政府与执法机关的数据请求

This document applies to the customer relationship management software-as-a-service platform, websites, applications, APIs, software, documentation, dashboards, reports, artificial intelligence features, support, and related services made available by SellioCRM, LLC, a limited liability company ("SellioCRM," "we," "us," "our").

This Policy describes how SellioCRM handles requests from public authorities, government agencies, law enforcement, and courts ("Government Requests") for personal data or personal information of users or customers, including data received from third-party platforms (such as Platform Data received from Meta) and Customer Content stored in the Services.

1. Guiding Principles

SellioCRM is committed to protecting the privacy of its customers and their data. We do not voluntarily provide personal data to public authorities. We disclose data in response to a Government Request only when we believe in good faith that disclosure is required by applicable law and the request is legally valid, or when disclosure is necessary to prevent imminent harm as permitted by law.

2. Required Review of Legality

Every Government Request received by SellioCRM is reviewed before any response. The review verifies, at a minimum: the identity and authority of the requesting body; the legal basis cited for the request; whether the request is properly scoped, signed, and served through a legally valid process; and whether SellioCRM is the correct recipient (in most cases the customer, as data controller, is the appropriate recipient). Requests that fail this review are rejected or returned to the requesting authority. Where appropriate, SellioCRM consults external legal counsel.

3. Challenging Unlawful or Overbroad Requests

If SellioCRM concludes that a Government Request is unlawful, invalid, overbroad, or inconsistent with applicable law (including data protection laws such as GDPR, LGPD, and CCPA), SellioCRM will challenge the request. Challenges may include: asking the authority to narrow or withdraw the request; requiring the authority to obtain a legally sufficient instrument; or contesting the request before a competent court where reasonably available. SellioCRM does not comply with requests that lack a valid legal basis.

4. Data Minimization

When disclosure is legally required, SellioCRM discloses only the minimum data necessary to comply with the specific, valid legal demand. We interpret requests narrowly, limit responses to the accounts, records, categories, and time ranges expressly and lawfully demanded, and do not provide direct or unrestricted access to systems or databases.

5. Customer Notification

Unless legally prohibited (for example, by a binding non-disclosure order), SellioCRM will notify the affected customer of a Government Request before disclosure, so the customer may seek protective measures. Where notification is temporarily prohibited, we provide notice when the prohibition expires.

6. Documentation and Record Keeping

SellioCRM documents every Government Request, including: the request itself and the requesting authority; the legal basis cited; the internal legality review and its conclusion; any challenge made and its outcome; the response provided, including the categories and scope of any data disclosed; the personnel and counsel involved; and relevant dates. These records are retained in accordance with our retention practices and applicable law.

7. National Security Requests

As of the date of this Policy, SellioCRM has not received any national security requests for user personal data. If such a request is received, it will be handled under this Policy, subject to the specific legal framework that applies to it.

8. Platform Data

Data received from third-party platforms (including Meta Platform Data such as access tokens, WhatsApp Business Account identifiers, and message payloads) is covered by this Policy and additionally by the terms of the relevant platform. SellioCRM applies this Policy to any Government Request that concerns Platform Data.

9. Contact

Public authorities may serve legally valid requests, and customers may direct questions about this Policy, to legal@selliocrm.com.

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