These Guidelines are a reference for law enforcement officials seeking data from Life360, Inc. and its subsidiaries Tile, Inc. and Jio, Inc. (collectively, “Life360”). These Guidelines are not intended for requests for information by Life360 members, civil litigants, or criminal defendants.
For Emergency Disclosures, please refer to Section 8.
Life360 takes the privacy of its members seriously and is committed to protecting their privacy. Life360 requires valid and legally binding legal process that is properly served, and completion of a Legal Request Intake Form, before disclosing member data, except in emergencies, where the member has provided consent, or in other circumstances in Life360’s sole discretion and consistent with applicable law. We review all legal process for authenticity, facial validity, and legal sufficiency (including by ensuring the form of legal process—such as a subpoena, d-order or search warrant—is sufficient under applicable law or under the Electronic Communications Privacy Act to obtain the type of data requested), and Life360 reserves the right to object to requests that do not comply with applicable laws or our members’ rights.
These Guidelines do not create any obligation or enforceable right against Life360, nor do these Guidelines constitute legal advice or a waiver of any objection by Life360 in any particular scenario. Life360’s policies and these Law Enforcement Guidelines may be updated or changed in the future without further notice.
1. About Life360, Tile, and Jiobit
Life360 is a leading technology platform that allows members to locate people, pets, and things using services and products offered by Life360 and its subsidiaries, Tile and Jiobit. Life360’s core offering, the Life360 mobile application, enables members to share location information, communicate, ensure driving safety, and more. Tile offers Bluetooth trackers (known as “Tiles”) to locate objects. Jiobit likewise offers a hardware location device for young children, pets, and seniors.
2. Informal Inquiries to Life360
3. Service of Legal Process to Life360 and Requirements
Except as otherwise stated in these Law Enforcement Guidelines, Life360 generally accepts service of legal process via email to firstname.lastname@example.org if submitted with a completed Life360 Legal Request Intake Form (“Intake Form”). However, for any legal process concerning investigations or enforcement actions related to abortion, reproductive health, gender-affirming care, LGBTQ+ rights, or any other matter that Life360 determines in its sole discretion to be a fundamental right of its members, Life360 requires personal service on Life360 at its California offices located at 1900 S Norfolk St., Ste. 310, San Mateo, CA.
Regardless of the method of service, Life360 requires a completed Intake Form for all legal process submitted to Life360. The Intake Form is required to be consistent with California Assembly Bill 1242 and also helps Life360 ensure it can process and track each law enforcement request.
Please note that all legal process must be:
- In PDF format and assembled in the complete form as issued by the court or competent authority;
- Issued on government letterhead or with a caption that identifies the court that issued the process and the case/docket number;
- Dated and signed by an attorney or government official (if applicable), or by a judicial officer;
- Issued under the authority of a court with jurisdiction over Life360; and
Generally, legal process addressed to Life360 must be issued by a federal court or a state court in California or Delaware. State law enforcement located outside of California or Delaware typically must domesticate their legal process in California or Delaware. If you believe that legal process issued by a state court located outside of California or Delaware is binding on Life360, please identify the legal basis for your position.
- Addressed to Life360 Inc., Tile, Inc., or Jio, Inc. (as applicable).
All legal process must also identify:
- The specific member whose data is being requested. Names alone are generally insufficient. The request must include one or more of the following identifiers:
- Life360: Phone number or email address associated with the account.
- Tile: Email address, TileID, Data Matrix (serial number), Envelope ID (links packaging to Tile device), or “Scan if Found” Data Matrix.
- Jiobit: Email address, phone number, or serial number.
- The specific types of data requested (see below) and the applicable date range for the request;
- The legal basis for the request; and
- How and to whom the responsive data should be produced.
4. Information that May Be Available and Legal Process Required
The categories of member information that Life360 may have for a particular member depends on which Life360 products and services they use.
Please note that Life360, Tile, and Jiobit collect different types of geolocation data. Life360 collects two types of location data: raw location data and a data set referred to as “dwell” data. Raw location data reflects a member’s location as they were moving, whereas dwell data reflects locations where a member did not move for at least 15-20 minutes and the approximate length of time in such locations. Tile and Jiobit retain only raw location data.
Absent exigent circumstances or other lawful exceptions, the categories of information that may be available to law enforcement depend upon the service(s) used and the type of legal process submitted, as detailed in the below table.
|Court / 2703(d) Order
5. Data Retention
Life360 generally retains some form of location data for up to 13 months. Life360 currently collects dwell data in a yearlong batch and deletes the previous year’s batch in February of the following year. Thus, the retention period for dwell data depends on when it is collected but generally will not exceed 13 months.
Raw location data from Tile and Jiobit devices is retained for approximately 30 days. With the exception of the last place a Tile was recorded.
6. Witness Testimony Requests
Life360 provides a Business Record Certification with its productions, which generally eliminates the need for live testimony to authenticate records. Should you believe that a custodian of records is still necessary to provide testimony, we require domestication of all state subpoenas pursuant to the Uniform Act to Secure the Attendance of a Witness from Without a State in Criminal Proceedings, Cal. Penal Code § 1334, et seq. Life360 will not waive service requirements for subpoenas seeking witness testimony nor accept service via electronic means. All subpoenas seeking witness testimony must be personally served on Life360 at its California offices.
Life360 does not provide expert witness testimony.
7. Preservation Requests
Life360 will preserve member data for 90 days upon receipt of a formal preservation request from law enforcement in connection with an official criminal investigation and pending the issuance of a court order or other legal process. Law enforcement may request one extension of the preservation request for an additional 90 days. If law enforcement agents do not request an extension before the expiration of the initial 90-day preservation period and/or do not serve Life360 with compulsory legal process before the expiration of the preservation period, the preserved information will be deleted after the preservation period expires. It is the responsibility of law enforcement to track the expiration date for a preservation request and notify Life360 of any request to extend the preservation period.
Preservation requests must be sent on official law enforcement letterhead, signed by a law enforcement official and must include:
- Required identifiers for the member whose data is requested to be preserved (see Section 3); and
- A statement that steps are being taken to obtain a court order or other legal process for the data sought to be preserved.
Preservation requests should be submitted to Life360 via email at email@example.com.
8. Emergency Disclosure Request Procedures
Life360 has a process for evaluating requests on an expedited basis where an emergency situation exists involving an imminent threat of death or serious bodily harm to a person. If law enforcement believes an emergency situation exists, please complete the Life360 Emergency Disclosure Request form and submit it to Life360 via email at firstname.lastname@example.org. The subject line of the email should include “Emergency Request.” We review these requests on a case-by-case basis.
Please note that we will only review and respond to emergency requests from law enforcement. We will not respond to emergency requests sent to this address by non-law enforcement officials.
9. International Requests
Life360 only responds to valid legal process issued by a U.S. governmental entity or court and properly served on Life360 in the United States. Non-U.S. law enforcement seeking information from Life360 should appropriately domesticate requests through a U.S. court by working through the appropriate process for international cooperation, such as letters rogatory or a Mutual Legal Assistance Treaty. More information may be available by contacting the Office of International Affairs at the U.S. Department of Justice.
Life360 may disclose data pursuant to an emergency disclosure request when we believe that doing so is necessary to prevent death or serious physical harm to someone. If international law enforcement believes an emergency situation exists involving an imminent threat of death or serious bodily harm to a person, please follow the emergency disclosure request procedures set forth in Section 8.
10. Member Consent
Life360 may disclose member data to law enforcement pursuant to consent from the affected member upon completion and submission of the Life360 Consent Release Form. Likewise, the primary legal guardian of a minor child may provide consent for the release of their minor child’s records upon completion and submission of the Life360 Minor Consent Release Form. Consent forms should be submitted via email at email@example.com.
11. Member Notice Policy
Life360’s policy is to notify members when we receive legal process seeking their data unless we are prohibited from doing so by law or a court order. Before disclosing member data, we will make a reasonable effort to notify any affected member by sending a message to their verified email address, with a copy of the legal process. Life360 may, in its sole discretion, shorten or forgo the notice period for emergency situations or exceptional circumstances such as child exploitation cases. Law enforcement officials who believe that notification would jeopardize an investigation should obtain an appropriate court order that specifically prohibits Life360 from notifying any affected members, such as an order issued under 18 U.S.C. § 2705(b). Life360 reserves the right to notify affected members after any non-disclosure period has expired unless we are prohibited from doing so by law or an additional court order.
12. Cost Reimbursement
Life360 reserves the right to seek reasonable reimbursement costs for responding to law enforcement requests for information.