This Legal Requests Policy ("Policy") describes how Meridian S.A. ("Meridian", "Company", "we", "our", or "us") receives, reviews, and responds to lawful requests for information, records, or other assistance from competent governmental authorities.
Meridian is committed to protecting User privacy while complying with Applicable Law and legally binding requests issued by competent authorities.
This Policy should be read together with the Terms of Service, Privacy Policy, AML & Compliance Policy and Prohibited Use Policy.
1. Introduction
This Legal Requests Policy ("Policy") describes how Meridian S.A. receives, reviews, and responds to lawful requests for information, records, or other assistance from competent governmental authorities.
Meridian is committed to protecting User privacy while complying with Applicable Law and legally binding requests issued by competent authorities.
This Policy should be read together with the:
- Terms of Service
- Privacy Policy
- AML & Compliance Policy
- Prohibited Use Policy
2. Scope
This Policy applies to legal requests relating to Users, Accounts, Digital Assets, Transactions, or other information processed by Meridian.
The Policy applies regardless of whether Services are accessed through:
- Website
- Telegram Bot
- mobile applications
- APIs
- merchant interfaces
- business accounts
- future Meridian products
3. Types of Legal Requests
Meridian may receive requests including:
- court orders
- subpoenas
- search warrants
- production orders
- disclosure orders
- preservation requests
- freezing orders
- seizure orders
- regulatory requests
- requests from financial intelligence units
- other legally authorized requests
Each request is reviewed individually.
5. Submission Requirements
Legal requests should clearly identify:
- the requesting authority
- the legal basis for the request
- the specific information requested
- relevant account identifiers where available
- applicable deadlines
- appropriate contact information
Meridian may request clarification where a request is incomplete or ambiguous.
6. Emergency Requests
Where Meridian receives a request asserting that an emergency involving an imminent risk of death, serious physical harm, or other exceptional circumstances exists, Meridian may evaluate whether expedited action is appropriate.
Emergency requests should include sufficient information demonstrating the nature of the emergency and the legal basis for the request.
Submission of an emergency request does not guarantee immediate disclosure.
7. Preservation Requests
Meridian may receive requests to preserve existing records pending the issuance of further legal process.
Where appropriate and consistent with Applicable Law, Meridian may preserve relevant records for a reasonable period.
Preservation of records does not itself constitute disclosure of information.
8. User Notification
Where permitted by Applicable Law and where Meridian determines that notification would not:
- violate legal obligations
- interfere with an investigation
- compromise public safety
- breach a court order
- conflict with confidentiality requirements
Meridian may notify affected Users before or after responding to a legal request.
Meridian reserves the right to delay or withhold notification where legally required.
9. Confidentiality
Meridian treats legal requests and related communications as confidential to the extent permitted by Applicable Law.
Information relating to ongoing investigations may be disclosed only where legally authorized or required.
10. Review of Legal Requests
Meridian reviews each legal request individually before taking any action.
The review may consider:
- the legal authority of the requesting party
- applicable jurisdiction
- authenticity of the request
- scope of the requested information
- proportionality of the request
- applicable confidentiality obligations
- data protection requirements
- other applicable legal considerations
Meridian may request clarification or additional documentation before responding.
12. Requests That May Be Declined
Meridian may decline, limit, or seek clarification regarding requests that:
- lack an appropriate legal basis
- are overly broad or disproportionate
- contain insufficient identifying information
- conflict with Applicable Law
- conflict with data protection obligations
- are technically impossible to fulfill
- are submitted by persons lacking legal authority
Where appropriate, Meridian may invite the requesting authority to submit a revised request.
13. Information That May Be Disclosed
Subject to Applicable Law and the specific legal request, Meridian may disclose information including:
- account registration information
- identity verification information
- transaction records
- blockchain transaction identifiers
- account activity records
- communications with Users where legally required
- compliance records where disclosure is legally required
- records relating to Digital Asset Transactions
Disclosure will be limited to information that Meridian reasonably determines is legally required or authorized to disclose.
14. Information Not Generally Available
Meridian does not generally maintain or possess certain categories of information.
Depending on the Services used, Meridian may not possess:
- private keys belonging to external wallets
- passwords selected by Users
- recovery phrases
- communications occurring outside the Meridian Platform
- information not collected during onboarding or operation of the Platform
Meridian cannot disclose information that it does not possess or control.
15. Restriction of Accounts or Digital Assets
Where required by Applicable Law or a legally binding order, Meridian may:
- restrict access to an Account
- suspend withdrawals
- restrict deposits
- freeze Digital Assets
- prevent transfers
- delay execution of Transactions
- implement other legally required restrictions
Such measures may remain in effect until Meridian determines that the applicable legal obligation has been satisfied or otherwise no longer applies.
16. Preservation of Evidence
Where legally required or reasonably necessary to comply with Applicable Law, Meridian may preserve:
- account records
- transaction records
- blockchain-related records
- audit logs
- compliance records
- communications
- authentication logs
- operational records
Preservation of information does not imply wrongdoing by any User and does not necessarily result in disclosure to a requesting authority.
17. Response Time
Meridian seeks to respond to valid legal requests within a reasonable period, taking into account:
- the nature of the request
- legal deadlines
- operational complexity
- urgency
- applicable legal requirements
- availability of relevant records
Meridian does not guarantee response times and may require additional time where necessary to complete legal or technical review.
18. Costs and Reimbursement
Where permitted by Applicable Law, Meridian may seek reimbursement of reasonable costs associated with responding to extensive or unusually burdensome legal requests.
Such costs may include:
- document production
- data extraction
- forensic review
- technical analysis
- legal review
- secure transmission of records
Any reimbursement request will be determined on a case-by-case basis and in accordance with Applicable Law.
19. Cross-Border Cooperation
Meridian may receive legal requests relating to Users, Accounts, or Transactions involving multiple jurisdictions.
Where appropriate and consistent with Applicable Law, Meridian may cooperate with competent authorities through lawful international cooperation mechanisms.
Cross-border cooperation may be subject to:
- mutual legal assistance procedures
- recognition of foreign judicial orders
- international treaties
- applicable data protection laws
- conflict of laws principles
- other legal requirements
Meridian will assess each request individually before determining whether information may be disclosed.
20. Compliance with Applicable Law
Nothing contained in this Policy limits Meridian's obligation to comply with Applicable Law.
Where legally required, Meridian may:
- preserve records
- disclose information
- restrict Accounts
- restrict Digital Assets
- suspend Transactions
- implement court orders
- comply with sanctions obligations
- take other actions required by competent authorities
Where multiple legal obligations apply, Meridian will seek to comply with all applicable legal requirements to the extent reasonably possible.
21. Transparency
Meridian is committed to balancing:
- User privacy
- legal compliance
- operational security
- regulatory obligations
- protection of the Platform
Where permitted by Applicable Law, Meridian may publish aggregated or anonymized information regarding the volume or categories of legal requests received.
Publication of such information is entirely at Meridian's discretion and may be omitted where publication would conflict with legal obligations, confidentiality requirements, or operational security.
22. Relationship with Other Policies
This Legal Requests Policy should be read together with the following Meridian legal documents:
- Terms of Service
- Privacy Policy
- AML & Compliance Policy
- KYC Policy
- Digital Asset Custody Policy
- Digital Asset Risk Disclosure
- Digital Asset Loan Terms
- Digital Asset Loan Risk Disclosure
- Fees Policy
- Cookie Policy
- Prohibited Use Policy
- Complaints Policy
Where another Meridian policy specifically governs a particular subject matter, that policy shall apply together with this Legal Requests Policy.
23. Changes to this Policy
Meridian may amend this Legal Requests Policy from time to time to reflect:
- changes in Applicable Law
- judicial decisions
- regulatory developments
- operational improvements
- technological developments
- cybersecurity enhancements
- business developments
Updated versions become effective upon publication unless a later effective date is specified.
Where required by Applicable Law, Meridian will provide reasonable notice before material amendments become effective.
Continued use of the Platform following publication constitutes acceptance of the updated Policy.
24. Contact Information
Legal requests should be submitted through the official legal contact channels published by Meridian.
General customer support channels should not be used for the submission of court orders, subpoenas, preservation requests, or other legal process unless expressly directed by Meridian.
Questions regarding this Legal Requests Policy may also be submitted through Meridian's official communication channels.
25. Effective Date
This Legal Requests Policy is effective from the date stated above and remains in force until amended or replaced by Meridian S.A.
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