment method is chosen that requires an external payment processor and that payment processor requires that IVPN store a link to the transaction in our system then that identifier together with the payment processor is stored with the randomly generated user account ID.

Information not available from IVPN

Connection logs

IVPN does not store any logs relating to the connections of IVPN users to the VPN network i.e. timestamped records of when a particular user connected and disconnected to any server in the IVPN network. If provided with a timestamp IVPN are therefor not able to determine who was connected to any server at that time.

Activity logs

IVPN do not store logs relating to the activity of IVPN users when connected to the IVPN service i.e. timestamped records of what Internet servers or websites the IVPN user was connected to. Therefor if provided with a timestamp IVPN are not able to retrieve any Internet activity relating to any time period or user account.

If you have further questions, please contact legal@ivpn.net.