Compliance and Law Enforcement Requests Policy

1. Introduction and scope

1. This policy explains how [LEGAL ENTITY NAME], trading as "lotivano" (the "Firm", "we", "us", "our"), approaches requests, orders, and demands it may receive from courts, regulators, law enforcement, and other authorities (each, a "Request").
2. It describes how we balance our duty to comply with valid legal obligations against our duties of confidentiality and the protection of legally privileged information. It forms part of, and should be read with, our Website Terms of Use and Privacy Policy.
3. This policy is a statement of general approach. It is not legal advice, and it does not expand or reduce any obligation imposed on the Firm by Applicable Law. Where Applicable Law or a valid court order requires a particular course of action, that requirement governs.

2. Definitions

"Request"

any request, subpoena, summons, warrant, production order, regulatory notice, or other demand for information, documents, or cooperation received from an authority.

"Authority"

a court, tribunal, regulator, law-enforcement body, or other public body with apparent power to make a Request.

"Privileged information"

information protected by legal professional privilege (or an equivalent protection) under Applicable Law.

"Confidential client information"

information relating to a client or a matter that is subject to the Firm's professional duty of confidentiality.

"Applicable Law"

the laws, regulations, and professional rules applicable to the Firm in the relevant [JURISDICTION].

3. Guiding principles

When we receive a Request, we are guided by the following principles, subject always to Applicable Law:

• Legality. We comply with valid legal obligations and respond to lawful Requests through proper channels.
• Verification. We take reasonable steps to verify the authenticity and authority behind a Request before responding.
• Protection of privilege and confidentiality. We assert and protect legal privilege and client confidentiality to the extent the law allows.
• Minimisation. We seek to provide no more than what is lawfully required.
• Transparency. We give notice to affected persons where we are lawfully permitted to do so.
• Accountability. We keep appropriate records of how Requests are handled.

4. Verifying authority

1. On receiving a Request, we seek to confirm the identity of the Authority, the identity and role of the person making it, and the legal basis relied upon.
2. We may ask for the Request to be put in writing, for a copy of any order or authorisation, and for clarification of its legal basis and scope, except where Applicable Law prohibits us from doing so.
3. We do not act on an unverified or apparently invalid Request. If authenticity or authority cannot be established, we will seek to clarify or, where appropriate, decline until it is, to the extent Applicable Law permits.
4. We treat informal approaches — such as a telephone call or an email that is not supported by appropriate documentation — with particular care, and we generally require an appropriately evidenced Request before disclosing anything, except where Applicable Law compels an immediate response.
5. We direct Requests to the appropriate person within the Firm for handling, so that they are assessed consistently and by someone able to consider the confidentiality and privilege issues they raise.

5. Reviewing scope

1. We review each Request to understand precisely what is sought, the legal basis, and whether it is specific, proportionate, and within the Authority's powers.
2. Where a Request appears overbroad, vague, or disproportionate, we may seek to narrow it, request clarification, or raise appropriate objections through proper channels before providing any response, to the extent Applicable Law permits.
3. We aim to respond only to what is lawfully required and within the proper scope of the Request.

6. Confidentiality and privilege

1. The Firm owes duties of confidentiality to its clients, and certain communications may be protected by legal professional privilege. These protections are fundamental and are asserted and preserved to the fullest extent permitted by Applicable Law.
2. We will not disclose privileged information in response to a Request unless privilege does not apply, has been validly waived by the client, or Applicable Law compels disclosure notwithstanding privilege. Where there is a genuine question about privilege, we will seek to resolve it through proper channels before disclosure.
3. Where a Request would require disclosure of confidential client information, we disclose only what is lawfully required and take reasonable steps to protect the remainder.
4. Where time and Applicable Law permit, and where doing so would not be unlawful or prejudice an investigation, we consider whether to consult the affected client before responding, so that any claim of privilege can be properly considered and, if appropriate, asserted or tested through proper channels.
5. The fact that information is held electronically, or by a service provider on the Firm's behalf, does not diminish these protections. We apply the same principles to information wherever and however it is stored.

7. Client identification and anti-money-laundering

1. The Firm may be subject to client identification, verification, record-keeping, and anti-money-laundering obligations under Applicable Law. Accepting or continuing a matter may depend on the satisfactory completion of those checks.
2. Where Applicable Law imposes a mandatory reporting obligation in connection with suspected money laundering or other financial crime, the Firm will comply with that obligation. Such obligations may, in defined circumstances, operate alongside or as an exception to the duty of confidentiality, as determined by Applicable Law.
3. The specific obligations, thresholds, and reporting routes depend on the applicable regime and must be confirmed: [AML / REPORTING FRAMEWORK].

8. Sanctions and export controls

1. The Firm is subject to Applicable Law concerning economic sanctions and, where relevant, export controls. The Firm will not act in a manner that breaches such measures and will take them into account when considering a matter or a Request.
2. Where a Request relates to sanctions or export-control matters, we will handle it consistently with this policy and the applicable measures. The relevant frameworks must be confirmed: [SANCTIONS / EXPORT-CONTROL FRAMEWORK, IF APPLICABLE].

9. Mandatory reporting

1. In certain circumstances, Applicable Law may require the Firm to make a report to an Authority and may restrict the Firm from informing the affected person that a report has been made ("tipping off"). Where such obligations apply, the Firm will comply with them.
2. Mandatory reporting obligations are preserved by this policy and are not limited or waived by any other statement on the Website. Nothing in this policy should be read as encouraging the Firm to withhold a report that Applicable Law requires.

10. Notice where permitted

1. Where we are lawfully permitted to do so, and it is appropriate, we will seek to notify a client or other affected person about a Request that concerns their information, so that they may take steps to protect their interests, including seeking to challenge the Request.
2. We will not give notice where Applicable Law or a valid order prohibits it, where doing so would prejudice an investigation or breach a legal obligation, or where it would otherwise be unlawful. In such cases, we comply with the restriction.

11. Data minimisation

1. When responding to a Request, we seek to disclose only the specific information that is lawfully required, and to avoid over-disclosure. Where feasible and lawful, we may redact information outside the proper scope of the Request.
2. We handle any information disclosed securely and in accordance with our Privacy Policy and Applicable Law, and we retain records of disclosures as described in section 15.
3. Where a Request is capable of being satisfied with less sensitive information — for example, a summary rather than a complete file, or data relating to a defined period rather than an entire history — we seek to provide the narrower response where that is lawful and adequate to the Request.

12. Cooperation where legally compelled

1. Where the Firm is legally compelled to provide information or cooperation — for example, under a valid court order or a binding statutory obligation — it will comply to the extent required by that obligation.
2. Cooperation in such circumstances is consistent with this policy and does not constitute a breach of confidentiality, because the disclosure is required by law. The Firm will nonetheless continue to protect privileged information and confidential client information to the extent the law allows, and will confine its compliance to what is lawfully required.
3. Nothing in this section requires or permits the Firm to disclose information that Applicable Law protects from disclosure, or to act contrary to a mandatory professional obligation.
4. Cooperation does not mean unquestioning compliance. The Firm may still seek clarification, raise legitimate objections, and insist that the proper legal basis and process are followed, even while ultimately complying with a valid and binding obligation.
5. Where a Request is directed to the Firm but concerns information held for, or belonging to, a client, the Firm will, so far as lawful, treat the client's interest in that information as a relevant consideration in deciding how to respond.

13. Challenging requests

1. Where there are proper grounds, the Firm may challenge, seek to narrow, or seek to set aside a Request through appropriate legal channels — for example, where a Request is invalid, overbroad, or seeks privileged information.
2. Any challenge is conducted in accordance with Applicable Law and, where relevant, in consultation with the affected client, subject to any restriction preventing such consultation.
3. The decision whether to challenge a Request is made in good faith and on proper grounds. The Firm does not challenge a valid Request simply to obstruct or delay a lawful investigation, and it will comply with the outcome of any process through which a Request is tested, upheld, or refined.
4. Where the cost or burden of responding to a Request is significant, the Firm may, where Applicable Law allows, seek a reasonable extension of time or discuss the practical scope of the response with the Authority, without compromising the protections described in this policy.

14. Emergency requests

We recognise that some Requests arise in genuine emergencies involving a risk to life or safety. In such cases we will act responsibly and consistently with Applicable Law, seeking to verify the Request as far as the circumstances reasonably allow while taking urgency into account. The existence of an emergency does not remove our duty to protect privileged information where the law so requires.

15. Records

We keep appropriate records of Requests received and how they were handled, including the steps taken to verify authority, review scope, protect privilege, and respond. These records are maintained in accordance with our Privacy Policy and Applicable Law, and support accountability and any later review.

These records allow the Firm to demonstrate, if later called upon to do so, that it acted lawfully and proportionately, and that it confined any disclosure to what was required. They also help the Firm identify patterns or recurring issues so that it can keep this policy and its internal procedures under review. Where a Request concerns a client matter, the existence and handling of the Request are, so far as lawful, treated as confidential to the same standard as other client information.

16. Complaints and rights

1. If you believe your information has been mishandled in connection with a Request, you may contact us using the details in section 18. We will consider your concern in accordance with our complaints process and Applicable Law.
2. You may also have rights to complain to a relevant supervisory authority or to seek a legal remedy. Any such authority must be confirmed before publication: [SUPERVISORY AUTHORITY / REGULATOR]. Nothing in this policy affects any non-waivable right you have under Applicable Law.

17. Changes to this policy

We may update this policy from time to time. The current version will be posted on this page with an updated effective date. Continued use of the Website after changes take effect constitutes acceptance of the revised policy.

18. How to contact us

Authorities and others wishing to make or discuss a Request, and individuals with a related concern, may contact legal@lotivano.example or write to [LEGAL ENTITY NAME AND ADDRESS]. Please observe the cautions in the Website Terms of Use before sending confidential information.