Government & Legal Requests Policy

1. Scope

This policy covers requests for user data or account information from law enforcement agencies, regulatory bodies, courts, and other government authorities (collectively, "government requests"). It applies to data held by Bookify Malta as a controller and as a processor on behalf of salon owners.

2. What we require

Before disclosing any user data, we require:

• Maltese court order or other judicial authorisation issued by a Maltese court; or
• Binding legal process under Maltese law (e.g. a production order under the Criminal Code, a regulatory notice with statutory authority, or an order from the Information and Data Protection Commissioner); or
• Mutual legal assistance treaty (MLAT) request routed through the Maltese authorities, for requests originating outside Malta.

We do not accept voluntary disclosure requests, informal letters, or requests made solely by email or telephone without accompanying legal documentation.

3. Emergency requests

In cases involving an imminent threat of death or serious physical injury, we may voluntarily disclose limited information to law enforcement without waiting for formal process. We will document the basis for the emergency disclosure and, where possible, seek retrospective authorisation. We will notify the affected user after the emergency has passed unless notification would compromise an ongoing investigation.

4. User notice

Our policy is to notify affected users before disclosing their data in response to a government request, unless:

• We are legally prohibited from doing so (e.g. by a gag order or non-disclosure provision in the legal process);
• Notification would create an imminent risk of death or serious physical injury;
• Notification would compromise an ongoing criminal investigation; or
• The request relates to a child safety matter where notification could endanger a child.

Where we are prohibited from providing prior notice, we will notify the user after the prohibition expires unless we are still legally prevented from doing so.

5. Data minimisation and scope

We disclose only the data specifically required by the legal process. If a request is overly broad, we will seek to narrow it before complying. If the request covers data that belongs to a salon’s clients (where the salon is the controller), we will, where possible, direct the requesting authority to the salon and limit Bookify’s role to that of a processor complying with a legal obligation.

6. Cross-border requests

Bookify Malta is based in Malta and governed by Maltese law. Requests from authorities outside Malta should be routed through the appropriate mutual legal assistance channels. Foreign court orders that are not domesticated in Malta through an MLAT or equivalent process will not be treated as binding legal process under this policy. We will, however, review each request on its merits and may voluntarily comply where consistent with Maltese and EU law.

7. Challenging requests

We reserve the right to challenge requests that we believe are unlawful, overly broad, procedurally deficient, or inconsistent with Maltese or EU data protection law. Where we challenge a request, we will seek legal advice and may apply to the relevant court or tribunal.

8. Record keeping

We maintain a record of every government request received, including the requesting authority, the legal basis cited, the data requested, whether we disclosed data, and the date of our response. These records are retained for the duration required by Maltese law.

9. Transparency reporting

We do not currently publish a transparency report. As the platform grows and we receive a meaningful number of requests, we will consider publishing periodic aggregate statistics on the number and type of government requests received and how we responded, subject to any legal restrictions on disclosure.

10. Submitting a request

Government requests should be directed to legal@bookify.mt. We accept service by email where permitted by the applicable legal process. Postal service is available at: Christian Azzopardi t/a Bookify Malta, Gcoe, Triq il-Mithna, Qala, Gozo, Malta.