2257 Compliance Statement

1. Purpose and Scope

1.1 What This Statement Covers

This statement sets out the obligations of Corestack Digital Ltd and of Service Providers who use the TDolls platform in relation to age verification and record-keeping for persons depicted in sexually explicit content.

It is issued in compliance with, and with reference to, 18 U.S.C. § 2257 and 28 C.F.R. Part 75 of United States federal law, which impose record-keeping and labelling requirements on producers of sexually explicit content. It also reflects equivalent obligations under applicable Gibraltar law and the laws of other jurisdictions in which the Platform operates.

1.2 Applicability

18 U.S.C. § 2257 applies to producers of visual depictions of actual sexually explicit conduct. As an intermediary platform that hosts content uploaded by independent Service Providers, Corestack Digital Ltd operates as a secondary producerunder the definitions of 18 U.S.C. § 2257. Service Providers who create and upload content to the Platform are primary producers.

The obligations of primary and secondary producers differ and are set out separately in this statement.

1.3 Relationship to Other Documents

This statement should be read alongside:

• Content Policy — which governs what content may be uploaded and by whom
• Age Verification Policy — which describes how users and content subjects are age-verified
• Service Provider Terms of Service — which incorporates these record-keeping obligations as a contractual requirement
• Modern Slavery and Anti-Trafficking Statement — which addresses the broader safeguarding context

2. Primary Producers — Service Provider Obligations

2.1 Who Is a Primary Producer

A Service Provider is a primary producer in respect of any sexually explicit visual content that they create, direct, or in which they personally appear. This includes photographs, video clips, and live streams uploaded to or transmitted via the Platform.

2.2 Record-Keeping Obligations

Every Service Provider who uploads or transmits sexually explicit content via the Platform must, before doing so, compile and maintain the following records for every person depicted in that content:

• Full legal name of the depicted person
• Date of birth of the depicted person
• Any stage names, aliases, or working names used by the depicted person
• A copy of a government-issued photographic identity document establishing the person's identity and confirming their date of birth (such as a passport, national identity card, or driving licence)
• The date the content was produced
• The title or description of the content item to which the records relate

Where the depicted person is the Service Provider themselves, these records must still be maintained in relation to each content item.

2.3 Consent Records

In addition to the age and identity records above, Service Providers must maintain evidence of the explicit consent of every person depicted in their content to:

• Appear in the specific content item
• Have that content published on the Platform
• Have that content made available in accordance with the visibility settings chosen by the provider

Consent must be freely given, specific, and informed. A general consent to being photographed is not sufficient — consent must relate to each content item and to its proposed use.

2.4 Format and Storage of Records

Records required under this section must be:

• Maintained in a secure, organised manner that allows retrieval on request
• Retained for a minimum of 7 years from the date the content is last published or transmitted on the Platform, and for a minimum of 7 years from the date of the last amendment to the record
• Held in a format that can be produced promptly in response to a lawful inspection or request

Records may be maintained in digital or physical format, or both. Digital records must be backed up and protected against loss, alteration, or unauthorised access.

2.5 Production on Request

Service Providers must make their records available for inspection upon request by:

• Corestack Digital Ltd, in the exercise of our secondary producer compliance obligations
• Any duly authorised law enforcement officer or regulatory inspector with a lawful basis for inspection
• Any other person or authority legally entitled to inspect such records under applicable law

Requests from Corestack Digital Ltd for record confirmation will be made via providers@tdolls.net. Service Providers must respond within 5 business days of such a request. Failure to respond or inability to produce records in relation to specific content will result in that content being removed from the Platform.

2.6 Declaration at Registration

By completing Service Provider registration and ticking the relevant declaration at registration, you confirm that:

• You understand your obligations as a primary producer under applicable law
• You will maintain the records required by this statement for all content you upload
• You will not upload content depicting any person whose identity and age you have not verified and for whom you do not hold the required records
• You will make those records available on request as described above

3. Secondary Producer — Corestack Digital Ltd Obligations

3.1 Our Role

As the operator of the Platform, Corestack Digital Ltd is a secondary producer under 18 U.S.C. § 2257 in respect of sexually explicit content hosted on the Platform. Our secondary producer obligations require us to maintain records of the custodian of records for each primary producer whose content appears on the Platform.

3.2 Custodian of Records

The custodian of records for all content uploaded by Service Providers is the Service Provider themselves, as primary producer. Each Service Provider is responsible for maintaining the records described in Section 2 in respect of their own content.

The custodian of records for any content produced directly by Corestack Digital Ltd (if any) is:

3.3 Inspection of Our Records

Where a law enforcement officer or other person lawfully entitled to inspect our secondary producer records wishes to do so, they may contact us at:

We will respond to lawful inspection requests in accordance with our legal obligations and our Law Enforcement Request Policy.

3.4 Content Removal for Non-Compliance

Where a Service Provider is unable or unwilling to confirm that primary producer records exist in relation to specific content, we will remove that content from the Platform. This is not a moderation or editorial decision — it is a compliance obligation. Content for which records cannot be confirmed has no place on the Platform regardless of its other characteristics.

4. Labelling

4.1 Compliance Label

In accordance with 28 C.F.R. Part 75, the following compliance statement applies to all sexually explicit content hosted on the Platform:

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

All persons depicted in sexually explicit content on this platform were 18 years of age or older at the time of production. Records required by 18 U.S.C. § 2257 and 28 C.F.R. Part 75 are maintained by the respective content producers (Service Providers) as primary producers. The custodian of records for each primary producer is the Service Provider themselves.

For secondary producer records maintained by Corestack Digital Ltd, please contact: legal@tdolls.net

4.2 Placement

This compliance statement is displayed on the Platform at tdolls.net/2257 and is accessible from the footer of every page of the Platform. It is also incorporated into the Service Provider onboarding process and confirmed by each provider at registration.

5. Non-US Jurisdictions

5.1 Gibraltar and EU

While 18 U.S.C. § 2257 is a US federal statute, the obligations it imposes reflect a standard of age verification and record-keeping for explicit content that is consistent with the expectations of regulators and law enforcement in Gibraltar, the UK, and the EU. We apply these standards across our operations regardless of the jurisdiction of access.

Under Gibraltar law and consistent with the Gibraltar GDPR, records maintained under this statement must be held securely, used only for compliance purposes, and protected from unauthorised access or disclosure.

5.2 UK

For users accessing the Platform via TDolls.uk, equivalent obligations exist under UK law. Content producers must be able to demonstrate that all depicted persons are adults. The record-keeping standards described in Section 2 satisfy these requirements.

5.3 No Exemption by Jurisdiction

A Service Provider cannot avoid the record-keeping obligations described in this statement by reason of being located or registered outside the United States. These obligations apply to all content uploaded to the Platform regardless of where the uploader is based.

6. Prohibited Content — Absolute Reminder

No record-keeping obligation, however meticulously fulfilled, creates any permission to upload content depicting a minor in a sexual context. The absolute prohibition on such content in our Content Policy Section 5.1 is unaffected by anything in this statement.

Where any doubt exists about the age of a person depicted in content, that person must be treated as under 18 and the content must not be uploaded. The burden of proof lies with the uploader. Age ambiguity is not a defence.

7. Breach and Consequences

Failure by a Service Provider to comply with the record-keeping obligations in this statement constitutes a material breach of the Service Provider Terms of Service and will result in:

• Immediate removal of the non-compliant content
• Suspension of the provider's account pending review
• Termination of the provider's account in cases of persistent or deliberate non-compliance
• Referral to relevant law enforcement authorities where the non-compliance indicates the possible depiction of a minor or a trafficking victim

Corestack Digital Ltd reserves the right to audit Service Provider record-keeping compliance at any time. Providers who cannot demonstrate compliance on audit may have their accounts suspended until compliance is established.

8. Changes to This Statement

We will update this statement to reflect changes in applicable law, regulatory guidance, or our operational processes. When we make material changes we will:

• Update the "Last updated" date and version number
• Notify registered Service Providers by email
• Display a notice on the Platform

The current version of this statement is always available at tdolls.net/2257, tdolls.eu/2257, and tdolls.uk/2257.

9. Contact

For 2257 compliance enquiries and record inspection requests:

For safeguarding concerns:

This document is version TDOLLS-2257-v1.0. The current version is always available at tdolls.net/2257, tdolls.eu/2257, and tdolls.uk/2257.