Purpose
These guidelines explain how Minutes Network FZ-LLC handles requests for information from law enforcement, regulators and other public authorities, and how anyone can report abuse of the Platform. They are for information and do not waive any right we or our members have.
What records may exist
PacketExchange is a wholesale platform. Many of the calls and messages we carry are for businesses serving their own customers, so we may not know who the end user is. Depending on the account and the features it uses, we may hold:
- account details: name, email address, company, phone number, country and tax details, as given to us;
- payment records: top-ups, withdrawals, wallet addresses, blockchain transaction IDs and payout bank details;
- sign-in and API activity: IP addresses and times;
- call and message records: calling and called numbers, caller ID, times, duration, route and IP addresses;
- the text of SMS messages sent or received through the Platform;
- call recordings and voicemails, only where the account holder turned them on for a number, and only until deleted;
- signalling traces for calls made in the last 7 days.
We do not listen to calls, and we do not record calls or keep call audio unless the account holder has turned on recording or voicemail for their number.
How long records are kept
| Record | How long we keep it |
|---|---|
| Signalling traces for each call | 7 days, then deleted automatically |
| API request logs | 90 days, then deleted automatically |
| Call recordings and voicemails | The period the member sets for each number (30 days by default), then deleted automatically |
| Call and message records | While needed for billing, disputes, fraud prevention and legal obligations |
| SMS message content | While the member’s account is open, and after closure until deleted on request |
| Account details | While the account is open. Name, email address, company, phone number and country are removed when it is closed |
| Financial records | For as long as tax and accounting law requires, including after the account is closed |
| Website visit statistics (page, referring site, campaign, country, device type) | 13 months, then only as daily totals that identify no one |
| Visitor ID records, if you allowed Analytics | 13 months after your last visit, then deleted automatically |
| Where an account came from (signup campaign, country and device type, and ad click IDs if you allowed it) | For as long as the account record exists |
| Product analytics: the pages you opened in your account, time on each, buttons clicked and errors you hit | 90 days, then deleted automatically |
| Product analytics session summaries (start and end page, time spent, counts of clicks and errors, device type, country) | 13 months, then deleted automatically. Daily totals per page that identify no one are kept |
On receiving a preservation request that identifies specific records, we preserve them for 90 days while you obtain legal process, and we can extend this on request. Preserved records are copied to a separate store, so normal deletion, by us or by the account holder, does not affect them. Signalling traces are deleted after 7 days, so send preservation requests for them promptly.
Making a request
Send requests to legal@packetexchange.io from an official email address. Each request should:
- identify the requesting authority and officer, and how we can verify them;
- state the legal basis, with the legal process attached, such as a court order, warrant or production order;
- identify the phone numbers, account, IP addresses or other identifiers concerned;
- describe the records sought and the time period, as narrowly as possible.
We require legal process that is valid in a jurisdiction that applies to us before disclosing account or traffic records, and a court order, warrant or equivalent before disclosing message content or recordings. We may challenge requests that are unclear, too broad or not legally valid. Minutes Network FZ-LLC is established in the United Arab Emirates, so authorities in other countries should generally use mutual legal assistance or other international procedures.
We check that every request is genuine before acting on it, including by contacting the requesting authority through contact details we find independently, not those given in the request. We reply with a reference number to quote in all later correspondence.
How we produce records
Records are produced only after a second member of our team has reviewed and approved the release. They are sent as a ZIP archive of CSV files, with any recordings as audio files and a cover note listing the request, the subjects, the period and each file. We keep a SHA-256 fingerprint of every archive we release and can confirm it on request. Archives are delivered to the official address or secure portal of the requesting authority.
Emergencies
If a request involves an imminent risk of death or serious physical injury, put “EMERGENCY” in the subject line, describe the emergency and explain how the information will help prevent harm. We review emergency requests as a priority and may disclose information without legal process where the law allows.
Telling account holders
We tell account holders about requests for their data before disclosing it, so they can seek legal advice, unless the law or a court order forbids it, telling them would put someone at risk, or the account exists only to commit fraud.
Reporting abuse
Anyone can report fraud, scam calls or messages, unlawful robocalls or other abuse involving numbers or traffic on the Platform. Email abuse@packetexchange.io with:
- the phone numbers involved, including the caller ID you saw;
- the date, time and time zone of each call or message;
- what happened, with screenshots or recordings if you have them.
We investigate credible reports and act under our Acceptable Use Policy, which can mean blocking numbers and closing accounts. Carriers and the Industry Traceback Group can send traceback requests to the same address.
Contact
- Legal notices and law enforcement requests
- legal@packetexchange.io
- Privacy and support
- support@packetexchange.io
- Abuse reports
- abuse@packetexchange.io