Law Enforcement Guidelines
How Miles responds to requests from law enforcement and government agencies for user information.
These Guidelines are a reference for law-enforcement officials seeking information from Miles Labs, Inc. (“Miles”). They are not intended for use by Miles users, civil litigants, or criminal defendants. For emergency requests, see Section 6.
1. Purpose and scope
These Guidelines explain how U.S. law-enforcement and government agencies may request information from Miles, and how Miles handles those requests. Miles is committed to protecting the privacy of its users while complying with valid legal process. Except in an emergency, where the affected user has consented, or as otherwise permitted by law, Miles requires valid and legally binding legal process that is properly served before it will disclose user information. Miles uses reasonable efforts to review all legal process for authenticity, facial validity, and legal sufficiency, and reserves the right to object to requests that do not comply with applicable law or that infringe its users’ rights, however, Miles does not guarantee accuracy or correctness of its assessment for any of the foregoing. These Guidelines are informational only; they do not create any rights or obligations, do not constitute legal advice, and do not waive any objection available to Miles or its users. Miles may update these Guidelines at any time without notice.
For the avoidance of doubt, Miles is required to comply with applicable laws and expressly reserves the right to take actions Miles reasonably deems necessary in order to comply with applicable laws.
2. About Miles and the information it may hold
Miles offers the Miles Plug — a device that plugs into a vehicle’s OBD-II port — and the Miles app, which help families understand driving, respond quickly to a crash, and, optionally, turn safe driving into insurance savings. The information Miles may hold about a user depends on the products and services they use, and may include account and identity information; vehicle information; and telematics data generated by the Device, including precise location (GPS coordinates and trip routes), trip history, driving events, vehicle diagnostics, and crash and safety records. Miles treats precise location and related telematics data as highly sensitive. Miles cannot guarantee that it holds any particular information for any given user or time period (see Section 5).
3. Serving legal process; what a request must include
Miles accepts service of valid legal process by email to legal@mileslabs.com. Miles will review and respond to law-enforcement requests submitted to this address. Miles does not provide a form; instead, all legal process must meet the requirements below.
The legal process itself must be:
- In PDF format and complete as issued by the court or competent authority;
- On government letterhead, or bearing a caption that identifies the issuing court and the case or docket number;
- Dated and signed by the issuing attorney or government official, or by a judicial officer, as applicable;
- Issued under the authority of a court with jurisdiction over Miles; and
- Addressed to Miles Labs, Inc.
Jurisdiction: legal process should generally be issued by a federal court or a state court in Delaware; process from a state court elsewhere may need to be domesticated in an appropriate jurisdiction.
The request must also identify:
- The specific user whose information is sought. A name alone is not sufficient; the request must include one or more identifiers, such as the account email address, phone number, account ID, vehicle identification number (VIN), or Device serial number;
- The specific categories of data requested (see Section 4) and the applicable date range;
- The legal basis for the request;
- How and to whom the responsive data should be produced; and
- The issuing agency and the requesting official, with contact information.
4. Information available, and the legal process required
Absent an emergency, user consent, or another lawful exception, the categories of information that may be available depend on the type of legal process served:
| Legal process | Information that may be available |
|---|---|
| Subpoena | Basic subscriber information (name, email, phone number, address, account-creation date, IP logs, and method of payment); and customer-support records. |
| Court order (e.g., 18 U.S.C. § 2703(d)) | The above, plus transactional metadata, service and app usage records, and billing records. |
| Search warrant (issued on probable cause) | The above, plus telematics and geolocation data (GPS coordinates, trip routes, and driving events), crash and safety records, and content (documents a user uploads, AI-assistant chat, and photos). Miles requires a search warrant for precise location and trip history. |
5. Data retention; no guarantee of data
Miles cannot guarantee that it will have any particular information for any given user or time period. Miles retains data in accordance with its Privacy Policy and its Data Retention and Deletion Policy; retention periods vary by data type (for example, raw precise location is retained for up to 12 months), and data may have been deleted before a request is received.
6. Emergency requests
Miles evaluates emergency requests on an expedited, case-by-case basis where an emergency involving an imminent threat of death or serious physical injury to a person exists. If law enforcement believes such an emergency exists, submit the request by email to legal@mileslabs.com with “Emergency Request” in the subject line, identifying the nature of the emergency, the person at risk, and the information needed. Miles will only review and respond to emergency requests from law enforcement; it will not respond to emergency requests sent to this address by others. Where Miles reasonably and in good faith believes disclosure is necessary to prevent the harm, it may voluntarily disclose the limited information necessary, consistent with applicable law.
7. Preservation requests
Upon a valid preservation request from law enforcement in connection with an official investigation, Miles will preserve a snapshot of available records associated with a specified account for 90 days, pending service of valid legal process, and will honor one request to extend preservation for an additional 90 days. It is the requesting agency’s responsibility to track the expiration date and to request any extension before it expires; if no extension is requested and no valid legal process is served before the period ends, the preserved information may be deleted. Preservation does not mean disclosure — preserved records are disclosed only pursuant to valid legal process or an emergency. Preservation requests must be on official law-enforcement letterhead, signed by a law-enforcement official, and must include the required user identifiers (Section 3) and a statement that steps are being taken to obtain legal process. Submit preservation requests to legal@mileslabs.com.
8. Notice to users
Miles’s policy is to notify users about requests for their information before disclosing it, so they have an opportunity to object, unless Miles is prohibited from doing so by law or court order, the request is an emergency involving risk of harm, or notice would be counterproductive (for example, a clear risk to a person’s safety, or of destruction of evidence or witness tampering, such as in child-exploitation cases). Law enforcement that believes notice would jeopardize an investigation should obtain an appropriate court order prohibiting notice, such as an order under 18 U.S.C. § 2705(b). Where a non-disclosure order is time-limited, Miles reserves the right to notify the affected user after it expires, unless otherwise prohibited by law.
9. Requests involving protected health care and other fundamental rights
Consistent with applicable law, Miles will not voluntarily provide location or other personal data, and will require valid legal process (and may require heightened process), in connection with any investigation or action seeking to impose liability for, or to prevent, lawful reproductive health care or gender-affirming health care, or other conduct protected under applicable law.
10. Witness testimony
Miles provides a business-records certification with its productions, which generally eliminates the need for live testimony to authenticate records. Miles does not provide expert-witness testimony.
11. User consent
Miles may disclose a user’s information to law enforcement with that user’s consent, or, for a minor, with the consent of the minor’s parent or legal guardian. Consent-based requests should be submitted to legal@mileslabs.com.
12. Scope of production; no bulk access
Miles produces only the specific records responsive to valid legal process. Miles does not provide bulk data, does not provide direct, automated, or ongoing access to its systems or to any user’s location or account, and does not build tools for surveillance. Miles may decline or move to limit any request that would require it to do so.
13. Cost reimbursement
Miles may seek reimbursement for the reasonable costs of searching for, assembling, and producing records in response to legal process, to the extent permitted by law.
14. Requests from outside the United States
Miles requires valid U.S. legal process. Requests from authorities outside the United States should be submitted through a U.S. legal-assistance channel (such as a mutual legal assistance treaty or letter rogatory) or other process recognized under U.S. law. Emergencies should follow Section 6.