Operator and governing law
Tubaar is operated by Nevolut S.A.R.L.U. (Democratic Republic of Congo) together with its European Union branch Nevolut S.R.L. (Romania). The Service is governed by DRC law; personal data of people in the EU/EEA/UK is processed under the GDPR and the UK GDPR through our Romanian establishment. Legal process should be addressed to the entity appropriate to the requesting jurisdiction; where in doubt, to Nevolut S.R.L.
How to submit a request
Send requests in writing, on official letterhead, from an official government email domain, to legal@tubaar.com. Requests from personal email addresses are not processed. Include:
- the requesting agency, the officer's name, badge or ID number, and a direct contact;
- the legal authority for the request (statute, court order, warrant, subpoena, or equivalent) and a copy of the instrument;
- the account(s) concerned — handle (e.g. @handle), profile URL, or phone number; a video or Echo URL where relevant. Names alone are usually insufficient;
- the specific data requested and the date range;
- the case reference and, where the request is urgent, the reason.
We respond in English or French. Requests we cannot act on are answered with the reason.
What legal process is required
- Basic subscriber information (Section 5, first category): a valid subpoena, court order, or equivalent instrument from a competent authority.
- Account records and metadata (IP logs, login history, follow graph, timestamps): a court order or equivalent.
- Content (videos, Echoes, comments, messages, drafts if synced, live recordings held): a warrant or judicial order based on probable cause or the equivalent standard, issued by a competent court.
- Requests from outside the DRC and Romania should generally proceed through mutual legal assistance (MLAT), letters rogatory, or the EU e-Evidence framework where applicable. We may voluntarily act on foreign requests only in emergencies (Section 6) or where the law otherwise allows.
Preservation requests
On receipt of a valid preservation request from a law-enforcement agency, we preserve the existing account records and content for 90 days, extendable once by a further 90 days, pending receipt of legal process. A preservation request does not by itself result in disclosure. Preserved data is a snapshot; it does not capture later activity unless a new request is made.
What we may hold
Depending on how the member used Tubaar, we may hold, in ascending order of sensitivity:
- Basic subscriber information: phone number and/or email address used to register, country code, account creation date, handle and display name, date of birth, current account status, and whether the account is also used with Ontryst.
- Account activity records: IP addresses and timestamps of sign-ins and sessions, device type and app version, push-token metadata, approximate (city-level) location derived at sign-in or attached to videos, follower and following lists, Scenes joined, blocks and reports made or received, moderation history.
- Public content: videos, Echoes and the chains they belong to, sounds, captions, comments, Scene posts, profile — as visible on the platform, with upload timestamps and any city-level label the member chose.
- Private content: followers-only videos, Stories during their 24-hour window and archived Stories, direct messages and Scene chat messages, message requests, live recordings held for safety review (up to 30 days), reported content preserved for review.
- Payment records (if any): transaction confirmations from stores or processors, without full card numbers.
Limits: we do not hold passwords (sign-in is by one-time code); we do not hold a history of precise device locations; one-time codes are discarded within minutes; drafts remain on the device unless the member synced them; guest viewers have no account record beyond IP/device logs retained for up to 90 days.
Emergency disclosure
Where we believe in good faith that an emergency involving imminent risk of death or serious physical harm to a person — including a child — requires disclosure without delay, we may disclose the information necessary to prevent the harm, before or without formal legal process. Mark such requests "EMERGENCY" in the subject line to legal@tubaar.com and include a description of the emergency, the specific information needed and why it is needed now. Emergency requests are reviewed around the clock. Child-safety emergencies may also be sent to child-safety@tubaar.com.
Member notice
Our policy is to notify members of requests for their information before disclosure, and to give them an opportunity to challenge the request, unless we are legally prohibited from doing so, the request involves child exploitation, notice would create a risk of harm, or the matter is an emergency. Where a non-disclosure order expires, we may notify the member afterwards.
Content removal requests from authorities
Requests to remove or restrict content (as opposed to requests for data) are assessed first against our Community Guidelines; content that violates them is removed globally. Content that is lawful under the Guidelines but alleged to be illegal under local law is assessed for restriction in the relevant country only, on receipt of a valid order identifying the specific content and the legal basis. We record such restrictions in our transparency reporting.
Child safety
We report apparent child sexual abuse material to NCMEC and to competent national authorities proactively, as described in our Child Safety Standards. Agencies following up on a CyberTipline report should quote the report number.
Testimony, authentication and cost
Records are produced with a certificate of authenticity on request. We do not provide expert testimony. We may seek reimbursement of reasonable costs for responding to requests where permitted by law, and we reserve the right to do so for unusually burdensome requests.
Requests from members and civil litigants
Members can obtain their own data from Settings → Account → Download your data. We do not disclose member information in response to requests from private parties or civil litigants except under a valid court order served on Nevolut in a jurisdiction where we are established.
Contact and updates
Legal process, preservation and emergency requests: legal@tubaar.com. Child-safety matters: child-safety@tubaar.com. These Guidelines are for informational purposes, do not create rights for any party, and do not waive any objection we may raise. They should be read with our Privacy Policy and Terms of Service, and may be updated at any time.