Law Enforcement Guidelines
Last updated: August 30, 2026 · Official Legal Guidelines
These guidelines explain how law enforcement authorities can request information from HubbaBaba, the legal process we require, and what to expect when you submit a request. HubbaBaba is committed to the safety of our members and to cooperating with valid legal requests, while also protecting the privacy rights of our users under applicable law.
Operating Entity: HubbaBaba is operated by JMP, an independent sole trader (autónomo) established in Spain (VAT/NIF ES46989635Z) Capità Mirambell 22, 08320 el Masnou, Spain. Because our operator is established in Spain and stores certain user data in the United States, requests may be subject to Spanish law, European Union law, United States law, or a combination of these, depending on the data sought and the requesting authority.
This page is not legal advice and does not waive any rights or objections available to HubbaBaba or our users. We reserve the right to object to, narrow, or decline any request that does not comply with applicable law.
How to submit a request
All law enforcement requests must be submitted in writing and on official letterhead of the requesting agency, signed by an authorized officer or official.
Postal Mail
Formal physical service
JMP (HubbaBaba)
Attn: Legal / Law Enforcement Response
Capità Mirambell 22, 08320 el Masnou, Spain
Please include the following in every request:
- The name, agency, badge or ID number, and official contact details of the requesting officer
- A direct agency phone number and official (government-domain) email address for verification
- The legal authority for the request (for example, the judicial authorization, court order, warrant, or production order attached)
- The specific HubbaBaba account identifiers at issue — a username, registered email address, phone number, or account ID. Requests that do not identify a specific account with reasonable particularity cannot be processed.
- The specific categories of records sought and the relevant date range
- Any applicable deadline and, if urgent, the reason for urgency
We cannot act on requests that are incomplete, that fail to identify an account, or that seek records we do not maintain.
Legal process we require
The type of legal process required depends on the category of data requested and the jurisdiction of the requesting authority. We disclose user data only where we are legally permitted or required to do so.
Requests from Spanish and EU authorities
As a sole trader established in Spain, we are subject to Spanish law and to European Union law, including the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Spain’s Organic Law 3/2018 (LOPDGDD). Under Spanish criminal procedure (Ley de Enjuiciamiento Criminal), access to electronic communications data generally requires authorization from a competent judicial authority (an investigating judge). As a general matter:
- Subscriber / identification data: May be sought through valid legal process from a competent authority.
- Traffic, log, and content data: Generally require authorization from a competent judicial authority.
Judicial authorities in other EU Member States may seek data through a European Investigation Order (EIO) (Directive 2014/41/EU) or, where applicable, a European Production or Preservation Order under Regulation (EU) 2023/1543. We will assess and respond to such orders in accordance with the applicable EU framework and any implementing national law.
Requests from United States authorities
Because certain user data is stored in the United States (Council Bluffs, Iowa), requests from U.S. authorities are also evaluated under the U.S. Stored Communications Act (18 U.S.C. § 2701 et seq.). As a general matter:
- Basic subscriber information (for example, name, email address, account creation date, IP address at sign-up) may be sought with a valid subpoena.
- Non-content transactional and log records generally require a court order under 18 U.S.C. § 2703(d) or an equivalent order.
- The contents of communications (for example, message content) require a valid search warrant issued on a showing of probable cause by a court of competent jurisdiction.
Requests from authorities outside the EU and the United States
HubbaBaba serves members worldwide, but we are not able to respond directly to legal process issued by authorities outside of the European Union and the United States. Foreign authorities should generally proceed through a Mutual Legal Assistance Treaty (MLAT), letters rogatory, or another recognized channel of international legal cooperation so that a valid Spanish, EU, or U.S. legal instrument can be issued. We may, at our discretion and where permitted by law, respond to foreign requests that are accompanied by legal process enforceable in Spain.
Emergency disclosure requests
Imminent Harm or Danger
If we receive a request from a law enforcement authority based on a good-faith belief that there is an emergency involving an imminent risk of death or serious physical harm to any person, we may voluntarily disclose information necessary to prevent that harm, to the extent permitted by applicable law. Under the GDPR, this may include disclosures necessary to protect the vital interests of the data subject or of another natural person (Article 6(1)(d)). For data stored in the United States, the emergency provisions of 18 U.S.C. § 2702 may also apply.
To submit an emergency request, email [email protected] with “EMERGENCY DISCLOSURE REQUEST” in the subject line and include:
- The nature of the emergency and the specific harm you are seeking to prevent
- Why the situation is imminent and why the information is needed to address it
- The specific account(s) and information required
- Verifiable official contact details for the requesting officer
We review emergency requests as quickly as we reasonably can. Submitting a request does not guarantee disclosure; we assess each request on its facts and disclose only what we believe in good faith is necessary to address the emergency.
Preservation requests
We will honor valid requests to preserve records in connection with an active investigation, consistent with applicable law. For data stored in the United States, this includes preservation under 18 U.S.C. § 2703(f). Within the EU, we will act on a European Preservation Order where applicable. A preservation request must identify the specific account and be sent to [email protected].
Preservation captures a snapshot of the records we hold at the time we process the request; it does not compel disclosure. To obtain preserved records, you must still serve appropriate legal process. Preservation is maintained for 90 days and may be extended by a renewed request. Because of our data retention practices (see Section 6), records not covered by a timely preservation request or legal process may be deleted in the ordinary course and cannot be recovered.
Information we may be able to provide
Subject to valid legal process and to what we actually hold at the time of the request, HubbaBaba may maintain some or all of the following:
- Subscriber / account information: registered name, email address (including email verification timestamp and status), phone number (if provided), and account creation date
- Profile information: the details a user has entered in their public or private profile
- Message content: subject to our retention period (see Section 6)
- Log and device data: IP addresses, timestamps, and device or app information associated with account activity
- Account status and moderation history: records relating to reports, safety actions, or account suspensions
Information we generally do not hold
- Identity-verification selfies / biometric images: HubbaBaba uses a third-party service to confirm that a profile photo matches a live selfie. Verification images are deleted immediately after the check is completed and are not retained. We therefore cannot produce verification selfies or associated biometric data.
- Full payment card details: Payments and subscriptions are processed by our authorized platform providers — the Apple App Store for iOS subscriptions and Google Play Store for Android subscriptions (or Stripe for select web transactions). HubbaBaba does not store complete payment card numbers. Law enforcement seeking full payment records, cardholder details, or financial transaction logs may need to direct a separate subpoena or legal request to Apple Inc., Google LLC, or Stripe Inc.
We can only provide records that exist and that we maintain in the ordinary course of business. We are not obligated to create records, and we do not have data that has already been deleted under our retention schedule.
Data retention
HubbaBaba retains data only as long as needed for the purposes for which it was collected, unless a longer period is required by law or a valid preservation request or legal process. In general:
Account and message data
Retained for approximately 30 days following deletion or the relevant activity.
Safety and moderation records
Retained for approximately 3 years.
Because retention periods are limited, we strongly encourage law enforcement to submit a preservation request promptly where records may be relevant to an investigation.
User notice
Our policy is to notify affected users about requests for their information before disclosure, so that they may have an opportunity to object, unless we are prohibited from doing so by law or court order, or where we determine in good faith that notice would be counterproductive (for example, where there is a risk of danger to an individual, a risk to a child, destruction of evidence, or witness intimidation). Where we have delayed notice due to a legal prohibition, we may notify the user once that prohibition expires.
If your request seeks to prevent notice to the user, please cite the specific legal basis (for example, a non-disclosure order or statutory prohibition) in your request.
Authentication and cost
We take steps to verify that requests are genuine and originate from a legitimate law enforcement authority, including confirming officer identity and agency contact details through official channels. Requests that cannot be authenticated will not be processed.
Where permitted by applicable law, we reserve the right to seek reimbursement for reasonable costs incurred in responding to a request.
No waiver
Nothing in these guidelines is intended to, and nothing should be read to, waive any objection or legal right available to HubbaBaba or to our users, or to expand or limit any obligation we may have under applicable law. We may update these guidelines at any time.
Legal & Law Enforcement Contact
JMP (HubbaBaba)
Independent sole trader — VAT/NIF ES46989635Z
Legal / Law Enforcement Response
Capità Mirambell 22, 08320 el Masnou, Spain
Email: [email protected]