Law Enforcement Requests

Should TITLEMAN Inc ever receive a request for customer data from a U.S. or non-U.S. law enforcement or government agency, TITLEMAN Inc will direct the requestor to contact the relevant customer directly to obtain the requested data. If the requestor refuses to contact the customer directly, TITLEMAN Inc’s policy is to notify the customer of any such request unless TITLEMAN Inc reasonably believes it is legally prohibited from doing so. In such cases, TITLEMAN Inc will use best efforts to request a waiver of the prohibition and will document that request. TITLEMAN Inc will notify the customer once the prohibition expires or has been lifted, with the aim of providing as much relevant information as reasonably possible.

TITLEMAN Inc will only disclose customer data or other customer information when required to do so in compliance with valid legal process. TITLEMAN Inc’s legal counsel will carefully review the legality of each such request and will challenge a request if there are reasonable grounds to consider it unlawful. If TITLEMAN Inc receives such a request from a non-U.S. law enforcement or government agency, TITLEMAN Inc will respond only through established legal mechanisms, such as a Mutual Legal Assistance Treaty request, letters rogatory, or a request by a qualifying foreign government as defined under the U.S. CLOUD Act, depending on the nature of the request.

When challenging a request, TITLEMAN Inc will seek interim measures with a view to suspending the effects of the request until it has been decided on its merits. TITLEMAN Inc will not disclose customer data or other information until required to do so under applicable law, and in such cases will provide only the minimum amount of information based on a reasonable interpretation of the request.