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Sensitive Data Removal Policy

Introduction

If you believe that content on WhatToy infringes a valid copyright you own, please see our DMCA Takedown Policy and our Guide to Submitting a DMCA Takedown Notice. We rely on the DMCA notice and takedown process for the majority of our removal actions.

However, we understand that sensitive, security-related content may get published on WhatToy – whether accidentally or on purpose – from time to time. We provide our sensitive data removal process to remove this sensitive data in certain exceptional circumstances where the DMCA process would not be applicable, such as when your security is at risk from exposed passwords and you do not own the copyright to the specific content that you need removed, or the content is not protectable by copyright. This guide describes the information WhatToy needs from you in order to process a request to remove sensitive data from a repository.

What is Sensitive Data?

For the purposes of this document, “sensitive data” refers to content that (i) should have been kept confidential, and (ii) whose public availability poses a specific or targeted security risk to you or your organization.

Sensitive data removal requests are appropriate for:

  • Personal and/or private information regarding an individual or organization.
  • Access credentials, such as user names combined with passwords, access tokens, or other sensitive secrets that can grant access to your organization's server, network, or domain.
  • Tokens and other similar access credentials that grant access to a third party on your behalf. You must be able to show that the token does belong to you.
  • Documentation that poses a specific security risk for an organization. Internal server names, IP addresses, and URLs, on their own, are not sufficiently sensitive.

Sensitive data removal requests are not appropriate for:

  • Requests to remove content that may infringe your or your organization's copyright rights. If you have questions about how WhatToy handles copyright-related matters or would like to report potentially infringing content, please review our DMCA Takedown Policy. The sensitive data removal process is generally not intended for the removal of full pages — only for the specific pieces of sensitive data in those pages. While there may be cases where pages are filled entirely with sensitive information, you must justify the security risk for the removal of such pages, and this may increase the time required to process your request.
  • Mere mentions of your company's identity, name, brand, domain name, or other references to your company in pages on WhatToy. You must be able to articulate why a use of your company's identity is a threat to your company's security posture before we will take action under this policy.
  • Privacy complaints. If you have concerns about your own privacy or you are contacting us on behalf of your employees due to a privacy concern — for example, if there are private email addresses or other personal information posted — please contact us via our Contact Page, selecting the Legal option.
  • Entire pages that do not pose a specific security risk, but you believe are otherwise objectionable.

Things to Know

Ask Nicely First. A great first step before sending us a request to remove data is to try contacting the user directly. This is not strictly required, but it is appreciated.

No Bots. You should have a trained professional evaluate the facts of every request you send. If you're outsourcing your efforts to a third party, make sure you know how they operate, and make sure they are not using automated bots to submit complaints in bulk. These complaints often include data that does not pose any security threats, and they do not include sufficient explanations, requiring additional back-and-forth and resulting in delays, even when the complaint is valid.

Send In The Correct Request. We offer this sensitive data removal process as an exceptional service only for high-risk content. We are not able to use this process to remove other kinds of content, such as potentially infringing content, and we are not able to process any other kinds of removal requests simultaneously while processing sensitive removal requests. We will be able to help you more quickly if you send in your sensitive data removal requests separately from any requests to remove potentially infringing content. If you are unsure whether your request involves only sensitive data or also involves other legal matters, please consult legal counsel.

Processing Time. While we do process sensitive data removal requests as quickly as possible, due to the volume of requests we process, it may take some time for your request to be reviewed. Additional requests, or multiple requests from additional points of contact, may result in delays.

How Does This Actually Work?

  1. Complainant Investigates. It is up to the requesting party to conduct their own investigation and to provide us with the details we require — most importantly, an explanation of how the data poses a security risk. WhatToy is not in a position to search for or make initial determinations about sensitive data on any individual's or organization's behalf.

  2. Complainant Sends a Sensitive Data Removal Request. After conducting an investigation, the complainant prepares and sends a sensitive data removal request to WhatToy. If the request is not sufficiently detailed to demonstrate the security risk and for WhatToy to locate the data, we will reply and ask for more information.

  3. WhatToy Asks User to Make Changes. In most cases, we will contact the user who created the content and give them an opportunity to delete or modify the sensitive data specified in the request or to dispute the claim.

  4. User Notifies WhatToy of Changes. If the user chooses to make the specified changes, they must tell us so within the window of time they've been allowed. If they don't, we will remove the content. If the user notifies us that they made changes, we will verify that the changes have been made and notify the complainant.

    OR

  5. User May Dispute the Request. If a user believes the content in question is not sensitive data subject to this Policy, they may dispute it. If they do, we will generally leave it up to the complainant to contact the user and work things out with them directly, within reason.

  6. Complainant Reviews Changes. If the user makes changes, the complainant must review them. If the changes are insufficient, the complainant must provide WhatToy with details explaining why. WhatToy may remove the content or give the user an additional chance to make the changes.

  7. User May Request an Additional Window to Make Changes. If the user missed their opportunity to remove the sensitive data specified in the notice, we may allow them an additional window of approximately 1 business day, upon request, to make those changes. In that event, WhatToy will notify the complainant.

Sending A Sensitive Data Removal Request

Due to the type of content WhatToy hosts and the way that content is managed, we need complaints to be as specific as possible. In order for us to verify that a user has removed reported sensitive data completely, we need to know exactly where to look.

These guidelines are designed to make the processing of requests to remove sensitive data as straightforward as possible.

Your Request Must Include:

  1. A working, clickable link to each page containing sensitive data. (Note that we're not able to work from search results, examples, or screenshots.)
  2. Specific location within each page containing the sensitive data.
  3. A brief description of how each item you've identified poses a security risk to you or your organization. It is important that you provide an explanation of how the data poses a security risk beyond merely stating that it does.
  4. If you are a third party acting as an agent for an organization facing a security risk, include a statement that you have a legal right to act on behalf of that organization.
  5. OPTIONAL: Let us know if your request is particularly urgent, and why. We respond to all sensitive data removal requests as quickly as possible. However, if this request is especially time-sensitive, such as a very recent credential exposure, please explain why.

How to Submit Your Request

You can submit your request to remove sensitive data via our Contact page, selecting the Sensitive Data option. Please note, if your request has more than 5000 characters, or you would like to add attachments, send us an email instead, which is the next option.

You can also send an email notification to [email protected]. You may include an attachment if you like, but please also include a plain-text version of your letter in the body of your message. Please also add in the subject that it is a sensitive data request.

Disputes

If you received a sensitive data removal request from us, you can dispute it by replying to our email and letting us know — in as much detail as possible — why you think the content in question is not sensitive data subject to this Policy.

Finishing Up

WhatToy’s DMCA policies have been influenced by those at GitHub.
This page was last updated: 01/07/2021 (dd/mm/yyyy).

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