18 U.S.C. § 2257 Compliance Statement

This statement is provided in compliance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75, which govern the maintenance and inspection of records pertaining to the production of sexually explicit content. Velvet Lobby takes its obligations under these laws seriously and maintains a strict zero-tolerance policy toward any content depicting individuals under the age of 18.

Platform Role and Exemption

Velvet Lobby operates as a passive hosting platform and online directory. Velvet Lobby does not produce, direct, film, photograph, or otherwise create any of the visual content uploaded by Providers. All content on the Platform is user-generated and uploaded directly by independent Providers who are solely responsible for compliance with all applicable laws, including 18 U.S.C. § 2257 and its implementing regulations.

As a secondary producer within the meaning of 18 U.S.C. § 2257(h)(2)(B), Velvet Lobby is exempt from the record-keeping requirements of 18 U.S.C. § 2257 with respect to content produced by third parties, provided that Velvet Lobby complies with the requirements applicable to secondary producers. Velvet Lobby complies with these requirements by requiring all Providers to submit age and identity verification prior to uploading any content to the Platform.

Provider Obligations

Every Provider who uploads visual content to the Platform is a primary producer within the meaning of 18 U.S.C. § 2257 and bears full responsibility for compliance with all record-keeping requirements. Providers represent and warrant that:

• All individuals depicted in any content uploaded to the Platform are at least 18 years of age.
• The Provider has obtained and maintains all records required by 18 U.S.C. § 2257 and 28 C.F.R. Part 75 for every individual depicted in their content, including copies of government-issued photo identification establishing date of birth.
• Such records are available for inspection as required by law.
• No content uploaded to the Platform depicts any individual under the age of 18 in a sexually explicit manner.

Velvet Lobby's Verification Program

As an additional safeguard beyond the statutory requirements, Velvet Lobby requires all Providers to complete an age and identity verification process before uploading any photographs or accessing certain Platform features. This verification process requires Providers to submit:

• A valid, government-issued photo identification document (such as a passport, driver's license, or national identity card) establishing that the Provider is at least 18 years of age.
• A verification selfie photograph of the Provider holding a handwritten sign displaying the Platform name and the date of verification.

Verification materials are reviewed by Velvet Lobby's moderation team and stored securely in encrypted cloud storage. Access to verification materials is restricted to authorized personnel only and is never displayed publicly. Verification records are retained for a minimum of seven (7) years in accordance with applicable law.

Content Moderation

All photographs uploaded to the Platform's Spicy Gallery (which may include lingerie, swimwear, and tasteful topless content) are subject to administrative review and approval before becoming publicly visible. Content that depicts individuals who appear to be under the age of 18, depicts full nudity or explicit sexual acts, or otherwise violates our content standards will be rejected and may result in immediate account termination.

Reporting Suspected Violations

Velvet Lobby is committed to the protection of minors and will immediately report any content that appears to depict a minor in a sexual manner to the National Center for Missing and Exploited Children (NCMEC) via the CyberTipline at www.missingkids.org/gethelpnow/cybertipline, and to the appropriate law enforcement authorities. We will also cooperate fully with any law enforcement investigation.

If you encounter any content on the Platform that you believe depicts a minor, please report it immediately to [email protected] with the subject line "CSAM Report." We will investigate and act on all such reports within 24 hours.

Custodian of Records

Requests for inspection of records maintained pursuant to 18 U.S.C. § 2257 should be directed to:

Velvet Lobby — Custodian of Records
Attn: Legal / Compliance
Email: [email protected]
Subject: 18 U.S.C. § 2257 Records Request

Inspection requests must be submitted in writing and will be responded to in accordance with the requirements of 28 C.F.R. Part 75.

Contact

For questions regarding this compliance statement or our age verification program, please contact us at [email protected].