Government & Law Enforcement Request Policy
Issued June 3, 2026
Avoda Interactive, LLC, and its subsidiaries ("Avoda," "Company," "we," "us," "our"), operates the ConnectBetter platform and other digital properties (the "Sites"). We are committed to protecting the privacy of our users and the individuals whose information we process on behalf of our customers. This Government & Law Enforcement Request Policy ("Policy") explains how we respond to requests from government agencies, law enforcement, and other public authorities for user data, and the safeguards we apply to every such request.
This Policy is intended to provide transparency to our users and clear guidance to any authority seeking data from us. It supplements, and should be read together with, the Avoda Privacy Policy at avoda.co/privacy.
Scope
This Policy applies to all requests from any government, regulatory body, law enforcement agency, or other public authority, anywhere in the world, seeking access to or disclosure of:
- Personal data or personal information of our users or our customers' end users;
- Account, subscription, or transaction records;
- Content, communications, or metadata processed through our Sites; or
- Any other data in our possession or control.
It applies whether the request arrives by subpoena, court order, search warrant, civil investigative demand, statutory notice, emergency disclosure request, preservation request, or any other form of legal process.
Acceptable Legal Process
We require valid legal process before disclosing user data, and we disclose only what the applicable legal process compels. As a general matter:
- Subpoena — we require a valid subpoena issued under applicable law for the disclosure of basic subscriber or account-identifying information.
- Court order — we require a valid court order for the disclosure of non-content records and other transactional information.
- Search warrant — we require a valid search warrant issued upon a showing of probable cause by a court of competent jurisdiction for the disclosure of stored content.
Requests must be issued by an authority with jurisdiction over Avoda Interactive, LLC and must be served through the channel described in the "How to Submit a Request" section below. Requests from authorities outside the United States must be served through a legally recognized mechanism, such as a mutual legal assistance treaty (MLAT) or letter rogatory, unless another lawful basis applies.
Validity and Legality Review
We review every request we receive to confirm that it is legally valid and sufficient before we respond. This review includes confirming that:
- The request comes from a legitimate, identifiable authority with jurisdiction over us;
- The request is issued under, and complies with, applicable law;
- The form of legal process matches the category of data sought (for example, a search warrant for stored content); and
- The request is specific, properly scoped, and not facially deficient, overbroad, or otherwise improper.
We do not disclose data in response to informal, unauthenticated, or legally insufficient requests.
Objections and Challenges
Where a request is legally deficient, overbroad, vague, improper, or otherwise unlawful, we will seek to narrow it and, where appropriate, object to or formally challenge it through available legal channels. We reserve the right to require the requesting authority to follow the correct legal process and to litigate or move to quash requests that do not meet the requirements of applicable law. We will not voluntarily produce data that the law does not require us to produce.
Data Minimization
When we are legally required to disclose data, we disclose only the minimum information necessary to comply with the specific, valid legal process presented. We do not provide data beyond the precise scope of a valid request, and we interpret the scope of any request narrowly. Where a request can be satisfied with less sensitive or less extensive data, we provide only that data.
Recordkeeping and Documentation
We document each government or law enforcement request we receive and our handling of it, including:
- The identity of the requesting authority and the date received;
- The legal process presented and the data sought;
- Our legal review, any objections or challenges raised, and the reasoning behind our response;
- What data, if any, was disclosed and to whom; and
- The personnel involved in reviewing and responding to the request.
These records are retained in accordance with our internal retention practices and applicable law.
User Notice
We believe users are entitled to know when a government or law enforcement authority seeks their data. Our policy is to notify the affected user before disclosing their data, and to provide them with a copy of the request where practical, so that they have an opportunity to object. We will delay or withhold notice only where we are legally prohibited from giving notice (for example, under a valid non-disclosure or gag order), where notice would be futile or counterproductive, or in a genuine emergency involving a risk of death or serious physical harm. Where notice is delayed by a legal prohibition, we will provide notice after the prohibition expires.
Emergency Requests
In genuine emergencies involving an imminent risk of death or serious physical injury to a person, we may disclose limited information to law enforcement without legal process, on a voluntary and narrowly tailored basis, where we have a good-faith belief that disclosure is necessary to prevent the harm. Emergency requests must be submitted through the channel below and must describe the nature of the emergency, the specific information needed, and how that information relates to preventing the harm. We evaluate each emergency request individually and disclose only the data necessary to address the emergency.
Preservation Requests
We will honor valid requests to preserve account records pending the service of formal legal process, as required by applicable law. A preservation request does not by itself compel disclosure; we will preserve the relevant records for the period required by law while awaiting valid legal process for any disclosure.
National Security Requests
We apply the same principles of legality review, scope minimization, challenge of improper demands, and documentation to national security requests, to the fullest extent permitted by law. Where we are legally prohibited from disclosing the existence of, or details about, a national security request, we will comply with that prohibition while applying the safeguards in this Policy to the extent the law allows.
Customer Data
For data we process on behalf of our business customers (for example, the end-user communications a customer manages through ConnectBetter), our customer is the controller of that data. Where we receive a request for such data and are legally permitted to do so, our policy is to redirect the requesting authority to the customer and to notify the customer, so that the customer may respond directly. We will not disclose customer-controlled data except as required by valid legal process directed to us.
How to Submit a Request
Government and law enforcement authorities seeking data from Avoda Interactive, LLC must submit a request, with valid legal process attached, to:
Avoda Interactive, LLC Attn: Legal — Government & Law Enforcement Requests 801 W. Main Street Peoria, IL 61606 Email: legal@avoda.co
To allow us to process a request, please include the requesting authority and contact information, the specific data sought, the legal process authorizing the request, and a deadline for response. For emergency requests, clearly mark the request as an emergency and describe the nature of the risk.
Submitting a request through this channel does not waive any objection we may raise, and our acceptance of a request for review does not constitute agreement to produce the data sought.
Updates to this Policy
We may update this Policy from time to time to reflect changes in law or our practices. The current version is always available at avoda.co/government-requests.
Questions or Concerns
If you have any questions about this Policy, please contact us at legal@avoda.co or at the address below.
Avoda Interactive, LLC 801 W. Main Street Peoria, IL 61606
Effective Date: June 3, 2026 Version: 06.03.26v01