Inflection Law Enforcement Guidelines

This guide is designed for U.S. law enforcement seeking information related to websites and services operated by Inflection.com, Inc. These websites and services include PeopleSmart.com and its white-label affiliates, Identity.com, and GoodHire.com.

These guidelines describe what information we collect, the form of legal process required for different types of information, and what we require before producing information. These guidelines are not intended as legal advice. Please contact us if you have questions.

Here is how each Inflection service works.

Identity.com is a service that allows users to manage their identities online. Users can submit user content in order to build an Identity.com profile that can include personal information and social media information. Users can choose to verify their identities using a third-party service and also link their profiles to public records available on other Inflection services. User content on Identity.com is private by default.

PeopleSmart.com and its white-label affiliates provide tools that allow people to search public records related to themselves and others. Users can search by name, phone number, email address, or physical address. Users that want to purchase public records reports must provide customer registration information. PeopleSmart is a search tool – there is no user content on PeopleSmart.

GoodHire.com is an FCRA-compliant consumer reporting agency, specializing in employment screening. On behalf of verified businesses, the service runs background checks on these businesses’ prospective and current employees Only verified employers can submit customer registration information to GoodHire.com and purchase reports using the service.

Your legal request should identify you and what you seek.

  • Your agency’s name;
  • Requesting agent’s name, email address & direct phone number;
  • The Inflection service you seek information from;
  • Information describing the subject of the investigation, if relevant;
  • The specific information we possess that you seek (see below); and
  • A deadline for our response.

Here are the preferred methods of communication.

Inflection prefers to provide records via email, fax, or mail. We ask that your legal request expressly permit Inflection to produce records in this manner unless such production is insufficient and in-person witness testimony is necessary.

Here are the categories of information each service may collect.

Identity.com: Customer registration information, transaction records, and user content.
PeopleSmart.com, and its white-label affiliates, and GoodHire.com: Customer registration information and transaction records.

Here are the types of information we collect.

Your request should identify the specific material you seek (e.g. “IP address from account registration”). The more precise your request, the quicker we can process it.

Customer Registration Information

  • Full name
  • Email address associated with an account or purchase
  • Billing address and/or zip code
  • IP address, User Agent, and referral page from account registration
  • IP addresses related to logins and sessions, and the pages visited by a specific IP address (this information is only retained for 10 days)
  • Non-content information related to a specific customer-created message (e.g. To:/From: and date)

Transaction Records

  • Credit card information
  • Purchase records including order date, order number, product or report purchased, associated search query, and item status
  • Non-subscriber purchase information such as date, transaction ID, amount of purchase, type/status of purchase, and reason for status
  • Non-content information related to a specific message or correspondence
  • Messages sent by Inflection.com, Inc. to the relevant customer including messages related to transactions, customer queries, products, and services

User Content

  • Search criteria and date
  • Search results or results of reports purchased by accountholders
  • Recorded phone calls between Inflection customers and Inflection
  • User-generated content that has not been deleted by a user and that the user has designated as private, including personal information other than customer registration information
  • Messages sent by a registered user to Inflection

Here is the minimum legal process we require for each category of information.

We require at least a valid subpoena issued under state or federal law in order to produce customer registration information or transaction records.

We require a search warrant based on probable cause in order to produce user content. A search warrant should be issued under the procedures described in the U.S. Federal Rules of Criminal Procedure (or equivalent state criminal procedure laws).

Your request should be sent to:

Inflection Privacy Team

By email: lawenforcement@inflection.com

By mail:
Inflection
ATTN: Inflection Privacy Team
555 Twin Dolphin Drive, Suite 200
Redwood City, CA 94065

Our goal is to provide customers with notice.

Unless your legal request includes a court order prohibiting Inflection from providing notice to an affected user (e.g., an order under 18 U.S.C. § 2705(b)), Inflection will do its best to provide that user with notice except in certain limited cases where we believe that notice would be counterproductive, such as situations involving imminent physical harm or harm to minors. If we provide advance notice, we will also provide the user with the opportunity to obtain a copy of the relevant legal request. We explain this in our privacy policy on each website.

Law enforcement officials who believe that user notice may hinder an investigation should seek a court order and attach that order to the legal request upon providing it to Inflection.

We include the complete legal request served on Inflection when we notify users of requests for their information. To the extent that it does not decrease the user’s ability to understand the request and seek legal advice, we will redact the requestor’s identifying information (i.e., officer or investigator name, email, phone) from a request before we provide a copy to the affected user.

Emergency Requests

Inflection may produce information in certain emergency circumstances that involve imminent or serious bodily harm to a person. Examples include requests relating to harm to minors or children and credible threats towards identifiable persons.

Your emergency request should at a minimum include: (1) a detailed explanation of why the request satisfies Inflection’s standard for an emergency request and (2) the minimum information necessary to resolve the emergency.

If you need to contact Inflection after hours (before 8am PST or after 5pm PST) for an emergency, please call 650-260-8392.

Preservation Of User Information

Inflection will preserve information upon receiving a request under the Electronic Communications Privacy Act. See 18 U.S.C. § 2703(f). Inflection requires the following for preservation requests: (1) identification of the exact information to be preserved for 90 days pending the issuance of legal process, (2) the name of the user and/or relevant Inflection page URL, and (3) the date that preservation should begin.

Upon receiving the request, Inflection will set aside a copy of the requested records. Inflection will not record or preserve information in a prospective manner upon receiving a preservation request. Inflection retains the right to require reimbursement for costs, including reimbursement in advance of preserving user information, and to seek enforcement of such costs. See 18 U.S.C. § 2706.

Unless Inflection obtains an extension request before the 90 calendar days have lapsed, Inflection will delete the relevant records on the 91st day.

To be effective, any preservation request for user content must be received before a user or moderator deletes such content.

Civil Process

Inflection will inform users about civil subpoenas for their information and provide them with the opportunity to quash such subpoenas before we produce any information requested by any such subpoena.

Inflection is a Delaware company and thus requires legal process issued in compliance with state law. In Delaware, an out-of-state civil litigant must take certain steps in order to issue a subpoena that has authority in the state.

International Requests

Inflection is an American company. For information Inflection hosts in the United States, Inflection will respond to foreign legal requests only if they are issued by a U.S. court pursuant to a mutual legal assistance treaty or a letter rogatory.

Additional Information

Inflection’s receipt or compliance with any legal process does not waive any objections Inflection may have to such process, including but not limited to notice, personal jurisdiction, or venue.

If you have any questions about this guide, please reach out to us: lawenforcement@inflection.com