18 U.S.C. §2257 Record-Keeping Compliance Statement

Position of {{entity_name}}

{{entity_name}} is a {{producer_position}} within the meaning of 18 U.S.C. § 2257 and 28 C.F.R. § 75. {{entity_name}} does not produce, film, photograph, digitize, or otherwise create visual depictions of sexually explicit conduct. All visual depictions hosted on {{entity_name}} originate from third-party platforms and creators, who retain primary responsibility for production-related record-keeping under 18 U.S.C. § 2257.

{{entity_name}}'s role is limited to transmission, storage, retrieval, hosting, and formatting of material that may depict sexually explicit conduct. This re-publication model is consistent with 18 U.S.C. § 2257(h)(2)(B)(v) and the safe-harbor provisions of 47 U.S.C. § 230(c).

Content Origin & Discovery Model

{{content_source_disclosure}}

Minimum Age Representation

{{entity_name}} requires that all visual depictions on the platform depict individuals who were at least 18 years of age at the time of production. {{entity_name}} enforces this through:

• Indexing only from third-party platforms with verified 18+ performer policies;
• Immediate removal of any content where the age of a depicted person is in doubt;
• Acceptance of age-doubt reports via in-app flags, Content Removal Form, or Take-It-Down Report.

Records Maintained by {{entity_name}}

{{entity_name}} maintains the following records in connection with account-holder age verification:

• Date-of-birth attestations provided during account registration;
• Results of third-party age-verification checks (where applicable per jurisdiction tier);
• Audit trail of age-verification decisions and appeals.

These records are retained for {{data_retention_age_verification_years}} years from the date of account creation or last activity, per {{entity_name}}'s Privacy Policy.

Records NOT Maintained by {{entity_name}}

{{entity_name}} does not maintain identification, age-verification, performer-consent, or production-related records for individuals depicted in re-hosted third-party content. Such records are the responsibility of the primary producers (the original platforms and creators who hold the content) and are held by them pursuant to 28 C.F.R. § 75. {{entity_name}} does not have custody of, access to, or control over those records.

If you need performer identification or production records for content re-hosted on {{entity_name}}, you must contact the original creator platform where the content was initially published.

Custodian of Records (Age-Verification Audit)

Reporting Suspected Child Sexual Abuse Material (CSAM)

If you believe any content on {{entity_name}} depicts minors or child sexual abuse material, report it immediately:

• Via {{entity_name}}: In-app report button (reason: "Depicts a minor") or Take-It-Down Report Form
• Email (target {{response_target_ncii_hours}}-hour response): {{contact_email_ncii}}
• Directly to NCMEC: CyberTipline.org

All confirmed CSAM reports are escalated to the National Center for Missing & Exploited Children within {{response_target_ncii_hours}} hours.

Content Removal & Appeals

{{entity_name}} honors removal requests from account holders, content owners, copyright holders, and parties concerned about age or legality. Processes:

• Content Removal & Appeal Form — general submissions, age doubt, legality concerns, attribution
• Take-It-Down (NCII / CSAM) Report — suspected child exploitation
• DMCA Takedown Notice — copyright or performer-consent violation