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I think your understanding of 'proactively' might just be different from parent's (and mine).

I'd agree that entities that provide their users' data upon a simple request, and a carveout in regulations that allows (not forces) them to do so, fits the definition of proactive.

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Let's not get all Humpty Dumpty here. "Upon request" is reactive by definition. "Proactive" sharing would quite literally mean sharing on one's own initiative.
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It's proactive in the sense that it's shared before a valid warrant is issued for the information, and before they have any reason to do so. But is reactive to any request at all, sure.
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