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Assistance Guidelines

Last updated on: August 29, 2025

1. INTRODUCTION AND PHILOSOPHY OF COOPERATION

1.1. Purpose and Aim of the Guidelines. These Guidelines are intended for employees of law enforcement, judicial, and other authorised government bodies (“Law Enforcement Agencies”). Their purpose is to establish a unified, transparent, and predictable standard for requesting user information or data related to the use of our websites, including the main domain SmmPanelUS.com and all its associated subdomains (collectively, the “Sites”), except blog.smmpanelus.com and its associated subdomains, which are governed by their own separate policies, as well as all provided services (the “Service”). We are a company that takes its responsibilities seriously, and this document is an integral part of our commitment to transparency and accountability. We strive not only to prevent the use of our Service for illegal purposes but also to provide lawful assistance in the investigation of crimes that threaten public safety.

1.2. Balance of Obligations and Jurisdictional Priority. TokenSMM LLP (the “Company”) strictly observes the balance between protecting the privacy of our users, which is a fundamental right, and recognising the important role of law enforcement in ensuring public safety. All our actions regarding data disclosure are governed exclusively by the laws of the United Kingdom. This principle is applied uniformly to all requests, regardless of their origin, which ensures fairness, predictability, and non-discrimination. Our commitment to the rule of law means that we cannot and will not circumvent established legal procedures.

2. LEGAL BASIS AND MANDATORY LEGAL PROCESS

2.1. Company’s Jurisdiction. TokenSMM LLP is a limited liability partnership registered in England and Wales. We collect, store, and process data in strict accordance with UK law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. These laws impose strict obligations on us to protect personal data, which we rigorously adhere to.

2.2. Principle of Strict Legality. We disclose user data only upon receipt of a valid and legally binding document issued in accordance with applicable law. Informal requests, letters, or telephone calls are not grounds for providing data (except in emergency cases described in Section 9). This approach ensures that any disclosure of information is lawful, justified, and can be reviewed by a court, thereby protecting both the User’s rights and the integrity of the investigation.

3. MANDATORY REQUIREMENTS FOR ALL LEGAL REQUESTS

To ensure prompt and accurate consideration, all legal requests must strictly comply with the following requirements. Failure to meet these requirements will result in a delay or refusal to process the request, as we will be unable to verify its legitimacy.

  • Official Format: The request must be submitted on the official letterhead of the requesting authority, signed by an authorised official, and provided in PDF format. This is necessary to verify the authenticity of the document.
  • Identification of the Requesting Authority: The full name of the authority, the name, title, and position of the responsible officer, their contact email address on an official government/departmental domain, and a work telephone number. This information allows us to verify the authority of the requesting person.
  • Clear Account Identification: The unique and indisputable identifier of a user in our system is their email address. This requirement is necessary for accurate identification and to protect the privacy of other users. We are technically unable to search by name, surname, IP address, or a link from an order.
  • Detailed Description and Proportionality: The request must contain a specific list of the data being requested and the precise time period. In accordance with the principle of proportionality, we reserve the right to reject overly broad or vague requests (e.g., “provide all information on this user”).
  • Clear Statement of Legal Grounds: A reference to the specific article of the national law under which the request is made, and the criminal/administrative case number or court order number. This allows our legal department to assess the legality of the request.
  • Language of the Request: Requests must be made in English or accompanied by an official, certified translation into English to ensure accurate understanding and processing.

4. TYPES OF DATA AVAILABLE

As part of our commitment to the principle of data minimisation, we collect only the information necessary for the functioning of the Service. With the appropriate legal process, we may be able to provide:

  • Basic subscriber data: Email address and the date/time of Account creation.
  • Activity data (if available): IP addresses used to log in to the Account (stored for a limited time, typically no more than 90 business days), balance top-up history (without full payment details, only the amount, date, and transaction ID), Order history (date, service ID, target link).

Important: We do not collect and therefore cannot provide names, surnames, physical addresses, telephone numbers, or full bank card details of users. Our architecture is designed from the outset to minimise the collection of personal data.

5. REQUESTS FROM UK LAW ENFORCEMENT AGENCIES

We respond fully and promptly to valid and legally binding requests (e.g., court orders for disclosure, warrants) issued by authorised bodies in accordance with the laws of England and Wales.

6. INTERNATIONAL REQUESTS: PATHWAYS FOR COOPERATION

We recognise the global nature of crime and offer several internationally recognised legal pathways for foreign law enforcement agencies to obtain data.

6.1. Requests via Mutual Legal Assistance Treaty (MLAT). The primary and preferred mechanism is to submit a request through the procedure established by a Mutual Legal Assistance Treaty (MLAT), if such a treaty exists between the United Kingdom and the requesting authority’s country. This is the most reliable and legally correct path, ensuring respect for the sovereignty and legal norms of both countries.

6.2. Letters Rogatory. In the absence of an MLAT, law enforcement agencies can use the letters rogatory procedure. This is a formal request from a court in one country to a court in another country for assistance in obtaining evidence.

6.3. Restrictions Regarding UK Subjects. In accordance with our data protection obligations, requests from foreign states regarding individuals who are UK subjects are subject to rigorous scrutiny. Disclosure of such users’ data is possible exclusively based on an official request received through MLAT mechanisms or a direct court order issued by a competent UK court. Our assistance to foreign law enforcement agencies primarily concerns investigations into their own citizens or residents.

7. SPECIAL PROCEDURES AND PRINCIPLES FOR SPECIFIC JURISDICTIONS

7.1. Special Procedures for US Law Enforcement. We recognise the existence of special agreements, such as the UK-US CLOUD Act Agreement. Requests from federal, state, or local US law enforcement agencies based on current legislation (e.g., a warrant issued under 18 U.S.C. § 2703) will be reviewed for compliance with both US and UK laws, which allows for more expeditious cooperation.

7.2. Procedures for Jurisdictions without Special Agreements. For countries with which the UK does not have existing MLATs or special agreements, we offer the following pathways:

  • Recognition and Enforcement by a UK Court: A foreign warrant or court order can be presented to a competent court in England and Wales to have it recognised and converted into a local court order compelling us to disclose the data.
  • Consideration based on the principle of dual criminality (see section 7.3).

7.3. The Principle of Dual Criminality as a Basis for Assistance. In exceptional cases, the Company, at its sole discretion, may provide a limited amount of data in response to a direct request if the act under investigation is a serious crime in both the requesting country and the United Kingdom. This mechanism is designed to facilitate the investigation of the most serious offences recognised as such by the international community.

Examples of such crimes include, but are not limited to, the following categories:

  • Crimes threatening life and public safety:
    • Terrorism and related activities: Planning, financing, recruiting for terrorist acts, as well as public incitement to commit terrorist activity or public justification of terrorism.
    • Human trafficking and the use of slave labour: Any actions related to the recruitment, transportation, transfer, harbouring, or receipt of persons by means of the threat or use of force, for exploitation.
  • Serious crimes against children:
    • Creation, distribution, and possession of Child Sexual Abuse Material (CSAM):We have a zero-tolerance policy for any activity related to the sexual exploitation of minors. This includes not only real but also generated or simulated materials.
  • Serious cybercrimes:
    • Attacks on critical infrastructure: Actions aimed at disrupting or shutting down life-support systems, such as power grids, hospitals, financial systems, transport hubs, and government information systems.

Mandatory Conditions: The request must meet all the requirements of Section 3, and we must have a strong reason to believe that the User is a resident of the requesting country. The decision to apply this principle is made by our legal department on a case-by-case basis.

7.4. Refusal to Consider Other Direct Requests. Direct requests that do not comply with the procedures described above will not be considered or fulfilled.

8. DATA PRESERVATION REQUESTS

We accept official requests from law enforcement agencies to preserve data for a period of 90 business days in connection with an ongoing official investigation. The request must comply with the requirements of Section 3. This mechanism enables law enforcement agencies to obtain the proper legal instrument for disclosure without concern that the data will be deleted during standard procedures. We will retain a temporary copy of the available data, but will not disclose it until a formal legal document is received.

9. EMERGENCY REQUESTS (THREAT TO LIFE AND HEALTH)

In exceptional cases where we have a good faith belief that there is an imminent threat of death or serious physical harm, we are prepared to act immediately. We may disclose a limited amount of information necessary to prevent the threat. The request must contain a detailed description of the emergency. We expect that such a disclosure will be followed by the proper legal process.

10. VOLUNTARY DISCLOSURE OF INFORMATION

We reserve the right, on our own initiative, to report to the relevant law enforcement agencies any activity or content discovered on our Service that we believe may indicate the preparation or commission of a serious crime, particularly those related to child exploitation (CSAM) or terrorism.

11. USER NOTIFICATION POLICY

Our default policy is to respect user privacy. However, we will not notify a user of a request if it is expressly prohibited by law or a court order, or if we have a good faith belief that such notification could create a real risk to life, lead to the destruction of evidence, or otherwise obstruct justice.

12. CONTACT INFORMATION

All legal requests must be sent to the dedicated email address reserved exclusively for law enforcement agencies. This ensures timely processing by competent staff.

Email: legal-smmpanelus@tokensmm.org

Requests sent through other channels (e.g., to general customer support) will not be considered.