Legal Document

Age Verification Policy

SGSuperFans enforces strict age verification across every point of platform access. This policy explains who must verify their age, how verification works, what obligations apply to creators posting age-restricted content, and how we protect minors from accessing material that is not appropriate for them.

Effective: January 1, 2026Last Updated: March 2026Version 2.0Governing Jurisdiction: Ontario, Canada
Age Requirement Notice: SGSuperFans is strictly an 18-and-older platform. No person under the age of 18 may register an account, access any content, or conduct any transaction on this platform. Any attempt to access the platform by a minor, or to facilitate such access, is a violation of these Terms of Service and applicable law. We actively verify ages and take immediate action when violations are detected.
Foundation

1.Policy Purpose and Our Commitment

SGSuperFans Inc. (“SGSuperFans,” “we,” “us,” or “our”), a corporation incorporated in Ontario, Canada, operates a premium creator economy platform that enables creators to monetize content, including content that is age-restricted. Protecting minors from exposure to inappropriate material and ensuring that all users are genuine adults is not merely a legal obligation for us; it is a foundational commitment that shapes every aspect of how we build and operate this platform.

This Age Verification Policy (“Policy”) is a binding legal document that governs how we verify the age and identity of users, what obligations apply to creators who publish age-restricted content, and how we detect and respond to any breach of our age requirements. This Policy applies globally to every user, regardless of the country from which they access the platform, and it supplements our Terms of Service, Privacy Policy, and Creator Content Agreement.

Our Legal Framework

Our verification obligations arise from multiple overlapping regulatory frameworks, including: 18 U.S.C. 2257 and 28 C.F.R. Part 75 (United States record-keeping for sexually explicit content); the Children’s Online Privacy Protection Act (COPPA); the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada; the General Data Protection Regulation (GDPR) of the European Union; the California Consumer Privacy Act (CCPA); and the UK Online Safety Act. We designed this Policy to satisfy the most stringent applicable standard across all of these regimes.

This Policy is reviewed quarterly by our legal and compliance teams. Where law changes require updates, we will notify all users by email with no less than 14 days’ notice before the updated Policy takes effect. Continued use of the platform following that notice constitutes acceptance.
Foundation

2.Who This Policy Covers

This Policy applies to every person or entity that interacts with the SGSuperFans platform in any capacity. There are no exceptions.

Covered Parties

  • Visitors: Any person who accesses the public-facing pages of the SGSuperFans website without registering an account, including persons browsing landing pages, legal documents, and promotional content.
  • Registered Fans: Any person who has created a fan account for the purpose of viewing, purchasing, or engaging with creator content.
  • Creators: Any person who has applied for and received creator status on the platform, regardless of whether they have posted content that is age-restricted.
  • Agency and Business Accounts: Any organization, management company, or talent agency that operates accounts on behalf of creators or fans through our agency/business access tier.
  • Third-Party Performers: Any person who appears in content uploaded to the platform by a creator, whether or not that person has their own SGSuperFans account.

Covered Transactions and Interactions

This Policy governs all transactions and interactions on the platform, including but not limited to account registration, content viewing, content uploading, subscription purchases, tip and gift payments, pay-per-view purchases, event ticket purchases, paid direct messages, shoutout requests, 1-on-1 voice and video calls, and any participation in live streaming sessions.

Accessing the platform through a virtual private network (VPN), proxying service, or any other method designed to obscure your true location or identity does not exempt you from the requirements of this Policy. We may suspend accounts where we have reasonable grounds to believe that geo-bypassing tools are being used to circumvent our verification systems.
Foundation

3.Minimum Age Requirement

The minimum age to access, register for, or use SGSuperFans in any capacity is 18 years of age. This applies universally, without exception, regardless of: the type of content a user intends to view; the country from which the user is accessing the platform; whether the user has parental consent; or whether the content the user intends to access is itself explicitly sexual or merely general entertainment.

We set our minimum age at 18 for all users, not merely for those accessing adult content, for three foundational reasons:

  • Financial transactions: The platform facilitates subscriptions, tips, purchases, and payouts. These are financial transactions that require the legal capacity to contract, which in most jurisdictions (including all Canadian provinces and most U.S. states) is attained at the age of majority, which is 18 or 19 depending on the province.
  • Potential exposure to adult content: Even if a user navigates only to general content sections, platform architecture means that age-restricted thumbnails, promotional materials, and creator profile elements may be visible. A single minimum age for the entire platform eliminates ambiguity.
  • Data and privacy compliance: Major data protection regimes impose heightened obligations when personal data is collected from minors. A platform-wide 18-plus standard enables us to apply a uniform, adult-focused data processing regime without per-user differentiation.

Jurisdictions with Higher Minimums

Where the applicable law of a user’s jurisdiction sets a higher age of majority or a higher age for accessing the type of content available on this platform, the higher age applies. Users are responsible for knowing and complying with the laws of their own jurisdiction.

Verification

4.Fan Age Verification

Fan accounts are subject to a layered age verification approach. The intensity of verification scales with the sensitivity of service access: browsing public profiles requires less verification than purchasing subscription content or engaging with age-restricted material.

Tier 1: Registration-Level Verification

At account registration, all users must provide: (a) a date of birth confirming they are 18 or older; (b) a valid email address; and (c) acceptance of our Terms of Service and this Policy. The date of birth is used to calculate age and is stored in our systems. Providing a false date of birth is a material breach of our Terms of Service and may constitute fraud under applicable law.

Tier 2: Payment-Triggered Verification

Before completing any financial transaction, including but not limited to purchasing a subscription, paying for a pay-per-view item, tipping a creator, purchasing an event ticket, or booking a 1-on-1 call, users must complete enhanced verification. This step requires submission of a government-issued photo identification document processed through our third-party verification provider.

Tier 3: Adult Content Access Verification

Before a fan can view any content designated as adult or explicit by a creator, the fan must have successfully completed enhanced identity verification. Users who have not completed this step will see a content gate requiring verification before proceeding. This gate cannot be bypassed.

Verification status may be revoked at any time if we receive evidence that the information submitted was false, fraudulent, or obtained by unauthorized means. Revocation results in loss of access to verified-only features until a new, successful verification is completed.
Verification

5.Creator Identity and Age Verification

Creators are held to a higher standard of verification than fans because they bear direct responsibility for the content they upload and the financial relationships they maintain with fans. No creator may publish any content, whether free, subscriber-exclusive, or pay-per-view, until full identity verification has been completed and approved.

What Creators Must Submit

  • Government-issued photo identification: A current, unexpired passport, national identity card, or driver’s license. The document must clearly show the creator’s full legal name, date of birth (confirming they are at least 18), photograph, and the issuing authority’s details.
  • Liveness selfie: A real-time selfie photograph taken during the verification session to confirm that the person submitting the ID is the same person depicted on the document and is physically present.
  • Consent acknowledgment: Explicit acceptance of our Creator Content Agreement and acknowledgment that they understand their obligations under 18 U.S.C. 2257 and equivalent laws in their jurisdiction.

Verification Turnaround

Our verification provider processes submissions in real time or near real time for the majority of cases. Where manual review is required due to image quality or document authenticity questions, the process may take up to 72 business hours. We will notify the creator by email of the outcome.

Re-Verification Requirements

Creators must complete re-verification whenever: their verified identity document expires; they change their legal name; we have reason to believe that their original verification was fraudulent; or 24 months have passed since their most recent successful verification. Failure to complete re-verification within the timeframes specified results in suspension of content publishing and payout processing until verification is restored.

Creator accounts that have not completed verification cannot receive payouts. Pending earning balances are held and not forfeited; however, they will not be released until verification is successfully completed or, if the account is terminated, until applicable holding periods have elapsed.
Verification

6.Our Verification Technology Partner

SGSuperFans uses Didit (didit.me), a professional identity verification provider, to process all enhanced age and identity verification requests. Didit is a trusted, globally recognized identity verification platform that complies with applicable data protection laws in Canada, the European Union, and the United States, including PIPEDA, GDPR, and CCPA.

Why We Chose a Third-Party Verification Partner

Entrusting identity document processing to a dedicated specialist rather than performing it in-house offers three critical advantages: first, specialized security infrastructure specifically designed for handling sensitive identity documents; second, access to real-time document authentication databases and liveness detection technology that reduces the risk of spoofing and forgery; and third, independent audit trails that demonstrate our due diligence to regulators and law enforcement.

How the Process Works

  • The user initiates verification within their SGSuperFans account dashboard.
  • The user is directed to a secure Didit-hosted verification session, either within the platform interface or via a secure link.
  • The user captures their identity document and completes a liveness check.
  • Didit processes the submission and returns a pass or fail result to SGSuperFans, along with a verification reference number.
  • SGSuperFans records the outcome and verification status in the user’s account. We do not receive or store the raw document images; Didit retains those separately under its own data processing agreement.

Data Processing Agreement

SGSuperFans maintains a Data Processing Agreement (DPA) with Didit that establishes the terms under which Didit processes personal data on our behalf. That processing is governed by the applicable law of our primary jurisdiction (Ontario, Canada) as well as the requirements of GDPR where EU user data is involved. Didit’s separate privacy policy applies to the data it holds during and after the verification process.

Verification

7.Documents and Information We Collect

We collect the minimum information necessary to establish and maintain age verification compliance. The specific information collected depends on the verification tier triggered.

Information Collected at Registration (All Users)

  • Email address
  • Date of birth (self-declared)
  • Country of residence
  • IP address at registration, for fraud prevention and jurisdiction determination

Information Collected During Enhanced Verification (Fans and Creators)

  • Government-issued photo ID (document type, issuing country, document number, full legal name, date of birth, and expiry date as extracted from the document)
  • Liveness selfie photograph (processed and retained by Didit; not stored on SGSuperFans systems in raw form)
  • Verification session timestamp, outcome code, and Didit reference number stored on SGSuperFans systems

What We Do Not Collect

We do not collect or store full credit card numbers, banking credentials, social security numbers, national insurance numbers, or biometric templates independently of the verification session. Our payment processing is handled by PCI-DSS-compliant third-party processors (Stripe, PayPal).

For detailed information on how we use, share, and protect all personal data collected through this Policy, please refer to our Privacy Policy. For data subject rights including access, correction, and deletion requests, please contact privacy@sgsuperfans.com.
Adult Content

8.Age-Restricted Content Defined

For the purposes of this Policy, “Age-Restricted Content” means any content that may only be accessed by adults who have completed enhanced identity verification. Creators must explicitly designate their content appropriately, and our systems automatically apply designation rules for certain content types.

Explicitly Designated Age-Restricted Content

Content is age-restricted where it includes or depicts any of the following:

  • Sexually explicit conduct, as defined in 18 U.S.C. 2257, including actual or simulated sexual intercourse, masturbation, sadistic or masochistic abuse, or the lascivious exhibition of the genitals or pubic area
  • Non-sexual nudity that is presented in a sexual context or marketed as adult content
  • Depictions of sexual fetish, role-play, or adult fantasy content
  • Any content that the creator explicitly designates as adults-only through our content tagging system

Categories That Are Automatically Age-Gated

Even where a creator has not explicitly marked content as age-restricted, our moderation systems automatically apply age gating to content determined by image or video analysis tools to contain nudity or explicit material. Creators may not override these automatic classifications without review by our Trust and Safety team.

What Is Not Age-Restricted

The following categories of content are not considered age-restricted under this Policy and do not require enhanced verification to access: general lifestyle content, fitness and wellness content without nudity, music, art, performance content, comedy, educational material, and general creator-fan communications that do not contain explicit imagery.

Even for content that is not itself age-restricted, all platform users must still be 18 or older, as confirmed during registration. The absence of age-restricted content on a specific creator’s profile does not waive this requirement.
Adult Content

9.Creator Obligations Before Posting Age-Restricted Content

Before a creator may post any content that falls within the definition of Age-Restricted Content, they must have satisfied each of the following obligations without exception. These obligations are ongoing; creators must re-confirm compliance whenever they publish new age-restricted content.

Pre-Publication Checklist

  • Completed identity verification: The creator’s Didit identity verification must be in an active, approved state at the time of publication.
  • Verified all performers: Every person depicted in the content must have had their age and identity verified to the standard set out in Section 10 of this Policy. Publishing content featuring an unverified person is prohibited.
  • Obtained written consent: The creator must hold a signed consent agreement from every performer depicted, confirming that the performer is 18 or older, that the performance was consensual, and that the performer authorizes the publication of the specific content.
  • Stored 2257-compliant records: All records required under 18 U.S.C. 2257 must be completed, organized, and stored before the content is published. See Section 11 for full requirements.
  • Applied correct content designation: The creator must correctly designate the content as age-restricted during the upload process and ensure that appropriate category tags are assigned.
  • Compliance with applicable law: The creator confirms that the content does not violate the laws of either Canada (the platform’s home jurisdiction) or the creator’s country of residence, including laws on obscenity, indecency, and the protection of persons who appear in the content.

Prohibition on AI-Generated Content of Apparent Minors

SGSuperFans absolutely prohibits any content, whether photograph, video, animation, or AI-generated imagery, that depicts or appears to depict a person under the age of 18 in any sexual context. This prohibition applies regardless of whether the depicted individual is real or fictional, and regardless of any claim that the depicted individual is a character claimed to be over 18. AI-generated characters designed to appear as minors in sexual contexts violate this Policy and are subject to immediate removal and account termination without warning.

Violation of this section is treated as a zero-tolerance offense. Accounts found in breach are permanently terminated and, where legally required, referred to law enforcement. There is no appeal process for violations involving child sexual abuse material (CSAM) or AI-generated equivalents.
Adult Content

10.Performer Age Verification Requirements

Where a creator produces age-restricted content featuring persons other than themselves (individually referred to as a “Performer”), the creator bears full responsibility for verifying each Performer’s age and identity before production and before any content featuring that Performer is published on the platform.

Required Documentation per Performer

For each Performer appearing in age-restricted content, the creator must obtain and retain copies of the following:

  • A government-issued photo identification document confirming that the Performer is 18 years of age or older at the time of production. Acceptable documents are: passport, national identity card, or driver’s license. Expired documents are not acceptable.
  • If the Performer uses a professional name or alias in the content, copies of documentation confirming both the legal name and the alias, and confirming their connection to the same individual.
  • A consent agreement signed by the Performer confirming their legal name, date of birth, agreement to participate, and authorization to publish the specific content.

Record Location and Access

As the primary producer of age-restricted content, the creator is the Custodian of Records for all Performer documentation under 18 U.S.C. 2257. Records must be maintained at a specific physical or electronic address that is disclosed to SGSuperFans upon request. The creator must respond within 5 business days to any request from SGSuperFans to produce these records, and within the timeframes applicable law requires in the event of official inspection.

Sub-Page Reference

For the complete record-keeping format requirements, custodian of records disclosures, and inspection procedures required under U.S. federal law, please read our dedicated 18 U.S.C. 2257 Compliance Statement.
Adult Content

11.18 U.S.C. 2257 Compliance and Record-Keeping

SGSuperFans acknowledges its obligations as a secondary producer under 18 U.S.C. 2257 and its implementing regulations at 28 C.F.R. Part 75. As a secondary producer, we do not create the visual depictions of actual sexually explicit conduct; our creators do. However, our platform role still engages secondary producer obligations, and we take those obligations seriously.

Creator as Primary Producer

Each creator who produces and uploads age-restricted content to our platform functions as the primary producer under 18 U.S.C. 2257. The primary producer bears the primary legal obligation to: inspect the identification of each performer before production commences; create and maintain records for each performer including legal name, any names used in production, date of birth, and the content produced; and make those records available for inspection.

SGSuperFans as Secondary Producer

As the platform that hosts and distributes age-restricted content created by its users, SGSuperFans may constitute a secondary producer with respect to that content. To satisfy secondary producer obligations, we: (a) require each creator to certify age verification compliance before publishing; (b) enforce our verification systems as described in this Policy; (c) maintain records of creator verification status and certifications on file; and (d) cooperate fully with any inspection or investigation by the U.S. Attorney General or authorized agents.

Record Retention Duration

Records required under 18 U.S.C. 2257 must be maintained for a minimum of 7 years from the date of production of the relevant content. Where content remains live on the platform, records must be maintained for the duration that the content remains accessible plus the 7-year minimum. Records may not be destroyed following account termination without specific written confirmation from our compliance team.

Creators who fail to maintain 2257-compliant records expose themselves to criminal penalties under U.S. federal law. SGSuperFans cannot assume liability for a creator’s failure to maintain required records as the primary producer. Creators are strongly advised to consult qualified legal counsel familiar with 18 U.S.C. 2257 before uploading any content that may constitute sexually explicit material.
Adult Content

12.Content Age Gates

All age-restricted content on SGSuperFans is protected by an aggressively enforced technical gate. A user cannot view, preview, access, or interact with age-restricted content by any means unless they have successfully completed enhanced identity verification. This gate functions at both the platform level (no unverified account can see flagged content) and the content level (individual pieces of content carry independent access controls that the creator cannot disable).

How the Gate Works

  • Age-restricted content is flagged in our database at the time of upload, either by the creator’s explicit designation or by our automated content analysis tools.
  • When a user attempts to navigate to or access flagged content, our platform checks the user’s verification status before serving any content.
  • Users without verified status receive a notice explaining that age verification is required, with a call-to-action to complete verification. No thumbnail, preview, blur-through, or other partial access is provided.
  • Verified users with confirmed adult status and active accounts can access flagged content subject to the creator’s pricing and subscription configuration.

No Gate Bypass

Attempting to bypass, circumvent, or defeat the content age gate by any technical or other means is a violation of our Terms of Service, may violate applicable computer fraud and abuse laws, and will result in immediate account termination. Reported bypasses are investigated and referred to law enforcement where warranted.

Search and Discovery Restrictions

Age-restricted content does not appear in search results, discovery feeds, or promotional placements visible to unverified users. Creatorprofiles that produce primarily adult content are de-indexed from public-facing search engine results by default, unless the creator has specifically enabled public indexing and is operating a fully verified account.

Protection

13.Protecting Minors from Platform Access

Preventing minors from accessing our platform is a non-negotiable obligation. We implement a multi-layer protective framework that combines technical controls, contractual requirements, active monitoring, and rapid response protocols.

Technical Safeguards

  • All registration forms require entry of a date of birth, which is validated to reject dates that would indicate an age below 18.
  • Identity verification through Didit includes biometric liveness checks that reduce spoofing attempts by minors using adult identification documents.
  • Our fraud prevention systems flag accounts where indicators of youth (such as self-disclosed educational status, school email addresses, or inconsistent behavioral signals) are present.
  • Device fingerprinting and IP reputation checks are applied at registration to identify accounts originating from children’s devices, schools, or parental control environments.

COPPA Compliance

The Children’s Online Privacy Protection Act applies to users under the age of 13 in the United States. We do not knowingly collect personal data from any person under the age of 13. Where we discover that a user under 13 has created an account, we will immediately delete all data associated with that account and notify relevant parties in accordance with applicable law. For Canadian users, these protections align with PIPEDA’s consent requirements, which require verifiable parental consent for users under the age of legal majority.

Cooperation with Parents and Guardians

If a parent or legal guardian discovers that a minor has created an account on SGSuperFans, they should contact us immediately at trust@sgsuperfans.com. We will prioritize such reports, immediately suspend the account pending investigation, and delete all associated data subject to our legal retention obligations. We will not charge any fees or penalties in connection with an account created by a minor.

Protection

14.Reporting Underage Users or Content

We rely on our user community, as well as our own systems, to identify and report accounts that may belong to minors or content that may feature underage individuals. Reporting concerns is not only an option; for creators who become aware of potential violations, it is an obligation.

How to Report

  • In-platform reporting: Every user profile and piece of content on SGSuperFans includes a report function. Select “Age or Identity Concern” as the report reason.
  • Email reporting: Send detailed reports to trust@sgsuperfans.com with as much supporting detail as possible.
  • Crisis reports: Where you believe a child is in immediate danger, contact your local law enforcement immediately before filing a platform report. Emergency situations take priority over platform processes.

What Happens After a Report

  • Reports are triaged by our Trust and Safety team within 4 business hours of receipt.
  • Flagged accounts are provisionally suspended and flagged content removed pending investigation.
  • Our team reviews available verification records, behavioral signals, and any supporting evidence provided by the reporting party.
  • Investigations are completed within 72 hours for the majority of cases. Complex cases may require up to 10 business days.
  • Where investigation confirms that a minor has accessed the platform or appeared in content, the matter is escalated to our legal and compliance team and, where required, reported to law enforcement and the National Center for Missing and Exploited Children (NCMEC) CyberTipline.
Protection

15.Consequences for Misrepresentation of Age

Providing false information about your age at any stage of the verification process is a serious violation with severe consequences. We treat age misrepresentation as a material and fundamental breach of our Terms of Service.

Consequences for Users Who Misrepresent Their Age

  • Immediate account termination: The account will be permanently closed. All content posted by the account will be removed. Follower counts, subscriptions, and platform connections associated with the account will be eliminated.
  • Fund forfeiture: Any balance held in a fan wallet associated with the account may be forfeited where the account misrepresented its age to access paid content or services.
  • Subscription cancellations: All active subscriptions are cancelled, and no refunds are provided for subscription fees paid under a fraudulently registered account.
  • Legal referral: Where the user was a minor at the time of account creation, we will notify the law enforcement authorities of the jurisdiction in which the minor resides, as required by applicable law.

Consequences for Creators Who Allow Underage Performers

  • Immediate account termination: Permanent and irrevocable.
  • Earnings forfeiture: All earnings from content featuring unverified or underage performers are forfeited and subject to clawback from pending payouts.
  • Law enforcement referral: SGSuperFans will report the matter to local law enforcement and, where the content involves sexually explicit material featuring a minor, to NCMEC and relevant Canadian law enforcement agencies.
  • Legal action: SGSuperFans reserves the right to pursue civil claims against creators who cause us to incur regulatory fines, legal fees, or reputational harm as a result of publishing content featuring underage individuals.
There are no warnings, second chances, or appeals for violations involving minors in explicit content. This is a zero-tolerance policy applied with full force.
Rights

16.Verification Appeals and Dispute Resolution

We recognize that our verification systems, while highly accurate, may occasionally produce incorrect results. An eligible user may appeal a failed or declined verification through our formal appeals process. This process applies to users whose verification was declined for technical reasons or document quality issues, and to creators whose accounts were suspended following a verification review.

Who Can Appeal

Appeals are available for: (a) users whose identity verification was declined due to document image quality or processing errors; (b) users who believe their verification was declined based on inaccurate information; and (c) creators whose publishing or payout access was suspended pending re-verification where they believe the suspension was issued in error.

Who Cannot Appeal

Appeals are not available for: (a) accounts confirmed to have been created by or for persons under the age of 18; (b) accounts terminated following discovery of CSAM or equivalent content; (c) accounts where identity forgery was confirmed; or (d) accounts terminated for any zero-tolerance violation listed in Section 15.

How to Submit an Appeal

  • Submit your appeal by email to appeals@sgsuperfans.com within 14 days of receiving notice of the adverse decision.
  • Include your account username, the email address associated with the account, the specific decision you are challenging, and the reason you believe the decision was incorrect.
  • Where applicable, attach a clearer copy of your identification document or any additional documentation that supports your appeal.

Appeal Resolution Timeframes

We acknowledge receipt of appeals within 2 business days. Standard appeals are resolved within 10 business days. Complex cases may require up to 21 business days. Our decision on appeal is final and constitutes the conclusion of the internal review process. Users who disagree with a final appeal determination may pursue external dispute resolution as provided in our Terms of Service.

International

17.International Compliance Framework

SGSuperFans serves users across the globe. Our verification and age protection standards are designed to satisfy the most demanding applicable legal standards across all jurisdictions from which we accept users. The following is a summary of our compliance posture under key international regimes.

Canada (PIPEDA and Provincial Law)

As a Canadian corporation, PIPEDA is our foundational data protection framework. We collect only the personal data necessary for the purposes described in this Policy, obtain meaningful consent before processing, allow access and correction rights, and maintain security safeguards appropriate to the sensitivity of the data. The age of majority in Ontario (our jurisdiction of incorporation) is 18, which is the standard we apply platform-wide.

United States (COPPA, 18 U.S.C. 2257, CCPA)

We do not knowingly collect data from users under 13 (COPPA). We maintain 2257-compliant records as described in Sections 10 and 11. We treat age and identity verification data as sensitive personal information under CCPA and do not sell it. California residents have additional rights under CCPA explained in our Privacy Policy.

European Union (GDPR and AVMSD)

For users in the EU, we process personal data under the lawful basis of compliance with a legal obligation (Article 6(1)(c) GDPR) and, where applicable, consent. Verification data involving biometric processing is handled by Didit, which operates an EU-compliant processing framework. Users in the EU have rights of access, rectification, erasure, restriction, portability, and objection. Our Data Protection Officer can be reached at privacy@sgsuperfans.com.

United Kingdom (Online Safety Act)

The UK Online Safety Act imposes robust age assurance requirements on platforms where users may encounter legal but harmful material and on platforms that distribute user-generated pornographic content. Our verification system is designed to satisfy the “highly effective” age assurance standard contemplated by that legislation. We maintain detailed records of our verification methodology available for Ofcom review upon request.

Australia (Online Safety Act 2021)

We comply with the Australian Online Safety Act by maintaining take-down procedures for harmful content, operating our Trust and Safety reporting processes, and cooperating with the eSafety Commissioner as required.

Rights

18.Verification Data Retention

We retain verification data for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, and to protect our legitimate business interests. The following retention periods apply.

Active Account Retention

For active user accounts, we retain verification records for the duration of the account plus 7 years from the date the account is closed. This 7-year post-closure period satisfies both 18 U.S.C. 2257 minimum retention requirements and standard commercial limitation periods in Canadian and U.S. jurisdictions.

Terminated Account Retention

For accounts terminated due to policy violations involving age misrepresentation or underage access, we retain a complete record of the verification data, the violation findings, and the remedial action taken for a minimum of 10 years. This extended period reflects the possibility of regulatory investigations, civil claims, or criminal proceedings arising from the same underlying events.

Deletion Rights and Exceptions

Users in jurisdictions that confer a right to erasure (such as the GDPR right of erasure) may submit deletion requests to privacy@sgsuperfans.com. We will honor these requests where legally permissible. However, deletion of verification data will be declined or limited where: (a) the data is required to comply with 18 U.S.C. 2257 record-keeping obligations; (b) the data is relevant to an ongoing or reasonably anticipated legal proceeding; or (c) deletion would prevent us from complying with a lawful regulatory inspection.

Security of Retained Data

All verification data retained on SGSuperFans systems is encrypted at rest using AES-256 and in transit using TLS 1.3. Access is restricted to designated compliance personnel with legitimate need and is logged for audit purposes. Verification data is stored in geographically isolated, access-controlled data centers with redundant security measures.

Legal

19.Limitation of Liability

While SGSuperFans implements robust verification systems and maintains strict age protection protocols, we operate a platform through which third-party creators upload and distribute content. Our ability to prevent all misrepresentation by all users, despite our best efforts, is not absolute. This section defines the limits of our legal responsibility.

Verification Conducted in Good Faith

Our verification processes are designed and operated in good faith and in accordance with industry best practices and applicable legal requirements. We use a professionally accredited verification provider and apply automated and manual review layers. However, we cannot guarantee that every document submitted is genuine or that every user who completes verification is who they claim to be. Advanced identity fraud techniques, including sophisticated document forgery, occasionally defeat even expert verification systems.

Creator Indemnification for Performer Violations

Each creator agrees, as a condition of using the platform, to indemnify, defend, and hold harmless SGSuperFans Inc., its directors, officers, employees, and agents from and against all claims, losses, liabilities, damages, fines, penalties, costs, and expenses (including reasonable legal fees) arising from or related to: (a) any failure by the creator to verify the age and identity of performers they depict in content; (b) content published by the creator in violation of this Policy or 18 U.S.C. 2257; or (c) any false certification or representation made by the creator regarding age verification compliance.

Liability Cap

To the maximum extent permitted by applicable law, SGSuperFans’s aggregate liability to any individual user arising from verification-related claims under this Policy, whether in contract, tort, or otherwise, shall not exceed the lesser of: (a) the total fees paid by that user to SGSuperFans in the 12 months preceding the claim; or (b) CAD $500.

Nothing in this section limits our liability for death or personal injury caused by our negligence, fraud, or fraudulent misrepresentation, or any other liability that cannot be excluded or limited under applicable law.
Contact

20.Compliance Contact Directory

If you have questions, concerns, or requests relating to this Age Verification Policy, please use the appropriate contact below. Routing your inquiry correctly helps us respond as quickly as possible.

Age Verification and Compliance

General questions about our verification process, verification failures, or compliance obligations.

compliance@sgsuperfans.com

Trust and Safety (Priority)

Reports of underage users, harmful content, CSAM concerns, or any urgent child safety issues. Monitored 24 hours a day, 7 days a week.

trust@sgsuperfans.com

Verification Appeals

Formal appeals of declined verification decisions or account suspensions related to this Policy.

appeals@sgsuperfans.com

Privacy and Data Rights

Data subject access requests, erasure requests, or questions about verification data processing under GDPR, PIPEDA, or CCPA.

privacy@sgsuperfans.com

18 U.S.C. 2257 Record Inspections and Legal Notices

Official inspection requests, regulatory correspondence, and legal notices relating to our secondary producer obligations or creator record-keeping.

legal@sgsuperfans.com

Response Time

We respond to compliance inquiries within 5 business days. Trust and Safety reports are triaged within 4 business hours. Verification appeals are acknowledged within 2 business days.

SGSuperFans Inc. is incorporated and principally operating in Ontario, Canada. Correspondence by post may be directed to our registered address, available upon request through legal@sgsuperfans.com.