Second Innings Law Enforcement Guidelines

1. ABOUT THESE GUIDELINES

1.1 Who they are for. These Law Enforcement Guidelines (these "Guidelines") are for government and law enforcement authorities seeking information about members of Second Innings. They explain how to submit legal process, emergency disclosure requests, and preservation requests to Second Innings, Inc. ("Second Innings," "we," "us," or "our").

1.2 Who they are not for. These Guidelines are not intended for members or other private parties. Members who want a copy of their own information can use "Download my data" in the app settings or contact privacy@secondinnings.app, as described in our Privacy Policy. Members who need to report a safety concern should use the in-app report tools or support@secondinnings.app, and anyone in immediate danger should contact local emergency services (911 in the United States).

1.3 No legal advice. We cannot provide legal advice to members, authorities, or anyone else. Nothing in these Guidelines is legal advice, creates any right in any person, or limits our right to object to, challenge, or decline any request.

1.4 Part of our policies. These Guidelines are one of the policies listed in Section 1.3 of our Terms of Service (the "Terms"). Capitalized terms that are not defined here have the meanings given in the Terms.

2. ABOUT SECOND INNINGS

2.1 Second Innings, Inc. is a Delaware corporation based in California, USA. We operate the Second Innings mobile applications and the website at secondinnings.app (together with related services, the "Services"), a dating service for adults 18 and older.

2.2 Our Services are operated from the United States and use service providers in the United States and other countries. Information is stored and processed in the United States and other countries, as described in our Privacy Policy.

2.3 We disclose member information only in accordance with our Terms, our Privacy Policy, and applicable law, including the U.S. Stored Communications Act, 18 U.S.C. 2701 and following (the "SCA").

3. INFORMATION WE MAY HAVE

3.1 Categories. Depending on how a member used the Services and on our retention practices, we may have some of the following information:

• Basic account information, such as name or display name, email address, phone number, date of birth, gender, sign-in method, account creation date, and account status;
• Profile content, such as photos, profile text, questionnaire answers, and location details the member provided;
• Messages between members sent through the Services, which are not end-to-end encrypted;
• Verification and safety records, such as selfie and liveness verification records, moderation decisions, reports and blocks, and ban records;
• Device and connection information, such as device identifiers, device model and operating system, IP addresses, and approximate location derived from IP address or from device location, with associated dates and times;
• Purchase records, such as subscription and add-on purchases, store transaction identifiers, and dates and amounts; and
• Support communications with us.

3.2 What we do not have.

• Purchases are processed by Apple and Google. We do not receive or store full payment card numbers. Payment information is held by the store.
• AI companion chat history is stored only on the member's device, not on our servers.
• We do not record voice or video calls.
• Some information may be held only by our service providers or by third-party platforms (such as Apple, Google, or Meta), and requests for that information should be directed to them.

3.3 Retention. We keep information for different periods depending on the type of information and why we have it, as described in our Privacy Policy. When a member deletes their account, the account enters a grace period (currently 14 days), after which most of the member's information is deleted or de-identified, while limited records may be retained, such as purchase records, safety and ban records, and records of legal acceptances, for the periods described in our Privacy Policy. Content that a member deleted, or that relates to a deleted account, may no longer be available. Evidence relating to child safety escalations is preserved for at least one year (see Section 9).

3.4 Identifying the account. To help us locate the correct account, please provide the email address or phone number associated with the account, or any account or user identifier you have. A name, age, city, or photo alone is often not enough to identify a single account, and we may not be able to respond to requests that do not identify an account with sufficient specificity.

4. REQUESTS FROM US AUTHORITIES

4.1 Valid legal process required. We disclose member records to US government authorities only in response to valid legal process issued under US law, or as otherwise permitted by law (for example, under Section 6 for emergencies). Consistent with the SCA:

• Subpoena. A valid subpoena issued in connection with an official criminal investigation may be used to request basic subscriber information described in 18 U.S.C. 2703(c)(2), where available, such as name, email address, phone number, account creation date, session dates and times, and IP addresses associated with logins.
• Court order. A court order issued under 18 U.S.C. 2703(d) is required to compel disclosure of other non-content records or information about an account, such as message headers (sender, recipient, date, and time) and IP address logs beyond basic subscriber information.
• Search warrant. A search warrant issued under the procedures described in the Federal Rules of Criminal Procedure, or equivalent state warrant procedures, upon a showing of probable cause, is required to compel disclosure of the stored contents of an account, such as messages, photos, and profile content.

4.2 What to include. Requests should be on official letterhead or issued by a court and include:
(a) the name of the issuing authority and agency, and the name, title, badge or identification number, official email address, telephone number, and mailing address of the requesting officer or agent;
(b) the email address, phone number, or other identifier of the account (Section 3.4);
(c) a specific description of the information requested and the relevant date range;
(d) the legal basis for the request; and
(e) a copy of any nondisclosure order (Section 8).
Please make requests as narrow as possible. Overly broad or vague requests may be delayed or declined.

4.3 How to submit. Send legal process to legal@secondinnings.app from an official government email address. We may also accept legal process by mail at Second Innings, Inc., Attn: Legal - Law Enforcement Response, 9206 Sunshine Pl, Downey, CA 90240, USA. We accept legal process by email or mail for convenience only. Doing so does not waive any objection, including objections to jurisdiction or to the manner of service, and does not mean that we consent to service by those methods for any other matter. We do not accept requests by phone, and we do not respond to requests from personal email accounts.

4.4 Our review. We review each request for legal sufficiency and may object to, narrow, or decline requests that are overbroad, unclear, unsupported, or legally deficient, or where we do not have the information requested.

5. REQUESTS FROM AUTHORITIES OUTSIDE THE UNITED STATES

5.1 Process. Second Innings is a US company. Authorities outside the United States should generally obtain information through a Mutual Legal Assistance Treaty ("MLAT") request, letters rogatory, an executive agreement under the U.S. CLOUD Act where one is in force, or another process recognized by US law. We will consider other requests from non-US authorities where disclosure is permitted by US law and by the law of the requesting country.

5.2 Voluntary disclosure. Where permitted by US law and consistent with our policies, we may, in our discretion, voluntarily disclose limited information in response to a request from a non-US authority, for example in an emergency (Section 6).

5.3 European Union. For purposes of the EU Digital Services Act, our single point of contact for authorities of EU Member States, the European Commission, and the European Board for Digital Services is legal@secondinnings.app, as stated in Section 27.1 of the Terms. We communicate in English.

5.4 India. Authorities in India may send requests under applicable Indian law to legal@secondinnings.app. We will respond as required by applicable law.

6. EMERGENCY DISCLOSURE REQUESTS

6.1 When we may disclose. Under 18 U.S.C. 2702(b)(8) and 2702(c)(4), we may voluntarily disclose information, including the contents of communications, to a governmental entity if we believe in good faith that an emergency involving danger of death or serious physical injury to any person requires disclosure without delay of information relating to the emergency. We evaluate each emergency request on its facts and decide in our discretion whether to disclose.

6.2 How to submit. Send emergency requests to legal@secondinnings.app from an official government email address with the subject line "EMERGENCY DISCLOSURE REQUEST" and include:
(a) the requesting officer's name, title, agency, badge or identification number, official email address, and a direct telephone number;
(b) the account identifier (Section 3.4);
(c) a description of the emergency, including who is at risk, the nature of the danger of death or serious physical injury, and why it is imminent;
(d) the specific information needed and how it will help prevent the harm; and
(e) a statement that the request is made in good faith based on an emergency involving danger of death or serious physical injury.

6.3 Response. We review emergency requests as quickly as reasonably practicable, but we cannot guarantee a response time. If someone is in immediate danger, contact local emergency services. We may require follow-up legal process for any disclosure beyond what the emergency requires.

7. PRESERVATION REQUESTS

7.1 US preservation requests. Under 18 U.S.C. 2703(f), on request from a governmental entity, we will take steps to preserve records and other evidence in our possession pending the issuance of legal process. Preservation requests should be sent to legal@secondinnings.app from an official government email address, or by mail as described in Section 4.3, and should include the account identifier (Section 3.4), the information to be preserved, and the relevant date range.

7.2 Duration. We preserve records for ninety (90) days from the date we process the request. We will extend preservation for an additional ninety (90) days upon a renewed request received before the initial period ends.

7.3 What is preserved. Preservation is a one-time snapshot of information we have at the time we process the request. We cannot preserve information that has already been deleted or that we do not have, and preservation does not capture information created after the snapshot unless a new request is made.

7.4 Non-US requests. We may honor preservation requests from non-US authorities for a limited period while the authority seeks formal legal process, such as through an MLAT.

7.5 Disclosure. Preservation does not mean we will disclose the information. Disclosure requires valid legal process as described in Sections 4 and 5.

8. NOTICE TO MEMBERS

8.1 Our policy. We may, in our discretion, notify members of requests for their information before disclosure, so that they have an opportunity to seek legal remedies.

8.2 When we may not notify. We will not notify a member where we are prohibited from doing so by law or court order (for example, an order under 18 U.S.C. 2705(b)), and we may decide not to notify a member, or to delay notice, in other circumstances, such as emergencies involving danger of death or serious physical injury, cases involving child exploitation, or where we believe notice would be counterproductive, futile, or would create a risk of harm.

8.3 Nondisclosure orders. If you believe notice would harm an investigation, please obtain a nondisclosure order or provide other legal authority prohibiting notice, and include a copy with your request. We may notify a member after a nondisclosure order expires.

9. CHILD SAFETY

9.1 Reports to NCMEC. As described in our Child Safety Standards, we report apparent child sexual exploitation and child sexual abuse material to the National Center for Missing & Exploited Children ("NCMEC") through its CyberTipline, as required by 18 U.S.C. 2258A. NCMEC may make reports available to law enforcement agencies in the United States and other countries.

9.2 Preservation. When we make a report, we preserve the contents of the report and related information for at least one (1) year, as required by 18 U.S.C. 2258A(h).

9.3 Follow-up requests. Law enforcement agencies following up on a CyberTipline report should serve legal process as described in Sections 4 and 5 and include the CyberTipline report number.

9.4 Child safety contact. Our designated child safety contact is legal@secondinnings.app.

10. COSTS, RECORDS, AND TESTIMONY

10.1 Costs. Where permitted by law, including 18 U.S.C. 2706, we may seek reimbursement of reasonable costs incurred in responding to requests, particularly for requests that are unusually broad or burdensome.

10.2 Authentication. Records we produce may be accompanied by a certificate of authenticity from a custodian of records, for example under Federal Rule of Evidence 902(11), which generally removes the need for live testimony. If you require testimony, please explain why a certificate is not sufficient and give us reasonable advance notice.

11. REQUESTS FROM PRIVATE PARTIES

11.1 Requests from private parties, including civil litigants and criminal defendants, must be made through valid legal process and properly served. The SCA generally prohibits us from disclosing the contents of communications in response to civil legal process, and we may object to civil requests for member information.

11.2 We do not provide legal advice to members or other parties. Members can obtain a copy of their own information through "Download my data" in the app settings or by contacting privacy@secondinnings.app.

12. CHANGES

We may update these Guidelines from time to time. The current version is available at secondinnings.app/law-enforcement.

13. CONTACT

• Legal process, emergency requests, and preservation requests: legal@secondinnings.app
• Mail: Second Innings, Inc., Attn: Legal - Law Enforcement Response, 9206 Sunshine Pl, Downey, CA 90240, USA

Please do not send law enforcement requests to support@secondinnings.app or privacy@secondinnings.app.