Law Enforcement Guidelines

§1Overview

Halo is a wireless service operated by Block Apps LLC. We produce customer information only when compelled by valid legal process and only to the extent that process requires. These guidelines explain how to submit a request and what to expect. They do not create any rights, contractual or otherwise, and do not waive any objection we may raise.

§2How to serve legal process

Send valid legal process to the contact in Section 9. To help us respond accurately and quickly, every request should include:

• The specific account identifier - the Halo phone number at issue.
• The precise records or information sought.
• A specific date or time range for the records.
• Issuing agency, requesting officer, a return contact, and any court reference or deadline.

Overly broad or ambiguous requests will be returned for narrowing. We accept properly issued process from US federal, state, and local authorities consistent with applicable law.

§3Legal standards we require

The type of legal process required depends on the information sought:

• Basic subscriber and transactional records - a valid subpoena, in general.
• Non-content records such as call detail records - a court order under 18 U.S.C. § 2703(d) or equivalent, in general.
• Stored content and precise location - a search warrant issued on probable cause, where the law requires one.
• Real-time interception, or pen register / trap-and-trace - a wiretap order or pen-register order under the applicable statute.

We reserve the right to require a warrant for categories of data even where a lower standard might arguably apply, and to object to process that is defective or overbroad.

§4What data may be available

We can only produce data we actually have. Halo is built to collect and keep as little as possible, and much of what we hold is deleted on a short cycle. General retention windows:

• Basic subscriber information (name, contact details, plan) - kept for the life of the account plus 90 days.
• Call detail records and messaging metadata - up to 18 months, consistent with FCC carrier obligations.
• Content of primary-line calls and messages - not stored by Halo.
• Secondary-number message content - kept while the number is active and for 30 days after it is released.
• VPN activity - not logged; connection metadata is deleted within 24 hours.

Full detail is in Section 11 of our Privacy Policy. Because our retention windows are short, requests for older records may find that no responsive data exists.

§5Emergency requests

In an emergency involving a danger of death or serious physical injury, we may voluntarily disclose information to a law-enforcement agency where we have a good-faith belief that disclosure is necessary to prevent that harm, as permitted by 18 U.S.C. § 2702. Emergency requests must come from an official agency account, describe the emergency, and identify the information needed. Mark the request EMERGENCY and use the contact in Section 9.

§6Account authentication

To protect our customers, we authenticate account holders before discussing account details or releasing records, and we validate that legal process is properly issued before responding. We will not release records based on informal requests or on answers to readily available personal questions.

§7Customer notification

Our policy is to notify customers of requests for their information before we disclose it, so they may seek to challenge the request, unless we are prohibited from doing so by law or court order, or unless notice would endanger a person or an investigation into an imminent threat. If you seek to prevent notification, include a specific legal basis (such as a non-disclosure order under 18 U.S.C. § 2705(b)) with your request. We publish aggregate figures in our Transparency Report.

§8Cost reimbursement

We may seek reimbursement for the costs of responding to legal process to the extent permitted by law.

§9Service of process

Submit legal process and law-enforcement requests to:

• Email - support@switchtohalo.com
• Registered agent for service of process - Republic Registered Agent LLC, 5830 E 2nd St Ste 7000, Casper, WY 82609
• Company - Block Apps LLC, Nashville, TN, United States

Accepting requests by email does not waive any legal requirement for valid service or any objection available to us or to our customers.