passings.io/legal/law-enforcement
This page is intended for law enforcement and government agencies seeking user records from Passings. It describes the legal process Passings accepts, what we produce in response, and how we handle user notification. If you are a user looking for information about your data, please see our Privacy Policy at passings.io/privacy.
Scope. Records produced in response to legal process cover all Passings surfaces — passings.io, app.passings.io, and the mobile applications — associated with the account named, unless the request specifies a narrower subset.
How to Contact Passings
Primary contact: [email protected]
For emergency disclosure requests involving imminent danger of death or serious physical injury under 18 U.S.C. §2702(b)(8) and §2702(c)(4), please include “EMERGENCY” in the subject line. This mailbox is actively monitored.
Mailing address:
Passings LLC
c/o Legal Department
2501 Chatham Rd, Suite R, Springfield, IL 62704
Passings does not accept legal process through social media, support channels, or other informal means.
What We Require
Passings responds to valid legal process issued by United States courts, government agencies, and law enforcement authorities. To request records from Passings, you must provide:
Authenticating process — a subpoena, search warrant, court order, or National Security Letter issued by competent authority. We verify authenticity before responding.
Agency identification — official letterhead, requesting agent’s name, badge or ID number, and contact information.
Specific user identification — the account email address or another specific identifier sufficient to locate the user’s records (Passings accounts have no usernames). Overbroad requests will require narrowing.
Scope of request — clear description of the records sought, the time period, and the legal basis for the request.
Compliance with applicable law — the request must comply with the Stored Communications Act (18 U.S.C. §2701 et seq.), the Fourth Amendment, and other applicable federal and state law.
We will not respond to requests that fail to meet these requirements.
What We Can Produce
The type of legal process required depends on the type of records sought. Categories below reflect our understanding of applicable law.
Subscriber Information (Subpoena)
Basic subscriber information may be produced in response to a properly issued subpoena. Subscriber information includes: email address, name (as recorded in the account, where the user has provided one — registration itself collects only an email address and an authentication credential (a password or a Google sign-in)), account creation date, last login timestamp, IP addresses associated with the account, and billing information.
Transactional Records (Court Order under 18 U.S.C. §2703(d))
Non-content transactional records may be produced in response to a court order issued under 18 U.S.C. §2703(d) or a search warrant. Transactional records include: connection logs, session metadata, delivery records for platform-generated emails and Legacy Content deliveries (without content), and records of actions taken within the account (creation dates, modification logs). Passings offers no user-to-user messaging, so no message-exchange records exist.
Content of Communications and User Files (Search Warrant)
The content of plan data, vault documents, media library content, Legacy Content, and any other stored user content requires a search warrant issued upon probable cause. Passings will not produce user content in response to a subpoena or §2703(d) order alone.
Zero-Knowledge Encrypted Documents
Passings operates an optional zero-knowledge encryption feature for the document vault. Documents stored with zero-knowledge encryption are encrypted with a random per-plan key that is wrapped by two independent user credentials — the user’s vault password and a one-time recovery key generated when the feature is enabled. Passings holds neither credential and stores only the wrapped forms of the key; Passings cannot decrypt user content encrypted under zero-knowledge encryption in response to any request or order. In response to a search warrant for zero-knowledge encrypted content, Passings can produce only the encrypted ciphertext and associated metadata. Decryption requires the user’s vault password or the user’s recovery key.
Preservation Requests
Passings accepts preservation requests under 18 U.S.C. §2703(f). To submit a preservation request, send a written request to [email protected] identifying the specific user account and the records to be preserved. Passings will preserve identified records for ninety (90) days from receipt of the request, which may be extended by one additional ninety (90) day period upon written renewal request.
A preservation request alone does not require Passings to produce records; additional legal process is required before production.
Emergency Disclosure Requests
In emergency circumstances involving danger of death or serious physical injury, Passings may disclose content to law enforcement as permitted by 18 U.S.C. §2702(b)(8), and non-content records as permitted by §2702(c)(4), without a subpoena, warrant, or court order. To submit an emergency request:
Email [email protected] with “EMERGENCY” in the subject line.
Include a written certification that an emergency involving danger of death or serious physical injury to a person requires disclosure without delay.
Specify the records sought and the user identifier.
Provide contact information for follow-up.
Passings will endeavor to respond promptly to emergency requests, and ordinarily does so within 24 hours of verification of the emergency circumstances. We may request additional information to verify the nature of the emergency.
Passings does not treat urgency or time pressure in an ongoing investigation as an emergency. Emergency disclosure is reserved for situations where delay would risk imminent harm.
Attorney-Category Records — Heightened Protection
Passings applies heightened protections to any records reflecting a Consumer’s inquiry to an attorney participating in the Passings marketplace. These records may be subject to attorney-client privilege or equivalent professional-conduct confidentiality protections, including Illinois Rule of Professional Conduct 1.6 (as amended effective July 1, 2025), which extends confidentiality protections to communications facilitated through an Intermediary Connecting Service.
When Passings receives legal process requesting attorney-category records, Passings will:
Scrutinize the request with particular care, including by confirming that the requesting authority has provided the legal basis for the disclosure;
Identify whether the records sought may be subject to attorney-client privilege or Rule 1.6 confidentiality protections and, where relevant, raise those protections in any response;
Endeavor to notify both the affected Consumer and the affected attorney Provider of the request whenever legally permitted, ordinarily providing each with sufficient time and information to seek to quash or modify the request;
Consider whether to challenge the request on confidentiality grounds, in consultation with counsel; and
Withhold privileged materials absent an order specifically directing their production.
These protections apply in addition to, and not in lieu of, the user-notification and legal-process safeguards described elsewhere on this page.
User Notification
Passings’ practice is to notify users of legal requests for their account information, except where:
A court order, subpoena, or statute prohibits notification.
A law enforcement agency has certified that notification would impede an ongoing investigation.
The request is made under a National Security Letter that includes a nondisclosure requirement.
Providing notification would risk harm to an individual.
When notification is permitted, Passings provides the affected user with the notice and with a copy of the legal process (with law-enforcement-sensitive details redacted where appropriate), at least 14 days before producing records, to allow the user to contest the request.
Law enforcement may request a specific delay of user notification by providing written certification of the grounds. Passings evaluates such requests based on the specific circumstances.
International Requests
Passings is a United States company operating under U.S. law. International law enforcement agencies seeking records should submit requests through established legal channels:
Mutual Legal Assistance Treaty (MLAT) requests routed through the U.S. Department of Justice Office of International Affairs.
Letters rogatory through U.S. courts.
The CLOUD Act for qualifying jurisdictions with Executive Agreements under 18 U.S.C. §2523.
Passings does not respond to direct requests from foreign law enforcement agencies absent process through these channels. Foreign courts do not have direct jurisdiction to compel Passings to produce records.
Fees
Passings does not charge fees for responding to legal process. If compliance with a particularly burdensome request requires significant engineering or data extraction effort, we reserve the right to negotiate cost reimbursement under applicable law.
Transparency
Passings may publish aggregated statistics about law enforcement requests in a future transparency report. This report, when published, will include the number of requests received, the number fulfilled, and general category information, without disclosing identifying details of any specific user or investigation.