18 U.S.C. §2257 Compliance Statement

Sweetly operates as a marketplace connecting independent adult content Performers with paying Members. Performers upload photos, videos, and live streams directly to their own profile and control the price and access level (free, Fan Club subscription, or Pay-Per-View) at which their Content is made available. Sweetly does not direct, script, or participate in the production of Performer Content, and does not select or arrange the individuals depicted in it.

As a condition of registration, and again before every single item of Content is published, each Performer expressly certifies, under her or his own responsibility, that every person appearing in that Content was at least 18 years old at the time the Content was produced, and that the Performer holds, or has verified the existence of, all consents and records required by applicable law for every person depicted.

This certification is a mandatory, repeated step in the Performer's workflow, not a one-time acknowledgment: a Performer cannot complete an upload or go live without reaffirming it. A false certification is a material breach of our Terms of Service, results in immediate removal of the Content and suspension of the Account pending investigation, and may be reported to law enforcement, including the National Center for Missing & Exploited Children (NCMEC), as required by law.

Before a Performer Account is approved and before any Content can be published, Sweetly requires the Performer to complete a mandatory identity and age verification process, including submission of a government-issued identification document and a live or photographic check matching the applicant to that document. This process is designed to confirm that the Performer herself or himself is at least 18 years old and to establish a verified identity on file, consistent with the platform-level obligations described in this statement.

Where Content depicts more than one person, the performing Performer remains responsible, as primary producer of that Content, for obtaining and maintaining the age and identity verification records required by law for every other person depicted, in accordance with Section 5 below.

To the extent Sweetly is deemed a secondary producer of any Content under 18 U.S.C. §2257 or §2257A, the following person is designated as Custodian of Records:

• Compliance Officer, Tinklab Ltd
• First Floor Office, 3 Hornton Place, London, W8 4LZ, United Kingdom

Records required to be maintained under applicable law, to the extent held by Sweetly, are available for inspection by the appropriate authorities at the above address, at the times and in the manner required and limited by 28 C.F.R. Part 75 and applicable law. This statement does not constitute a general invitation to inspect records outside the scope, timing, and process prescribed by law.

As the primary producer of her or his own Content, each Performer is independently responsible for creating and retaining the age and identity records required by 18 U.S.C. §2257 and equivalent laws for every person depicted in that Content, and for making those records available as required by law. Registration on Sweetly and completion of our internal verification process does not relieve a Performer of this independent, personal record-keeping obligation.

Sweetly may request that a Performer provide copies of, or confirm the existence of, such records at any time, including in response to a legal request, a content report, or a routine compliance review, and a Performer's failure to promptly provide satisfactory records upon request will result in removal of the associated Content and may result in suspension or termination of the Performer's Account.

This statement, and the record-keeping requirements it describes, apply only to visual depictions of actual, identifiable persons engaged in actual sexually explicit conduct, as defined under applicable law. Content that does not depict actual persons, including purely fictional, animated, drawn, or similarly generated material that does not depict a real, identifiable individual, is not subject to 18 U.S.C. §2257 record-keeping requirements. This exclusion does not affect the separate, absolute prohibition on any content depicting or implying a minor, in any form, as set out in our Terms of Service.

Sweetly maintains an absolute, zero-tolerance policy against any Content that depicts, describes, or implies a person under the age of 18, in any context or format. Every user can report suspected violations through the in-platform reporting tool, including a dedicated "underage person involved" category. Any such report is treated as a critical priority: the reported Content and the associated Performer Account are immediately actioned pending investigation, and, where the report is substantiated or cannot be disproven, the matter is reported to NCMEC and/or other competent law enforcement authorities as required by applicable law.

Content published on Sweetly is understood to carry the certifications described in Section 2 in lieu of individual physical labeling on each file, consistent with the nature of a digital marketplace. Sweetly reserves the right to implement additional labeling or metadata practices as necessary to comply with evolving legal requirements.

Requests related to this statement, including lawful requests for record inspection, should be directed to the Compliance Officer at [email protected], or in writing to Tinklab Ltd, First Floor Office, 3 Hornton Place, London, W8 4LZ, United Kingdom.