TAKE IT DOWN Act / NCII Policy

What Is the TAKE IT DOWN Act?

The U.S. TAKE IT DOWN Act (Pub. L. No. 117-314, enacted January 2025) requires online service providers to remove non-consensual intimate visual depictions ("NIVDs"), including artificial images and deepfakes, within 48 hours of a valid notice. Ollage is committed to compliance with this law and has committed to an accelerated 24-hour response target.

This policy applies only to removal requests made under the TAKE IT DOWN Act. Requests under other laws (EU Digital Services Act, UK Online Safety Act, GDPR, CCPA, or copyright/DMCA) are handled under separate policies.

What Content Is Covered?

Under the TAKE IT DOWN Act, Ollage removes:

• Non-Consensual Intimate Visual Depictions (NIVDs): Photographs, videos, or audiovisual recordings of an identifiable individual's intimate body parts or of sexual activity, created or distributed without consent. This includes content taken without knowledge and later shared.
• Digital Forgeries (Deepfakes): AI-generated, synthetically created, or digitally manipulated images, videos, or audiovisual recordings of an identifiable individual that depict sexual conduct or intimate body parts, created or distributed without consent.

Ollage does not remove:

• Content created or distributed with the depicted person's consent;
• Content flagged for other reasons (copyright, terms of service) — use the appropriate removal path instead;
• Non-sexual nudity or medical/educational content (context and consent matter).

Who Can Submit a Removal Request?

A valid removal request may be submitted by:

• The identifiable individual depicted in the NCII or deepfake;
• An authorized representative (parent/guardian for minors, attorney, designated agent) acting on behalf of the depicted person;
• A minor may submit on behalf of themselves without parental authorization.

Notice Requirements — What a Valid Request Must Include

To be valid and actionable, your removal request must include:

1. Identification of the depicted person: Your full legal name (or the depicted person's name if you are a representative). This allows us to verify that you are the person depicted (or authorized to act on their behalf).
2. Identification of the content: A link, URL, clip ID, or detailed description of the NCII or deepfake sufficient for us to locate it on Ollage (e.g., "the video at https://ollage.com/movie/ABC123" or "the clip titled 'X' posted by user 'Y' on [date]").
3. Statement of non-consent: A clear statement that the content was created or distributed without your consent and any information necessary for us to understand how it violates your rights (e.g., "This is a deepfake created without my permission" or "This video was taken without my knowledge").
4. Contact information: Your email address and phone number (or your representative's contact information) so we can follow up with you.
5. Good-faith statement: A statement that you have a good-faith belief that the content is non-consensual or a deepfake, and that your request is not intended to censor lawful speech or restrict someone else's access to content they have the right to possess.
6. Signature: Your physical or electronic signature (typed name is acceptable; include the date). If you are an authorized representative, sign on behalf of the depicted person and include your authority to act (e.g., "Power of Attorney" or "Parent/Guardian of [minor name]").

How to Submit a Removal Request

Preferred method: Use the Content Removal form (select "NCII / Non-Consensual Intimate Imagery"). This is our tracked intake system and generates a case ID (format: OL-YYYYMMDD-XXXX) for your records. The form guides you through all required fields.

Alternative method: Email your request to [email protected] with subject "TAKE IT DOWN Act Removal Request" and include all six elements above.

Reporting in-app: On any clip, you may use the in-app report function (three dots → Report → "Non-Consensual Intimate Imagery"). This does not formally notify Ollage under the TAKE IT DOWN Act — for a legally actionable notice, please use the form or email above.

Our Response Process

Upon receipt of a removal request, Ollage will:

• Acknowledge receipt within 24 hours: We will respond to your email or generate a case ID (if submitted via form) confirming we have received your request.
• Assess completeness: We review your request to ensure it includes all required elements. If information is missing, we will contact you to request clarification (within 24 hours).
• Verify your identity: We will verify that you are the depicted person or an authorized representative. This may include:
  • Asking for a distinguishing detail that only the depicted person would know (e.g., a visible tattoo, birthmark, or unique feature visible in the content);
  • Requesting a photo or video comparison (you may blur or crop to protect your privacy);
  • For authorized representatives, confirming your authority (power of attorney, guardianship documents, etc.);
  • We do NOT require government-issued ID (no passport, driver's license, etc.) — we use other means to verify identity.
• Remove or disable access within 24 hours: If your identity is verified and the request is valid, we will remove or disable access to the identified content and any known identical copies. We will not restore the content except as required by law.
• Confirm removal to you: We will send you written confirmation (email or case-ID update) that the content has been removed, along with any action taken against the account that uploaded it (account suspension or ban, if warranted).

Identity Verification — No Government ID Required

To prevent false removal requests, we require verification that you are the depicted person or an authorized representative. We do not require government-issued ID (passport, driver's license, national ID card, etc.). Instead, we use a combination of:

• Identity knowledge: Questions or details that only the depicted person would know (physical distinguishing marks, context of how the content was created, etc.);
• Visual comparison: You may provide a selfie, photo, or video clip (clothed or partial) to compare against the content. You may blur or crop the comparison to protect your privacy;
• Supporting documents (for representatives): Power of attorney, guardianship orders, or documentation of legal authority to act on behalf of the depicted person;
• Circumstantial evidence: Email records, timestamps, location data, or other corroborating information that links you to the content (with your consent).

Requests that provide insufficient identity verification (e.g., "remove this video of me" with no supporting detail or comparison) will be flagged as low-confidence. We may still remove the content if it is clearly NCII or deepfake-evident, but we will mark the record as pending higher verification in case of appeal or dispute.

Uploader Notification

Unlike DMCA counter-notices: When we remove content under the TAKE IT DOWN Act, we do not notify the uploader, disclose your identity, or provide them with an opportunity to respond (no counter-notice process). Your privacy and safety are paramount. The account that uploaded the content will be suspended or banned without prior notice.

Prevention of Re-Upload — Content Hash Registry

To prevent bad-faith re-uploads of removed content:

• Hash matching (planned): Upon removal, Ollage will compute a cryptographic hash (fingerprint) of the removed content. We will use this hash to detect and automatically reject re-uploads or identical copies from any source or uploader.
• Permanent block list: Content identified as NCII or deepfake will be added to an internal block list. Attempts to re-upload identical or substantially similar content will be automatically prevented.
• Account suspension: Uploaders who attempt to re-upload removed NCII or deepfake content will have their account permanently suspended or banned.

Record Retention and Compliance Evidence

Ollage retains removal requests, identity verification records, and compliance evidence for a minimum of 7 years, as required by federal law. These records are:

• Stored securely with restricted access (legal and compliance staff only);
• Not disclosed to third parties except as required by law or court order;
• Purged in accordance with our data retention schedule after the statutory period;
• Summarized in annual compliance reports (not publicly disclosed).

Distinction from DMCA (Copyright) and Other Removal Paths

NCII removal is NOT copyright removal. The TAKE IT DOWN Act protects against non-consensual intimate imagery and deepfakes, not copyright infringement. Choose the correct path:

• Copyright / Intellectual Property: DMCA Policy or [email protected];
• NCII / Deepfake (non-consensual intimate imagery): This page or [email protected];
• Harassment, impersonation, terms-of-service violations: Content Removal form (select "Other / Terms of Service Violation") or [email protected];
• Privacy, personal data deletion, GDPR/CCPA: Privacy Policy or [email protected];
• Record-keeping (18 U.S.C. § 2257): §2257 Statement;
• Human trafficking, exploitation: [email protected] (mark subject "TRAFFICKING / EXPLOITATION - URGENT").

Appeals and Escalation

If Ollage denies your removal request (e.g., because the content does not meet the definition of NCII, identity cannot be verified, or it was removed by mistake), you may appeal within 7 days by contacting [email protected] with:

• Your case ID (if you have one);
• A detailed explanation of why you believe our decision was incorrect;
• Any additional identity verification or evidence (e.g., additional photos, legal documents, witness statements).

We will review appeals within 7 business days and respond in writing.

No Liability for Good-Faith Removal

Under the TAKE IT DOWN Act, Ollage is not liable for any action taken in good faith to remove or disable access to NCII or deepfakes, or for any failure to restore content, provided we act in compliance with this policy.

Confidentiality and Privacy

All removal requests, identity verification information, and communications are strictly confidential. We will:

• Not disclose your identity to the uploader, the public, or other users;
• Not share your contact information with any third party (except law enforcement if legally compelled by court order);
• Refer to you anonymously in any internal or legal proceedings;
• Store all information securely and limit access to authorized compliance staff.

Questions

If you have questions about this policy, the TAKE IT DOWN Act, or how to submit a removal request, please contact [email protected] or use the Content Removal form.