Responsible Use & Platform Enforcement Policy

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• Terminals, not people. The Platform describes a dish: where it is and why we believe it is a Starlink terminal. Agencies may not use it to follow individuals.
• Lawful purpose only. Access is limited to public bodies with a licensing or spectrum mandate, for that mandate as approved by Equatorium, in the countries they subscribe to.
• Least data necessary. Identity-linked data is released only for a specific case, under a stated legal basis, for the scopes that case needs, and only through our Disclosure Policy.
• Protected activity stays protected. We deny requests that concern conflict areas, journalists, or other protected activity.
• Everything is recorded. Use of the Platform is written to an audit log that Equatorium and the Agency can review.
• Verify before acting. Detections are probabilistic. No one should face enforcement action on the strength of Output alone.

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Agencies may use the Services only for the Permitted Purpose defined in the Terms of Use: identifying, locating, monitoring, and taking lawful regulatory action concerning satellite terminals that may be operating without the required licence, authorization, or type approval in a subscribed country, together with related licensing, spectrum-management, enforcement, and policy work within the Agency’s legal mandate. Examples of permitted use include:

• measuring the number and distribution of unlicensed terminals to inform licensing policy or spectrum planning;
• setting up scan and alert workflows over areas within the Agency’s jurisdiction;
• planning on-site inspections or spectrum-monitoring missions to verify a detection;
• requesting, through the disclosure process, identity-linked information about a terminal that is the subject of one of the case types in the Disclosure Policy, within the Agency’s mandate; and
• preparing evidence for a specific licensing or enforcement proceeding, after independent verification.

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Agencies and Authorized Users must not use the Services, Output, or any Release, directly or through Quant or any other person, to do any of the following:

a. Tracking or profiling individuals

• Locate, track, follow, monitor, or build a profile of any individual or household, including through the device information shown on the Platform, except within the scope of an approved Release and the case stated in it.
• Attempt to re-identify any person from Output, or combine Output with other datasets (such as subscriber records, CCTV, social media, or other location data) to identify a person, except within the scope of an approved Release and as the Agency’s own law permits.
• Infer or act on any person’s sensitive characteristics, such as health, religion, ethnicity, sexual orientation, political opinion, or trade-union membership, from Output.

b. Targeting protected persons and activity

• Use the Services in connection with conflict areas, journalists, or other protected activity, or to target any person or group for lawful expression, association, assembly, or religious practice.
• Discriminate against any person or group on the basis of a protected characteristic.

c. Purposes outside the mandate

• Use the Services for any purpose outside the Agency’s stated mandate. Any use beyond spectrum licensing must fall within the mandate the Agency stated when it applied, which Equatorium’s legal team must approve in writing before the account is created.
• Use Output to determine any person’s eligibility for credit, employment, insurance, housing, education, healthcare, or public benefits, or for marketing or commercial purposes of any kind.
• Use the Services outside the countries the Agency subscribes to, or on behalf of another government, agency, or private party.

d. Sharing and commercial exploitation

• Disclose, publish, sell, resell, license, or otherwise make Output or a Release available outside the Agency, except as permitted by Section 4 of the Terms of Use.
• Use Output, Releases, or Quant responses to train, fine-tune, or evaluate any machine-learning or AI model, or to build a competing product or dataset.

e. Technical misuse

• Scrape, crawl, or bulk-download the Platform, or exceed rate or usage limits.
• Circumvent or attempt to circumvent access controls, roles, approval steps, audit logging, release expiry, or any other safeguard in the Disclosure Policy, including by creating duplicate accounts, sharing logins, or splitting a request to avoid review.
• Alter a Release or export, or present an altered copy as genuine.
• Upload malicious code, probe for vulnerabilities without coordination with security@equatorium.com, or interfere with the Services.

f. Children

• Use the Services in connection with any person the Agency knows or has reason to believe is a child under applicable law, or request a Release relating to a child, except where a threat to that child’s life is the stated case and Equatorium approves it. Report any Output you believe relates to a child to privacy@equatorium.com.

g. False or unlawful requests

• Submit or approve a disclosure request with a legal basis that is invented, expired, revoked, insufficient under the Agency’s law, or not related to the terminal in question, or with a justification that misstates the facts.

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The following uses are not permitted unless Equatorium has approved them in writing in advance, which we may do subject to conditions such as additional review, narrower scopes, or shorter retention:

• access by contractors or consultants acting for the Agency;
• sharing aggregate statistics derived from Output in public reports, parliamentary submissions, or press statements (aggregates must not allow any terminal or person to be singled out);
• enforcement action concerning aviation (in-flight) terminals, maritime terminals, diplomatic premises, or the premises of international organizations;
• use in a border area, or in connection with a cross-border matter involving another country’s authorities;
• integration of exports into the Agency’s own case-management or analytical systems; and
• any use not clearly within the Permitted Purpose.

Send requests for approval to legal@equatorium.com or raised through in-app Support.

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Each Agency must, and must ensure its Authorized Users:

• Hold a legal basis. Confirm before each disclosure request that a current legal basis exists under the Agency’s own law, including any required prior authorization by a court or independent body, and keep a copy available for Equatorium’s review on request.
• Apply need-to-know. Grant accounts and roles only to personnel who need them, keep approver and requester roles separate, enable two-step verification, and remove access promptly when it is no longer needed.
• Inform users. Ensure every Authorized User has read the Terms of Use, this Policy, and the Disclosure Policy before using the Platform. Equatorium provides onboarding training on request; it is not mandatory.
• Keep records. Maintain records of each case in which Output or a Release is used, including the legal basis, the decision taken, and any onward disclosure permitted by the Terms of Use, and provide them to Equatorium on reasonable request.
• Handle exports and Releases securely. Store them only in access-controlled systems approved for sensitive personal data, never in personal email or unmanaged devices, and never print or forward them beyond those who need them.
• Delete when the case ends. Delete Releases and exports containing identity-linked data when the case for which they were released is closed, or earlier when no longer needed, except where the Agency’s law requires retention as part of an official record.
• Verify before acting. Independently verify a detection before any enforcement action, as required by Section 14 of the Terms of Use.
• Respect individuals’ rights. Handle complaints and rights requests from affected persons in accordance with the Agency’s law, and pass to Equatorium any request that concerns Equatorium’s own processing.
• Report incidents. Tell Equatorium at security@equatorium.com within seventy-two (72) hours of discovering any misuse, unauthorized access, or loss of Output or a Release.

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Account approval. Equatorium staff review every sign-up before granting access, except a sign-up made with a valid referral code that Equatorium issued: the code is issued only after Equatorium has vetted the Agency, so that sign-up is approved without a separate staff review. When we review a sign-up, we verify the applicant’s official email and identity, the Agency’s existence and legal mandate, and the country concerned. Any use beyond spectrum licensing must be stated in the application and approved in writing by Equatorium’s legal team before the account is created. We may ask for further information, such as the legal instrument establishing the Agency’s mandate or a letter of authorization, and we may deny a sign-up without giving reasons.

Country review. We review each country subscription before activating it. Before offering the Services in a country, and periodically after that, we assess the legal framework for licensing and surveillance, the independence of courts and oversight bodies, the protection of journalists and civil society, the presence of armed conflict, and credible reports of misuse of surveillance technology. We may decline, condition, suspend, or end the Services in a country, or for an Agency, on the basis of that assessment.

Framework. Our due diligence follows the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and relevant export-control guidance on cyber-surveillance items.

Sanctions and restricted parties. We screen Agencies and Authorized Users against applicable sanctions and restricted-party lists and do not offer the Services where prohibited, as described in Section 13 of the Terms of Use.

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Terminal identity is protected by default. Identity-linked data is released to an Agency only through our Disclosure Policy, which requires a stated legal basis and review by Equatorium. In addition:

• Audit trail. Activity in the Platform is written to an audit log visible to Agency administrators with access to it and to Equatorium.
• Quant safeguards. Quant cannot release identity-linked data and never acts without a user’s confirmation.
• Usage limits. Usage limits apply to the Services.

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Equatorium monitors use of the Services to detect and prevent misuse. This includes:

• reviewing audit logs and usage for signs of misuse;
• reviewing approved Releases to confirm that the legal basis was genuine and the use matched the stated case, and asking Agencies for the supporting records described in Section 5;
• reviewing Agencies’ continued eligibility, including when an Agency’s mandate, leadership, or legal framework changes; and
• investigating every report of misuse we receive.

Authorized Equatorium staff carry out monitoring under confidentiality obligations. We do not access the content of Your Content except as needed to provide support, review disclosure requests, investigate misuse, or comply with law.

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If we determine, in our reasonable judgment, that an Agency or Authorized User has breached this Policy, we may take one or more of the following measures, depending on the severity of the breach, its consequences, and whether it is repeated:

1. Warning and a request for corrective action, such as removing a user, deleting an export, or providing records.
2. Restriction of specific features, such as disclosure requests, exports, Quant, or particular areas, or a requirement for additional review of future requests.
3. Revocation of an open Release and a request that the Agency confirm deletion of all copies.
4. Suspension of individual Authorized Users or of the Agency’s account.
5. Termination of the Agency’s account, subscriptions, and access to the Services, without refund, as provided in Section 17 of the Terms of Use.
6. Notification of the Agency’s oversight body, a competent data protection authority, or other authorities, where required by law or where we consider it necessary to prevent harm to any person.

Where a breach creates a risk of serious harm to any person, we may act immediately and without prior notice. Otherwise, we will generally give the Agency an opportunity to explain and remedy the breach. We may refuse future sign-ups from an Agency or individual whose access was terminated for misuse.

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Anyone, including Authorized Users, members of the public, journalists, and civil-society organizations, may report suspected misuse of Equatorium by emailing legal@equatorium.com or, for customers, through in-app Support. Please include as much detail as you can, such as the Agency concerned, dates, locations, and how you became aware of the issue. Reports may be made confidentially. We will not tell the Agency who reported it unless the reporter agrees or we are required by law, and we prohibit retaliation by Agencies against their personnel who report misuse in good faith.

Report security vulnerabilities to security@equatorium.com.

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We publish an annual transparency report with aggregate information about how the Services are used and enforced, including the number of countries served, the number of disclosure requests received, approved, and denied by case type and denial reason, the number of enforcement actions taken under this Policy, and the number of requests we received from authorities other than our customers (see Requests from Authorities & Third Parties). Figures are aggregated so that no Agency’s investigations can be identified. A draft of the current report, with underlying data where needed, is available on request from privacy@equatorium.com. See also Privacy Request Statistics.

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We may update this Policy as the Services, the law, or our understanding of risks change. We will post the updated Policy with a new “Last updated” date and notify Agency administrators of material changes as described in Section 1 of the Terms of Use. Changes that add safeguards may take effect immediately. Send questions about this Policy to legal@equatorium.com.