Law Enforcement Guidelines
Last modified: 7 February 2022
Introduction
These guidelines ("Guidelines") are intended for law enforcement authorities seeking data about users on the Lobby platform ("Platform") from any of the Lobby entities listed in the "Where to Direct a Request" section below. The Guidelines are not intended to provide legal advice and do not create any enforceable rights against Lobby. Some general principles are set forth below, but they may not be applicable in every case. Lobby may update or change the Guidelines without notice to any party.
Lobby is committed to cooperating with government authorities while respecting the privacy and other rights of its users. Lobby stores and maintains user data as described in our Privacy Policy and Terms of Service, and we will disclose user data only where a request is in accordance with those terms and applicable law, or in emergency circumstances. We may require appropriate legal and/or supporting documentation to be furnished by the law enforcement authority before we provide the requested customer information. Such documentation may include a court order, subpoena, warrant, authorization document or other valid legal process.
Lobby reserves the right to seek reimbursement for the costs associated with responding to law enforcement data requests.
Where to Direct a Request
Requests must be addressed to the correct Lobby entity, depending on the location of the relevant user:
Maverick Limited, LEVEL 54 HOPEWELL CENTRE, 183 QUEEN'S ROAD EAST, HONG KONGRequests for data of users located in the People's Republic of China (other than requests from US and UK law enforcement authorities, which should be directed to Lobby Universe, Inc). Requests from law enforcement authorities in the People's Republic of China (other than requests for US user data, which should be directed to Lobby Universe Inc.)
Lobby Universe Inc., 108 LAKELAND AVENUE, DOVER, KENT, DELAWARE 19901, USAAll other requests
All requests must be submitted by email to lerequests@lobby.game with any attachments (e.g. legal process or other documentation supporting the request) in PDF format. Law enforcement authorities may also use this email alias to obtain status updates on submitted requests or to ask questions.
Lobby will not respond to requests from non-law enforcement or non-governmental officials or to requests sent through unofficial channels.
Any confirmation of receipt of correspondence is for convenience only and does not waive any objections or legal rights of Lobby or its users (including objections for invalid legal process or lack of proper service or jurisdiction).
What Information to Include in a Request
You should include the below information in your request. Requests that are overbroad, vague, or otherwise inappropriate or that do not have a valid legal basis will be rejected.
Details of requesting law enforcement authority (or Court):
  • Requesting Authority (or Court): The name and location of the law enforcement authority. In the case of a Court order, the request should indicate the location and name of the relevant Court and judge / magistrate.
  • Requesting Officer: The requesting officer's name, badge / identification number, email address (this must be from an official email domain) and phone number (including any direct dial extension).
  • Signature: The request must be signed by the appropriate authority, such as a judge.
Details of relevant user account:
  • Unique account identifier: The request should include the individual's username. If no username is available, the request should include an individual's phone number or other identifying information that might assist us in locating the account(s) of interest.
  • User data requested: The request should provide clear details about the exact data fields being sought and the relationship between that data and the investigation in question. See the Types of User Data section for more information on the data we collect from and about our users.
  • Time period: The request should specify the time period for which you are requesting information.
Legal basis for the request:
  • Relevant legal process: The request should cite the applicable act or law pursuant to which the law enforcement agency is making the request.
  • Offense(s) under investigation: The request should separately indicate the type of offense(s) under investigation (citing the applicable act or law), the circumstances of the offense, and in what way it is connected to the Platform.
  • Deadline: The request should provide a date and time by which responsive materials must be produced, if applicable.
  • User notice: Please indicate whether you object to user notification and on what grounds (see User Notice section below).
Types of User Data
We may have the following types of data available:
Basic Subscriber Information
  • Lobby username
  • Lobby display name
  • Email address
  • Phone number
  • Date of birth
  • Lobby account creation date and IP address
  • Timestamp and IP address of Lobby account logins and logouts
Usage Data
  • Device information (e.g., model, device IDs, operating system)
Location Data
  • IP addresses
Logs
  • Timestamp and IP address of users entering and leaving Lobby rooms
Content Data
  • Messages
  • Photos
  • Videos
Preservation Requests
We honor formal requests from law enforcement to preserve information in accordance with 18 U.S.C. § 2703(f). Upon receiving a signed and dated preservation request on law enforcement department letterhead, we will attempt to preserve available Lobby account records associated with any properly identified Lobby user(s) in an offline file for up to 90 days, and will extend the preservation for one additional 90-day period with a formal extension request. If Lobby 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.
Emergency Disclosure Requests
Lobby may voluntarily disclose account information to a government authority if Lobby has a good-faith belief that an emergency posing a threat of imminent harm or serious physical injury would require the immediate disclosure of the requested information. Law enforcement may also obtain account information with an emergency disclosure request. The information disclosed must be limited to the amount necessary to specifically address the ongoing emergency.
Emergency disclosure requests may be submitted by email to lerequests@lobby.game. These requests must be submitted by a sworn law enforcement official and must come from an official law enforcement email domain on official law enforcement letterhead.
Emergency disclosure requests must:
  • Identify the person who is in danger of death or serious physical injury, or who is at risk of imminent harm.
  • Provide a unique account identifier for the user(s) whose data is necessary to prevent an emergency.
  • Include a description of the nature of the emergency, including details about the nature of the alleged actual or threatened physical harm or exigency.
  • Specify what exact data fields are being requested and provide as much detail as possible about the relationship between that data and the incident or emergency.
  • Certify that the request is, in fact, related to an emergency involving danger of death or serious physical injury that requires disclosure without delay of information relating to that emergency.
  • Certify that law enforcement is unable to obtain legal process in time to respond to the emergency.
User Notice
It is Lobby's policy to notify users when it receives legal process seeking disclosure of Lobby users' records. However, two exceptions to this policy may apply. First, Lobby will not notify users where such notice is prohibited by a court order issued under 18 U.S.C. § 2705(b) or by other valid legal authority. Second, Lobby reserves the right to withhold user notification where it determines, in its sole discretion, that exceptional circumstances exist. Such exceptional circumstances may include threat of imminent death or serious bodily injury or child exploitation.
If your data request draws attention to an ongoing or prior violation of our terms of use, we may take action to prevent further violations, including actions that may notify the user that we are aware of their violation. If such actions will jeopardize an ongoing investigation, it is your responsibility to request that we defer such action, which includes your providing the appropriate court order or other legal authority prohibiting such action.
Mutual Legal Assistance Treaty Requests
We may request that a law enforcement authority submit a request for legal assistance to designated government authorities under the Mutual Legal Assistance Treaty ("MLAT") framework, letters rogatory, or similar process, such as when the requesting law enforcement authority is located in a different country than the Lobby entity that provider the service to the user whose data is requested.
Child Safety Concerns
In certain circumstances, we may become aware of potential child exploitation content on our platform, and we may report such instances to the National Center for Missing and Exploited Children ("NCMEC"). NCMEC will review these reports and coordinate with both domestic and international law enforcement agencies as necessary.
Law Enforcement Guidelines
Last modified: 7 February 2022
Introduction
These guidelines ("Guidelines") are intended for law enforcement authorities seeking data about users on the Lobby platform ("Platform") from any of the Lobby entities listed in the "Where to Direct a Request" section below. The Guidelines are not intended to provide legal advice and do not create any enforceable rights against Lobby. Some general principles are set forth below, but they may not be applicable in every case. Lobby may update or change the Guidelines without notice to any party.
Lobby is committed to cooperating with government authorities while respecting the privacy and other rights of its users. Lobby stores and maintains user data as described in our Privacy Policy and Terms of Service, and we will disclose user data only where a request is in accordance with those terms and applicable law, or in emergency circumstances. We may require appropriate legal and/or supporting documentation to be furnished by the law enforcement authority before we provide the requested customer information. Such documentation may include a court order, subpoena, warrant, authorization document or other valid legal process.
Lobby reserves the right to seek reimbursement for the costs associated with responding to law enforcement data requests.
Where to Direct a Request
Requests must be addressed to the correct Lobby entity, depending on the location of the relevant user:
Maverick Limited, LEVEL 54 HOPEWELL CENTRE, 183 QUEEN'S ROAD EAST, HONG KONGRequests for data of users located in the People's Republic of China (other than requests from US and UK law enforcement authorities, which should be directed to Lobby Universe, Inc). Requests from law enforcement authorities in the People's Republic of China (other than requests for US user data, which should be directed to Lobby Universe Inc.)
Lobby Universe Inc., 108 LAKELAND AVENUE, DOVER, KENT, DELAWARE 19901, USAAll other requests
All requests must be submitted by email to lerequests@lobby.game with any attachments (e.g. legal process or other documentation supporting the request) in PDF format. Law enforcement authorities may also use this email alias to obtain status updates on submitted requests or to ask questions.
Lobby will not respond to requests from non-law enforcement or non-governmental officials or to requests sent through unofficial channels.
Any confirmation of receipt of correspondence is for convenience only and does not waive any objections or legal rights of Lobby or its users (including objections for invalid legal process or lack of proper service or jurisdiction).
What Information to Include in a Request
You should include the below information in your request. Requests that are overbroad, vague, or otherwise inappropriate or that do not have a valid legal basis will be rejected.
Details of requesting law enforcement authority (or Court):
  • Requesting Authority (or Court): The name and location of the law enforcement authority. In the case of a Court order, the request should indicate the location and name of the relevant Court and judge / magistrate.
  • Requesting Officer: The requesting officer's name, badge / identification number, email address (this must be from an official email domain) and phone number (including any direct dial extension).
  • Signature: The request must be signed by the appropriate authority, such as a judge.
Details of relevant user account:
  • Unique account identifier: The request should include the individual's username. If no username is available, the request should include an individual's phone number or other identifying information that might assist us in locating the account(s) of interest.
  • User data requested: The request should provide clear details about the exact data fields being sought and the relationship between that data and the investigation in question. See the Types of User Data section for more information on the data we collect from and about our users.
  • Time period: The request should specify the time period for which you are requesting information.
Legal basis for the request:
  • Relevant legal process: The request should cite the applicable act or law pursuant to which the law enforcement agency is making the request.
  • Offense(s) under investigation: The request should separately indicate the type of offense(s) under investigation (citing the applicable act or law), the circumstances of the offense, and in what way it is connected to the Platform.
  • Deadline: The request should provide a date and time by which responsive materials must be produced, if applicable.
  • User notice: Please indicate whether you object to user notification and on what grounds (see User Notice section below).
Types of User Data
We may have the following types of data available:
Basic Subscriber Information
  • Lobby username
  • Lobby display name
  • Email address
  • Phone number
  • Date of birth
  • Lobby account creation date and IP address
  • Timestamp and IP address of Lobby account logins and logouts
Usage Data
  • Device information (e.g., model, device IDs, operating system)
Location Data
  • IP addresses
Logs
  • Timestamp and IP address of users entering and leaving Lobby rooms
Content Data
  • Messages
  • Photos
  • Videos
Preservation Requests
We honor formal requests from law enforcement to preserve information in accordance with 18 U.S.C. § 2703(f). Upon receiving a signed and dated preservation request on law enforcement department letterhead, we will attempt to preserve available Lobby account records associated with any properly identified Lobby user(s) in an offline file for up to 90 days, and will extend the preservation for one additional 90-day period with a formal extension request. If Lobby 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.
Emergency Disclosure Requests
Lobby may voluntarily disclose account information to a government authority if Lobby has a good-faith belief that an emergency posing a threat of imminent harm or serious physical injury would require the immediate disclosure of the requested information. Law enforcement may also obtain account information with an emergency disclosure request. The information disclosed must be limited to the amount necessary to specifically address the ongoing emergency.
Emergency disclosure requests may be submitted by email to lerequests@lobby.game. These requests must be submitted by a sworn law enforcement official and must come from an official law enforcement email domain on official law enforcement letterhead.
Emergency disclosure requests must:
  • Identify the person who is in danger of death or serious physical injury, or who is at risk of imminent harm.
  • Provide a unique account identifier for the user(s) whose data is necessary to prevent an emergency.
  • Include a description of the nature of the emergency, including details about the nature of the alleged actual or threatened physical harm or exigency.
  • Specify what exact data fields are being requested and provide as much detail as possible about the relationship between that data and the incident or emergency.
  • Certify that the request is, in fact, related to an emergency involving danger of death or serious physical injury that requires disclosure without delay of information relating to that emergency.
  • Certify that law enforcement is unable to obtain legal process in time to respond to the emergency.
User Notice
It is Lobby's policy to notify users when it receives legal process seeking disclosure of Lobby users' records. However, two exceptions to this policy may apply. First, Lobby will not notify users where such notice is prohibited by a court order issued under 18 U.S.C. § 2705(b) or by other valid legal authority. Second, Lobby reserves the right to withhold user notification where it determines, in its sole discretion, that exceptional circumstances exist. Such exceptional circumstances may include threat of imminent death or serious bodily injury or child exploitation.
If your data request draws attention to an ongoing or prior violation of our terms of use, we may take action to prevent further violations, including actions that may notify the user that we are aware of their violation. If such actions will jeopardize an ongoing investigation, it is your responsibility to request that we defer such action, which includes your providing the appropriate court order or other legal authority prohibiting such action.
Mutual Legal Assistance Treaty Requests
We may request that a law enforcement authority submit a request for legal assistance to designated government authorities under the Mutual Legal Assistance Treaty ("MLAT") framework, letters rogatory, or similar process, such as when the requesting law enforcement authority is located in a different country than the Lobby entity that provider the service to the user whose data is requested.
Child Safety Concerns
In certain circumstances, we may become aware of potential child exploitation content on our platform, and we may report such instances to the National Center for Missing and Exploited Children ("NCMEC"). NCMEC will review these reports and coordinate with both domestic and international law enforcement agencies as necessary.