Requests for User Data from Public Authorities

• Legality review. Every request is reviewed for legality before any data is disclosed.
• Challenging unlawful requests. Requests we consider unlawful, overly broad or outside the requesting authority's powers are refused, narrowed or challenged.
• Data minimisation. We disclose only the minimum data the request lawfully requires.
• Documentation. Every request, and our response to it, is recorded.

We never give any public authority direct or ongoing access to our systems, and we do not disclose data voluntarily, without valid legal process, except in the emergencies described in section 6.

We respond only to requests that:

• are made in writing, from an official address or on the authority's letterhead;
• identify the authority, the officer making the request and how to verify them;
• state the legal basis (the law, court order, warrant or other legal process) that requires us to disclose the data;
• identify the account or data precisely (for example an account's email or phone number) and the time period concerned.

Requests should be sent to privacy@olbongo.com. Requests made informally, by phone or through social media are not answered until they are made in writing.

Each request is reviewed by Olbongo's designated privacy lead, with legal advice where needed. We check:

• that the request is genuine and comes from an authority with the power to make it;
• that it rests on a valid legal basis under the applicable law, including the Personal Data Protection Act, 2022 of Tanzania, where Olbongo is established;
• that an authority from another country uses a channel recognised by Tanzanian law, such as a mutual legal assistance request;
• that what it asks for is necessary and proportionate to its stated purpose.

No data is disclosed until the review is complete and the request has been approved.

Where a request is unlawful, lacks a valid legal basis, is overly broad or is outside the authority's powers, we refuse it, ask the authority to clarify or narrow it, or challenge it before the competent court or body where appropriate. We do not disclose data while a challenge we have raised is pending, unless the law requires us to.

• We disclose only the specific data, accounts and time period the request lawfully requires.
• Where a business is the controller of data we hold for it, such as an Omni business's conversations with its customers, we ask the authority to request the data from that business first, where the law allows.
• Messages in Olbongo chat are end-to-end encrypted; we do not hold the keys and cannot disclose their content.

We may disclose limited data without legal process when we believe in good faith that it is needed without delay to prevent death or serious physical harm to a person. Such a disclosure is limited to what the emergency requires, is reviewed and recorded like any other request, and the authority is asked to follow it with valid legal process.

Unless the law forbids it, or telling them would put someone at risk of harm, we notify the user or business whose data is requested before disclosing it, so that they can seek legal advice or object.

Every request is recorded with the date it was received, the requesting authority, its stated legal basis, the data requested, our assessment, the decision, any data disclosed, whether the person affected was notified, and who reviewed it. These records are kept securely, with access restricted to the people who handle requests, for at least five years.

Questions about this policy: privacy@olbongo.com. See also the Olbongo Privacy Policy and the Omni Privacy Policy.