Transparency Report

Our Commitment to Transparency

Clients.ai (operated by KC Meta Ventures, Inc.) is committed to transparency in how we handle government and law enforcement requests for user data. This Transparency Report provides detailed information about the number and types of legal requests we have received from government agencies, law enforcement, and regulatory authorities since our launch in 2022.

This report is published annually to ensure accountability and provide our users with visibility into government access to personal data processed through our platform. Transparency reporting is a key supplementary measure in our Transfer Impact Assessment (TIA) for international data transfers, particularly transfers to the United States.

About This Report

What We Report

This Transparency Report discloses information about legal requests for user data from:

• Government Agencies: Requests from government entities seeking access to user data for intelligence, surveillance, or administrative purposes
• Law Enforcement: Requests from police, federal law enforcement (FBI, RCMP, etc.), or investigative agencies seeking data for criminal investigations
• National Security Letters (NSLs): Administrative subpoenas issued by U.S. federal agencies (typically FBI) for national security investigations under the USA PATRIOT Act (18 U.S.C. § 2709)
• FISA Orders: Orders issued under the Foreign Intelligence Surveillance Act (FISA) by the U.S. Foreign Intelligence Surveillance Court (FISC) for foreign intelligence purposes, including FISA Section 702 orders
• Court Orders and Subpoenas: Judicially authorized orders or subpoenas issued by courts requiring disclosure of user data for civil or criminal proceedings
• Emergency Requests: Urgent requests from law enforcement in emergency situations involving imminent threat to life or serious bodily harm
• Regulatory Requests: Requests from data protection authorities, privacy regulators, or other government regulatory agencies for compliance investigations or audits

Reporting Scope and Limitations

Reporting Periods: This report covers cumulative data from our platform launch (January 1, 2022) through December 31, 2024. Future reports will be published annually covering each calendar year.

Gag Orders and Delayed Disclosure: U.S. National Security Letters and certain FISA orders may be accompanied by indefinite gag orders prohibiting disclosure of the request. If we receive such requests, we may be legally prohibited from reporting them immediately. We will disclose requests once gag orders are lifted or expire, if legally permissible.

Aggregation and Ranges: For future reports (if requests are received), we may report numbers in ranges (e.g., 0-249, 250-499) rather than exact counts, as required or permitted by applicable laws. Currently, with zero requests received, exact counts (0) are reported.

Detailed Request Breakdown (2022-2024)

Note: As of December 31, 2024, Clients.ai has not received any government data requests, law enforcement requests, national security letters, FISA orders, court orders, subpoenas, emergency requests, or regulatory data access requests from any jurisdiction worldwide.

Warrant Canary Status

Legal Framework and Data Protection Context

Schrems II and Transfer Impact Assessment (TIA)

Following the CJEU judgment in Schrems II (Case C-311/18), which invalidated the EU-US Privacy Shield, Clients.ai conducted a comprehensive Transfer Impact Assessment (TIA) to evaluate risks of government access to personal data transferred to the United States.

Key findings from our TIA regarding U.S. surveillance laws:

Our Data Request Policies and Procedures

How We Handle Government Requests

If we receive a government or law enforcement request for user data in the future, we are committed to the following principles and procedures:

Emergency Requests

We recognize that in rare emergency situations involving imminent threat to life or serious bodily harm, law enforcement may request expedited disclosure of user data without prior court authorization.

For emergency requests, we require:

• Good-faith representation by law enforcement that an emergency involving imminent danger of death or serious physical injury exists
• Specific description of the emergency and how the requested data is necessary to address it
• Commitment from law enforcement to obtain formal legal process (court order, subpoena) after the emergency
• Internal legal review and approval before disclosure (expedited where time-critical)

Emergency Request History (2022-2024): Zero emergency requests received.

Regulatory and Data Protection Authority Requests

In addition to law enforcement and government intelligence requests, data protection authorities and regulatory agencies may request information or access to data for compliance investigations, audits, or supervisory purposes.

Note: We cooperate fully with lawful requests from data protection authorities and regulatory agencies in accordance with our legal obligations under GDPR Article 31 (cooperation with supervisory authorities) and other applicable data protection laws.

Sub-Processor Transparency

Clients.ai engages third-party sub-processors (cloud infrastructure providers, AI model providers, payment processors, etc.) that may be subject to government requests in their respective jurisdictions. Our Standard Contractual Clauses (SCCs) with sub-processors require:

• Immediate Notification: Sub-processors must notify Clients.ai immediately upon receiving a government data request (unless legally prohibited by gag order)
• Challenge Obligation: Sub-processors must challenge overly broad, unlawful, or disproportionate requests before disclosure
• Transparency Reporting: Sub-processors must provide annual transparency reports or attestations regarding government requests

Future Reporting and Updates

Publication Schedule: Clients.ai will publish updated Transparency Reports annually covering the previous calendar year. Reports will be published in January of each year (e.g., January 2026 report covering 2025 data).

Material Changes: If we receive a significant government data request or experience a material change in government access patterns, we may publish interim updates to this report (subject to legal restrictions and gag orders).

Commitment to Improvement: We will continually evaluate and improve our transparency reporting based on industry best practices, legal developments, and user feedback. We advocate for legal reforms that enhance transparency and protect user privacy.

Questions and Feedback