Triple Whale’s Principles for Government Requests for Customer Data
We always aim to protect our customers’ data while complying with applicable laws. Accordingly, we will never voluntarily provide authorities with access to personal data that we process on your behalf; but we may disclose such data under a compelling legal obligation to do so, such as a valid subpoena, court order or search warrant (e.g., issued in connection with an official criminal investigation), issued to us by a court of competent jurisdiction.
Importantly, Triple Whale is not the ‘controller’ of the personal data that we process on our customers’ behalf (which is typically data relating to your shoppers or end-users), and we strongly believe that our customers should have as much control as possible over handling any such data disclosure requests. Accordingly, our first response to any government data request will always be to inform the requesting authority that any and all requests or demands for access to our customer’s data should be made directly to the customer concerned, and explain that Triple Whale is the ‘processor’ of such data on behalf of the customer.
Only where this is not possible will we continue to examine the request – for example, if the requesting authority declines to communicate the request to the customer or under exceptional circumstances as described below.
In order to give you the opportunity to challenge any government data request relating to your data, we will notify you before disclosing any such data to the requesting authority, unless:
If Triple Whale is legally prohibited from notifying you of the request prior to disclosure, we will:
Lastly, Triple Whale commits to preparing a bi-annual report (“Transparency Report”), which reflects the number and type of government data requests it has received in the preceding six months, as may be limited by applicable law or court order. Triple Whale shall publish the Transparency Report on its website, and make the report available upon request to competent data protection supervisory authorities.
Last updated: November 2022