Government Data Request Policy

Purpose

This policy governs how Spartan X Corp ("the Company"), including its products such as Automic Trades (app.automictrades.com), handles requests from any government or public authority — domestic or foreign — for personal data or personal information of the Company's users, including data received from third-party platform partners (for example, Meta Platform Data).

1. Legality Review — Required for Every Request

No data is disclosed until the request has been reviewed for legal validity. Review confirms, at minimum:

• The requesting authority's identity and jurisdiction
• The legal instrument relied upon (warrant, subpoena, court order, or statutory authority)
• That the request is properly scoped to identified accounts and data categories
• That disclosure would not violate the Company's contractual obligations to its platform partners or its users

The Company engages outside counsel for any request whose validity is unclear.

2. Challenging Unlawful or Overbroad Requests

The Company will challenge, through available legal means, any request it considers unlawful, overbroad, vague, or improperly served — including seeking to narrow, quash, or require proper legal process before any disclosure. Absent a valid emergency exception, informal or undocumented requests are declined and directed to formal legal process.

3. Data Minimization

Where disclosure is legally required, the Company discloses only the minimum data necessary to comply with the specific request — limited to the named accounts, the named data categories, and the named time ranges. The Company does not provide bulk, open-ended, or ongoing access.

4. Documentation

The Company maintains a written record of every government data request, including: the request itself; the requesting authority and named actors; the legal basis asserted; the Company's legal analysis and reasoning; all correspondence; any challenge made and its outcome; and a precise inventory of any data ultimately disclosed, with dates. Records are retained for a minimum of seven (7) years.

5. User and Partner Notice

Where permitted by law, the Company notifies affected users before disclosure. Where a platform partner's terms require notice to the platform, the Company provides that notice.

6. National Security Requests

As of the effective date, the Company has received no national security requests. Any such request will be handled under this policy with mandatory outside-counsel review.

Contact

Questions regarding this policy may be directed to Spartan X Corp via the contact page at spartanxcorp.com/contact.