18 U.S.C. § 2257 Statement

18 U.S.C. § 2257, enacted as part of the Child Protection and Obscenity Enforcement Act and subsequently amended, establishes mandatory record-keeping requirements for all “producers” of visual depictions of actual sexually explicit conduct. The statute is implemented through regulations promulgated by the United States Department of Justice at 28 C.F.R. Part 75, which specify in detail the form, content, organization, and production of required records.

The underlying legislative purpose of 18 U.S.C. § 2257 is to prevent the exploitation of minors in adult content by ensuring verifiable age documentation exists for every performer depicted in applicable visual depictions. Congress determined that age verification and record-keeping are essential tools to combat underage exploitation in the production and distribution of sexually explicit material.

SGSuperFans Inc. (“SGSuperFans,” “we,” “us,” or “our”) is a corporation incorporated under the laws of the Province of Ontario, Canada. Although 18 U.S.C. § 2257 is a United States federal statute, SGSuperFans maintains this compliance framework in good faith, recognizing that the Platform is accessible to users in the United States and that the underlying legislative objective of protecting minors from exploitation is a shared value of significance in Canada and internationally.

Governing Regulations

The primary regulatory authority for 18 U.S.C. § 2257 compliance is 28 C.F.R. Part 75, which addresses, among other matters: the definition of producer and the obligations of primary versus secondary producers (28 C.F.R. § 75.1); required records (28 C.F.R. § 75.2); the organization and indexing of records (28 C.F.R. § 75.3); the cross-reference statement requirement (28 C.F.R. § 75.6, 75.8); and inspection rights (28 C.F.R. § 75.4, 75.5). Creators are advised to review 28 C.F.R. Part 75 in its entirety and to consult legal counsel regarding their individual obligations.

The following definitions govern the interpretation of this Statement. Where applicable, definitions are drawn directly from 18 U.S.C. § 2256 and 28 C.F.R. § 75.1. In the event of any ambiguity, the statutory and regulatory definitions shall prevail over any summary provided here.

Sexually Explicit Conduct

“Sexually explicit conduct” means actual, not merely simulated: (a) sexual intercourse, including genital-genital, oral-genital, anal-genital, or oral-anal contact, whether between persons of the same or opposite sex; (b) bestiality; (c) masturbation; (d) sadistic or masochistic abuse; or (e) lascivious exhibition of the anus, genitals, or pubic area of any person. (18 U.S.C. § 2256(2)(A))

Producer

“Producer” means any person who: (i) produces, assembles, manufactures, publishes, duplicates, reproduces, or reissues a book, magazine, periodical, film, videotape, digital image, or other matter containing a visual depiction of actual sexually explicit conduct; or (ii) inserts on a website a digital image of, or otherwise manages the sexually explicit content of a website that contains, a visual depiction of actual sexually explicit conduct. (28 C.F.R. § 75.1(c))

Primary Producer

“Primary producer” means any person who produces, assembles, or manufactures a visual depiction of actual sexually explicit conduct. A creator who films, photographs, or otherwise captures original sexually explicit footage or images is a primary producer and bears the full record-keeping obligations set out in 28 C.F.R. § 75.2.

Secondary Producer

“Secondary producer” means any person who publishes, duplicates, reproduces, or reissues a visual depiction of actual sexually explicit conduct. SGSuperFans, as a hosting and publishing platform, qualifies as a secondary producer for content uploaded by individual creators. Secondary producer obligations are narrower than those of the primary producer, but remain legally significant.

Performer

“Performer” means any person depicted in actual sexually explicit conduct in a visual depiction subject to 18 U.S.C. § 2257.

Visual Depiction

“Visual depiction” includes undeveloped film and videotape, data stored on computer disk or by electronic means that is capable of conversion into a visual image, and any photograph, film, video, picture, digital image, or computer-generated or computer-altered image of an actual human being. It includes thumbnails and screenshots derived from applicable content.

Custodian of Records

“Custodian of records” means the person or entity designated by a producer to maintain and make available for inspection the records required under 18 U.S.C. § 2257 and 28 C.F.R. Part 75.

This Statement applies to every visual depiction of actual sexually explicit conduct that is published, hosted, distributed, or otherwise made available through the Platform. The following criteria determine whether a particular piece of content falls within the scope of this Statement and the underlying statute.

Covered Content

• Visual depictions depicting performers engaged in actual (not merely simulated) sexually explicit conduct as defined in Section 2 above.
• Content produced on or after November 1, 1990, the effective date established by 28 C.F.R. § 75.2(a).
• Content published on, or distributed through, the Platform by creators, regardless of the creator’s nationality, the nationality of the performers, or the country in which the content was produced.
• Video, photographic, and other digital content meeting the definition of “visual depiction” and depicting actual sexually explicit conduct involving one or more performers.
• Thumbnails, previews, and excerpts derived from covered content are themselves subject to this Statement and to applicable cross-reference statement requirements.

Content Not Covered

• Content that is purely text-based and contains no visual depictions.
• Drawings, cartoons, illustrated artwork, digital artwork, or other non-photorealistic images that do not depict actual human beings engaged in actual sexually explicit conduct.
• Simulated (non-actual) conduct in commercially released mainstream media products, where no performers engaged in actual sexually explicit conduct during production.
• Visual depictions produced exclusively prior to November 1, 1990, subject to the caveat that age verification of performers may still be required under other applicable laws and Platform policies.
• Content depicting nudity alone, without depiction of actual sexually explicit conduct as defined above, provided no performer is depicted in the lascivious exhibition of genitals or pubic area within the meaning of the statute.

SGSuperFans operates the Platform as a hosting, publishing, and distribution service that enables creators to upload, publish, and monetize user-generated content. In that capacity, and in respect of covered content uploaded to the Platform by individual creators, SGSuperFans qualifies as a “secondary producer” within the meaning of 28 C.F.R. § 75.1(c)(2).

SGSuperFans does not independently produce, film, direct, cast, script, or otherwise create the sexually explicit content uploaded by creators. SGSuperFans has no involvement in the production process and does not engage performers on its own behalf. The individual creators who upload content to the Platform are the primary producers of that content and bear independent, primary legal obligations under 18 U.S.C. § 2257.

Secondary Producer Obligations

As a secondary producer, SGSuperFans’s compliance obligations include:

• Requiring all creators, as a condition of publishing applicable content on the Platform, to certify in writing their compliance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75 as primary producers.
• Maintaining records of all such certifications, including the date and method by which each certification was obtained.
• Implementing technical systems to facilitate the display of cross-reference statements in connection with applicable content.
• Maintaining the records required of secondary producers under 28 C.F.R. § 75.3, which may include copies of producer certifications and records of the name and address of primary producers.
• Cooperating with lawful inspection requests from the U.S. Attorney General or designated agents in accordance with 28 C.F.R. § 75.4 and 75.5.

The statutory framework established by 18 U.S.C. § 2257 and 28 C.F.R. Part 75 allocates the core compliance burden as between primary and secondary producers. This Section sets out the allocation of responsibilities between SGSuperFans and the individual creators who publish applicable content on the Platform.

Creator Responsibilities (Primary Producers)

Each creator who uploads visual depictions of actual sexually explicit conduct to the Platform is solely and independently responsible as the primary producer for:

• Verifying that every performer depicted in such content was at least 18 years of age at the time of the production of the relevant visual depiction.
• Obtaining a qualifying government-issued photo identification document from each performer prior to production and retaining a legible, verified copy.
• Recording each performer’s legal name, date of birth, and all aliases, stage names, or pseudonyms used in connection with the content.
• Maintaining the complete performer record set in organized, accessible form for the required retention period, commencing from the date of production or the last date of publication, whichever is later.
• Including a proper cross-reference statement identifying the custodian and location of records in, on, with, or affixed to, every covered visual depiction published on the Platform.
• Providing SGSuperFans with written certification of compliance as required by the Platform’s publishing terms.

SGSuperFans Responsibilities (Secondary Producer)

• Collecting and maintaining written certifications from all creators prior to permitting publication of covered content.
• Operating identity verification systems to authenticate the identity of all creators as a precondition to publishing explicit content.
• Maintaining the Custodian of Records contact information described in Section 12 of this Statement.
• Cooperating with all lawful inspections, subpoenas, and legal processes directed to SGSuperFans in its capacity as secondary producer.
• Enforcing Platform policies that require creator compliance with primary producer obligations, including account suspension and termination for non-compliance.

Every creator who publishes visual depictions of actual sexually explicit conduct to the Platform is a primary producer under 18 U.S.C. § 2257 and bears independent and non-delegable legal obligations under the statute. These obligations exist regardless of the creator’s relationship with SGSuperFans and persist throughout the full retention period applicable to each visual depiction, including after the content is removed from the Platform.

As a condition of accessing the Platform’s content publishing features for applicable content, each creator agrees that:

• The creator has verified the age and identity of every performer depicted in actual sexually explicit conduct in the relevant visual depictions, prior to or at the time of production, and not merely at the time of upload.
• The creator has obtained and retains a legible copy of at least one qualifying government-issued photo identification document for each such performer, as further described in Section 7 of this Statement.
• The creator has documented the full legal name of each performer, together with all stage names, aliases, and pseudonyms used by that performer in connection with any visual depiction published on the Platform.
• The creator’s records have been organized so as to enable cross-referencing between each performer’s identity records and the specific visual depictions in which that performer appears.
• The creator will make all required records available for inspection by the U.S. Attorney General’s designated agent in accordance with applicable law.
• The creator has included, or will include, a proper cross-reference statement with each covered visual depiction published on the Platform, identifying the creator as the custodian of records and providing the address at which the creator’s records are maintained.
• The creator will notify SGSuperFans within 24 hours if any records pertaining to active content on the Platform are lost, destroyed, compromised, or become unavailable for inspection.

Under 28 C.F.R. § 75.2, primary producers must maintain specific records for every performer depicted in actual sexually explicit conduct. The following sets out the minimum documentation requirements that each creator acting as a primary producer must satisfy.

A. Identity Records for Each Performer

• Legal name: The performer’s full legal name exactly as it appears on the qualifying identification document obtained from the performer.
• Date of birth: The performer’s date of birth as confirmed by the qualifying identification document.
• Aliases and stage names: Each alias, stage name, professional name, and pseudonym used by the performer in connection with any visual depiction that is or has been published on the Platform, listed with the corresponding visual depictions in which each alias appears.

B. Qualifying Identification Documents

At least one of the following qualifying government-issued photo identification documents must be obtained and retained for each performer, confirmed as genuine prior to or at the time of production:

• A passport issued by the United States, Canada, or any country that is a member of the European Union.
• A driver’s license bearing a photograph of the performer and issued by a governmental authority of the United States or Canada.
• Any other government-issued identification card bearing a photograph that was issued by a governmental entity of the United States, Canada, or a country that is a member of the European Union.
• Any other similar identification document, provided it bears a photograph of the performer and was issued by a recognized governmental authority.

C. Content Records

• A title, description, or other identifier sufficient to identify each visual depiction of actual sexually explicit conduct to which the record pertains.
• The date on which each visual depiction was produced, if known and reasonably determinable.
• The date on which each visual depiction was first published on the Platform.
• A cross-reference index linking each covered visual depiction to the identity records of the performer or performers depicted therein.

D. Producer Records

• The full legal name of the primary producer (the creator) responsible for maintaining the records.
• The business or residential address at which the records are maintained and available for inspection.

Under 28 C.F.R. § 75.6 and § 75.8, every visual depiction of actual sexually explicit conduct must bear, at the point where the depiction is displayed, a cross-reference statement that directs any inspection to the location where the relevant records are maintained.

Required Cross-Reference Statement

The cross-reference statement must be “18 U.S.C. 2257 Record-Keeping Requirements Compliance Statement” and must identify the records custodian and the address at which the records are kept. The following language satisfies the regulatory requirement:

Placement Requirements

• For visual content: The cross-reference statement must appear in the content description, in a label, or in a disclosure associated with the specific visual depiction, displayed at the point where the depiction is delivered to the viewer.
• For the Platform: SGSuperFans includes a platform-level cross-reference statement on this Statement page, which is accessible from every page of the Platform, as a secondary-producer level disclosure.
• The statement must be clearly legible and readily accessible to any viewer of the content.
• Creators must update the cross-reference statement whenever the custodian’s address or contact information changes.

Platform-Level Cross-Reference Statement

Individual creators who are primary producers are responsible for establishing and maintaining the primary record set for each performer depicted in covered content. These records must be maintained in a manner that enables timely production upon an authorized inspection request.

Organization Requirements

Under 28 C.F.R. § 75.3, records must be organized in a manner that enables cross-referencing between: (a) each performer’s identity records and all visual depictions in which that performer appears; and (b) each visual depiction and the identity records of all performers depicted therein. An alphabetical index by performer surname (using legal name) and a separate index by content title or identifier are each separately sufficient for compliance, though both are recommended.

Security and Integrity

• Records must be stored securely to prevent unauthorized access, and creators are responsible for any breach of record security that compromises the personal information of performers.
• Electronic records must be protected against unauthorized modification. Creators should use tamper-evident storage methods where practicable.
• Physical records must be stored in a locked facility accessible only to authorized personnel.
• Backup copies should be maintained separately to protect against loss or destruction.

Availability for Inspection

• Records must be available for inspection by the U.S. Attorney General’s designated agent during regular business hours, as further described in Section 13 of this Statement.
• Records must be produced in a readable format. Where records are maintained electronically, the creator must be prepared to produce paper copies or a readable electronic format upon reasonable request.
• Creators must notify SGSuperFans within 24 hours of any loss, destruction, or compromise of records pertaining to content currently active on the Platform.

Post-Removal Obligations

A creator’s record-keeping obligations do not terminate upon removal of content from the Platform. Records must be maintained for the full retention period calculated from the later of the date of production or the last date on which the content was publicly available on the Platform, as described in Section 11 of this Statement.

SGSuperFans, in its capacity as secondary producer, maintains a distinct category of compliance records. These are not substitutes for the primary records that must be maintained by individual creators, but represent SGSuperFans’s own secondary producer compliance documentation.

Categories of Platform Records

• Creator certifications: Written certifications from each creator attesting to their compliance, as a primary producer, with 18 U.S.C. § 2257 and 28 C.F.R. Part 75, including the date and method by which each certification was obtained.
• Identity verification records: Records of the identity verification process completed by each creator prior to publishing applicable content, including the verification method, date, and outcome, as maintained by SGSuperFans’s verified identity verification service provider.
• Content publication logs: Records identifying each visual depiction subject to this Statement that has been published on the Platform, including the creator, date of publication, and date of any removal.
• Enforcement action records: Records of any enforcement actions taken by SGSuperFans against creators for non-compliance with 18 U.S.C. § 2257 obligations or Platform policies implementing those obligations.
• Inspection and legal process records: Records of all inspection requests, government investigations, subpoenas, and other legal processes received by SGSuperFans in connection with 18 U.S.C. § 2257 compliance.

Records required under 18 U.S.C. § 2257 and 28 C.F.R. Part 75 must be maintained for a minimum statutory period. SGSuperFans’s Platform policies impose additional retention and security requirements above the statutory minimum on SGSuperFans’s own records.

Minimum Retention Period

All primary records must be maintained for the longer of: (a) seven (7) years from the date of production of the visual depiction to which the records relate; or (b) two (2) years from the last date on which the applicable visual depiction is sold, transferred, or otherwise disseminated from the custodian’s inventory or website.

Security Standards for Platform Records

• Electronic records held by SGSuperFans are encrypted at rest using AES-256 or equivalent encryption and are transmitted exclusively over encrypted channels (TLS 1.2 or higher).
• Physical records, if any, are stored in locked facilities with access restricted to authorized compliance personnel.
• Records are backed up on a regular schedule, with backup copies maintained in a geographically separate location to protect against loss by disaster or system failure.
• Access to SGSuperFans’s compliance records is restricted on a need-to-know basis and is subject to access logging and audit trail requirements.

Records Hold Obligations

Records subject to this Statement may not be destroyed if SGSuperFans has received, or reasonably anticipates receiving, any subpoena, court order, inspection request, or other legal hold directive relating to those records. The destruction of records subject to a hold obligation may constitute criminal obstruction of justice or contempt of court.

Record Destruction Procedures

Upon expiration of the applicable retention period and in the absence of any hold obligation, records must be destroyed by a documented procedure that ensures personally identifiable information is permanently and irretrievably eliminated. Electronic records must be overwritten or cryptographically erased; physical records must be shredded or incinerated. All destruction events must be documented in a destruction log maintained by the applicable custodian.

In accordance with 28 C.F.R. § 75.3 and § 75.6, SGSuperFans designates the following as the Custodian of Records for records maintained by SGSuperFans in its capacity as secondary producer. This designation does not create any obligation on SGSuperFans to maintain primary producer records, which remain the sole responsibility of individual creators.

Designated Custodian

Inspection Hours

Platform-level records maintained by SGSuperFans are available for authorized inspection during the following hours, subject to advance scheduling requirements described in Section 13:

• Monday through Friday, 9:00 a.m. to 5:00 p.m. Eastern Time (ET).
• Excluding statutory public holidays in the Province of Ontario, Canada.
• Emergency requests from law enforcement may be accommodated outside these hours; contact legal@sgsuperfans.com for urgent matters.

Creator-Level Records

For records maintained by individual creators in their capacity as primary producers, the cross-reference statement included with each individual creator’s content identifies the creator as the custodian and provides the address at which those records are maintained. SGSuperFans does not act as custodian for individual creator records and is not responsible for the accuracy, completeness, or availability of those records.

Under 18 U.S.C. § 2257(f) and 28 C.F.R. § 75.4 and § 75.5, the U.S. Attorney General, or a person duly authorized by the Attorney General, may inspect the records required to be maintained under the statute. SGSuperFans is fully committed to cooperating with all lawful inspection requests.

Inspection of Platform Records

Authorized inspection agents seeking access to records maintained by SGSuperFans as secondary producer should direct requests to the Custodian of Records identified in Section 12 above, at 2257@sgsuperfans.com. The following procedures apply:

• Requests should be submitted in writing, identifying the authority of the inspection requestor and the specific records or categories of records sought.
• SGSuperFans will acknowledge receipt of an inspection request within one (1) business day.
• Inspections will be scheduled at a mutually agreeable time during the inspection hours set out in Section 12, unless emergency access is required.
• Inspecting agents must present valid credentials to the satisfaction of SGSuperFans’s designated compliance personnel before records are made available.
• SGSuperFans will produce the requested records in a readable format within the timeframe required by applicable regulation.

Inspection of Creator Records

Individual creators, as primary producers, are independently subject to inspection of their records by the U.S. Attorney General’s authorized agents. SGSuperFans will:

• Facilitate contact between authorized inspection agents and individual creators upon receipt of a lawful inspection request directing SGSuperFans to do so.
• Take immediate enforcement action, up to and including account suspension and termination, against any creator who fails or refuses to cooperate with a lawful inspection request.
• Remove from the Platform any content for which the applicable creator has failed to produce records upon a lawful inspection demand.

Canadian and International Law Enforcement

Law enforcement and regulatory authorities in Canada and other jurisdictions seeking records from SGSuperFans should direct requests through the applicable mutual legal assistance treaty (MLAT) framework or contact legal@sgsuperfans.com directly. SGSuperFans will process all lawful requests from Canadian and international authorities in accordance with applicable law, including the requirements of the Canadian Criminal Code, PIPEDA, and any applicable privacy legislation.

SGSuperFans operates a multi-layered technical and procedural verification architecture designed to confirm creator identity, support compliance with age verification obligations, and prevent the publication of content involving minors or unverified performers.

Creator Identity Verification

• All creators must complete identity verification through SGSuperFans’s designated third-party identity verification service before they are permitted to publish any explicit content.
• The identity verification process includes: document scan and authenticity assessment; biometric liveness verification; facial match between the creator’s selfie and the submitted identification document; and data cross-reference against authoritative sources where available.
• Verification outcomes are retained as part of SGSuperFans’s secondary producer compliance records.
• Creator accounts that fail identity verification are restricted from publishing explicit content pending resolution of the verification failure.

Content Pre-Publication Review

• All content submitted by creators for publication is subject to a pre-publication review process prior to being made available to other users.
• AI-assisted screening is applied to detect visual characteristics associated with potential underage performers or other compliance concerns.
• Content flagged by automated screening is escalated to human review by trained compliance personnel before any publication decision is made.
• Content that cannot be conclusively confirmed as depicting only adult performers, or for which a valid creator certification cannot be associated, is rejected and the creator is notified.

Ongoing Monitoring

• Creator accounts are subject to periodic re-verification of identity. Changes to identity documents must be submitted to the Platform within 30 days of the change.
• SGSuperFans operates an ongoing monitoring program for published content, utilizing automated tools and periodic human review.
• Creators’ certification status is reviewed periodically. Creators who do not maintain current certifications may have their ability to publish applicable content restricted.

Failure by a creator to comply with 18 U.S.C. § 2257, 28 C.F.R. Part 75, or the creator obligations set out in this Statement may result in any or all of the following consequences. SGSuperFans reserves the right to determine the appropriate response at its sole discretion, subject to applicable law.

Platform Enforcement Actions

• Content removal: Immediate and permanent removal of all affected visual depictions from the Platform, without notice or opportunity to cure in cases involving suspected minor exploitation.
• Account suspension: Suspension of the creator’s account pending investigation of the non-compliance, during which the creator is unable to publish, earn, or interact with subscribers.
• Permanent account termination: Permanent closure of the creator’s account, with forfeiture of any pending earnings and a permanent prohibition on creating any future accounts on the Platform.
• Clawback of earnings: SGSuperFans reserves the right to withhold or claw back any earnings attributable to non-compliant content, in addition to any other remedies available.

Legal Consequences

• Law enforcement referral: SGSuperFans will refer credible evidence of criminal non-compliance to appropriate law enforcement agencies in Canada, the United States, or any other applicable jurisdiction.
• NCMEC reporting: Any content or conduct involving suspected exploitation of minors will be reported immediately to the National Center for Missing and Exploited Children (NCMEC) CyberTipline, as required by the PROTECT Our Children Act (42 U.S.C. § 13032).
• Indemnification: Creators are required under the Platform’s Terms of Service to indemnify SGSuperFans for any costs, fines, penalties, or damages arising from the creator’s failure to comply with applicable law, including 18 U.S.C. § 2257.
• Civil liability: Nothing in this Statement limits SGSuperFans’s right to pursue civil claims against creators for losses arising from non-compliance.

SGSuperFans is unconditionally committed to full cooperation with law enforcement and regulatory authorities in matters relating to record-keeping compliance, child protection, and all related criminal or regulatory investigations. Cooperation with lawfully authorized process is not discretionary.

Mandatory Reporting Obligations

• SGSuperFans is required under the PROTECT Our Children Act (42 U.S.C. § 13032) to report apparent child sexual abuse material (CSAM) to the NCMEC CyberTipline whenever SGSuperFans becomes aware of facts or circumstances from which there is an apparent violation of federal laws relating to child exploitation.
• Reports to the NCMEC CyberTipline are made promptly and without undue delay upon the detection or receipt of apparent CSAM. The relevant content is preserved, the report is made, and the content is removed from the Platform.
• SGSuperFans cooperates fully with any investigation initiated by NCMEC, the Federal Bureau of Investigation (FBI), the Internet Crimes Against Children (ICAC) Task Force, or any equivalent domestic or international authority.

Response to Legal Process

• SGSuperFans will comply with all valid subpoenas, court orders, search warrants, and other legal process served in accordance with applicable law, including those directed to SGSuperFans as a Canadian corporation under applicable Canadian procedural law or pursuant to a mutual legal assistance treaty.
• Emergency requests from law enforcement involving imminent risk to a child may be submitted to legal@sgsuperfans.com and will be treated with the highest priority.
• Non-emergency law enforcement requests should follow the ordinary legal process applicable to the requesting authority’s jurisdiction.

Jurisdictional Considerations

SGSuperFans is a corporation incorporated under the laws of the Province of Ontario, Canada. Legal process directed to SGSuperFans is subject to Canadian procedural rules and applicable privacy legislation. United States law enforcement seeking records from this Canadian entity should utilize the US-Canada Mutual Legal Assistance Treaty (MLAT) framework, which is administered through the U.S. Department of Justice’s Office of International Affairs. SGSuperFans will cooperate fully with all MLAT-compliant requests.

Although 18 U.S.C. § 2257 is a United States federal statute, SGSuperFans’s compliance obligations are informed by a broader international legal framework. The Platform is accessible globally, and SGSuperFans strives to ensure that its compliance posture meets or exceeds the applicable standards in all principal jurisdictions from which the Platform is accessible.

Canadian Law

• Criminal Code of Canada, s. 163.1: Prohibits child pornography and imposes mandatory reporting and cooperation obligations on those who become aware of the existence of child pornography. SGSuperFans’s reporting and enforcement practices satisfy these obligations.
• PIPEDA and provincial privacy legislation: The collection, retention, use, and disclosure of performer identity records constitutes the processing of personal information subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. SGSuperFans’s record-keeping practices are designed to comply with PIPEDA’s data minimization, purpose limitation, and security safeguard requirements.
• Age of consent: For the purposes of Canadian law, the age of consent for participation in pornographic material is 18 years. SGSuperFans applies this standard to all content on the Platform, without exception, regardless of the jurisdiction in which the content was created.

United Kingdom

• The Online Safety Act 2023 imposes mandatory age assurance obligations on providers of user-to-user services and search services operating in the United Kingdom that make pornographic content available. SGSuperFans implements age verification measures consistent with guidance issued by Ofcom under the Online Safety Act.
• Creators publishing content accessible to UK users are subject to applicable UK law in addition to the obligations set out in this Statement.

European Union

• The Digital Services Act (DSA) imposes content moderation, transparency, and risk management obligations on platforms operating in the EU/EEA. SGSuperFans’s content screening and enforcement practices are designed to be consistent with DSA requirements applicable to its platform category.
• The General Data Protection Regulation (GDPR) and applicable national implementing legislation govern the processing of personal data of EU/EEA performers and users. Performer identity records constituting personal data of EU/EEA residents are processed in compliance with applicable GDPR requirements, including the requirement for an appropriate legal basis for processing and the implementation of technical and organizational security measures.

Privacy of Performer Records

• Performer identity records contain highly sensitive personal data subject to heightened protections under all applicable privacy frameworks.
• SGSuperFans does not sell, share, transfer, or otherwise disclose performer identity records except: (i) pursuant to a valid legal process served in accordance with applicable law; (ii) as required by an authorized statutory inspection; (iii) as strictly necessary to prevent, detect, or respond to imminent harm, criminal activity, or child exploitation; or (iv) with the documented, express written consent of the performer whose records are sought.
• Creators are independently responsible for ensuring their collection, use, and retention of performer identity records complies with applicable privacy law, including PIPEDA, GDPR, and any applicable U.S. state privacy law.

SGSuperFans maintains dedicated compliance and legal contact channels for all inquiries, reports, and formal notices relating to 18 U.S.C. § 2257, performer age verification, record-keeping compliance, and the reporting of suspected unlawful content. All formal notices must be submitted in writing to the appropriate contact listed below.

Compliance Contact Directory

Mailing Address

Report Suspected Unlawful Content

If you believe any content on the Platform depicts a minor or otherwise violates applicable child protection laws, report it immediately. You may also report directly to:

• NCMEC CyberTipline (USA): Report online at www.missingkids.org/cybertipline or by phone at 1-800-843-5678.
• Canadian Centre for Child Protection (Canada): Report online at www.cybertip.ca.
• Internet Watch Foundation (UK/International): www.iwf.org.uk.