Transparency report

At Flexa, we are committed to protecting the privacy and security of our customers. From time to time, we receive requests from government agencies around the globe that seek customer data or other information about our business, such as details of our partners or internal programs and procedures.

Because we believe that our customers have a right to know how we manage their data, we now provide transparency reports on an annual basis. To the extent that we are able to disclose such information, these reports include a summary of the law enforcement and government agency requests we have received, our responses to those requests, and any related context surrounding the requests.

Requests we receive

We receive legal requests for information from various federal, state, and local government agencies in the jurisdictions where we operate. These requests may consist of subpoenas, audits, or other written inquiries, and in the United States, may also consist of national security letters or requests made under the Foreign Intelligence Surveillance Act or its amendments (“FISA”). Before responding to any such information request, we closely evaluate the request’s legality and underlying justification, and always seek to narrow or reject requests if we believe them to be overly broad or legally insufficient.

Worldwide

All information requests received from government agencies worldwide, excluding national security requests (separately reported under United States, below):

Government requests for customer data

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 3                 | 3                  | 1                                | 33%                                            |
| 2022             | 2                 | 13                 | 13                               | 100%                                           |
| 2021             | 0                 |                   |                                 |                                               |
| 2020             | 0                 |                   |                                 |                                               |
| 2019             | 0                 |                   |                                 |                                               |
| 2018             | 0                 |                   |                                 | 

Government requests for other information

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 2                 |                   | 2                                | 100%                                           |
| 2023             | 12                |                   | 12                               | 100%                                           |
| 2022             | 11                |                   | 11                               | 100%                                           |
| 2021             | 5                 |                   | 5                                | 100%                                           |
| 2020             | 1                 |                   | 1                                | 100%                                           |
| 2019             | 0                 |                   |                                 |                                               |
| 2018             | 0                 |                   |                                 | 

Canada

All information requests received from government agencies in Canada:

Government requests for customer data

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 0                 |                   |                                 |                                               |
| 2022             | 0                 |                   |                                 |                                               |
| 2021             | 0                 |                   |                                 |                                               |
| 2020             | 0                 |                   |                                 |                                               |
| 2019             | 0                 |                   |                                 | 

Government requests for other information

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 0                 |                   |                                 |                                               |
| 2022             | 0                 |                   |                                 |                                               |
| 2021             | 0                 |                   |                                 |                                               |
| 2020             | 0                 |                   |                                 |                                               |
| 2019             | 0                 |                   |                                 | 

El Salvador

All information requests received from government agencies in El Salvador:

Government requests for customer data

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 3                 | 3                  | 1                                | 33%                                            |
| 2022             | 1                 | 1                  | 1                                | 100%                                           |
| 2021             | 0                 |                   |                                 | 

Government requests for other information

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 5                 |                   | 5                                | 100%                                           |
| 2022             | 5                 |                   | 5                                | 100%                                           |
| 2021             | 0                 |                   |                                 | 

United States

All information requests received from government agencies in the United States, including those received via National Security Letters or under the authority of FISA:

Customer data

FISA Content requests

| Reporting period | Requests received | Accounts |
|------------------|-------------------|----------|
| 2023             | 0–499             | 0–499    |
| 2022             | 0–499             | 0–499    |
| 2021             | 0–499             | 0–499    |
| 2020             | 0–499             | 0–499    |
| 2019             | 0–499             | 0–499    |
| 2018             | 0–499             | 0–499

FISA Non-Content requests

| Reporting period | Requests received | Accounts |
|------------------|-------------------|----------|
| 2023             | 0–499             | 0–499    |
| 2022             | 0–499             | 0–499    |
| 2021             | 0–499             | 0–499    |
| 2020             | 0–499             | 0–499    |
| 2019             | 0–499             | 0–499    |
| 2018             | 0–499             | 0–499

National Security Letters requests

| Reporting period | Requests received | Accounts |
|------------------|-------------------|----------|
| 2023             | 0–499             | 0–499    |
| 2022             | 0–499             | 0–499    |
| 2021             | 0–499             | 0–499    |
| 2020             | 0–499             | 0–499    |
| 2019             | 0–499             | 0–499    |
| 2018             | 0–499             | 0–499

Government requests

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 0                 |                   |                                 |                                               |
| 2023             | 0                 |                   |                                 |                                               |
| 2022             | 1                 | 12                 | 12                               | 100%                                           |
| 2021             | 0                 |                   |                                 |                                               |
| 2020             | 0                 |                   |                                 |                                               |
| 2019             | 0                 |                   |                                 |                                               |
| 2018             | 0                 |                   |                                 | 

Other information

FISA Content requests

| Reporting period | Requests received |
|------------------|-------------------|
| 2023             | 0–499             |
| 2022             | 0–499             |
| 2021             | 0–499             |
| 2020             | 0–499             |
| 2019             | 0–499             |
| 2018             | 0–499

FISA Non-Content requests

| Reporting period | Requests received |
|------------------|-------------------|
| 2023             | 0–499             |
| 2022             | 0–499             |
| 2021             | 0–499             |
| 2020             | 0–499             |
| 2019             | 0–499             |
| 2018             | 0–499

National Security Letters requests

| Reporting period | Requests received |
|------------------|-------------------|
| 2023             | 0–499             |
| 2022             | 0–499             |
| 2021             | 0–499             |
| 2020             | 0–499             |
| 2019             | 0–499             |
| 2018             | 0–499

Government requests

| Reporting period | Requests received | Accounts specified | Requests where data was provided | Percentage of requests where data was provided |
|------------------|-------------------|--------------------|----------------------------------|------------------------------------------------|
| 2024 YTD         | 2                 |                   | 2                                | 100%                                           |
| 2023             | 7                 |                   | 7                                | 100%                                           |
| 2022             | 6                 |                   | 6                                | 100%                                           |
| 2021             | 5                 |                   | 5                                | 100%                                           |
| 2020             | 1                 |                   | 1                                | 100%                                           |
| 2019             | 0                 |                   |                                 |                                               |
| 2018             | 0                 |                   |                                 | 

About this data

These reports disclose counts of the requests received from government agencies around the world since Flexa was formed, as processed through Flexa’s internal system for receiving, tracking, and responding to such information requests. The data provided in these reports are summarized worldwide and at a country-specific level for each of the countries in which we operate.

We process and respond to all requests that we determine to have a valid legal basis. We process and challenge or reject any requests that we believe are overly broad or legally insufficient. Each request that we process, whether accepted, challenged, or rejected, is counted as one request. Amended requests submitted under separate legal process are counted as additional requests.

For national security requests that we receive in the United States, we report as much detail as legally allowed. Please note that, as required by law, the data we report on FISA requests is delayed by six months and reported only in ranges of 500.