18 U.S.C. 2257

Record-Keeping Requirements Compliance Statement

FansClique — Operated by Mediagaze Limited

Effective Date: 25 August 2025  |  Last Revised: March 2026

1. Platform Classification & Applicability

FansClique is a multi-creator digital content platform operated by Mediagaze Limited (Company No. 16645155), incorporated in England and Wales. All content made available on FansClique is user-generated by independent Creators.

FansClique does not produce, direct, commission, or exercise editorial control over Creator Content. Mediagaze Limited therefore operates as a Secondary Producer under 18 U.S.C. 2257 and 28 C.F.R. Part 75, to the extent that US federal law applies to non-US operators hosting user-generated content. FansClique does not take the position that it is entirely exempt from 2257 obligations and instead maintains the following framework to ensure compliance.

2. Age Verification Requirements

FansClique requires all Creators to complete a mandatory age and identity verification process (KYC) before being permitted to upload any Content. As part of this process:

1. Creators must confirm, through verified government-issued identification, that they are at least 18 years of age;
2. Creators must confirm and warrant that all persons featured in their Content were at least 18 years of age at the time of production;
3. Creators must retain documentary evidence of the age verification of all performers featured in their Content as required by 18 U.S.C. 2257 and 28 C.F.R. Part 75;
4. Creators must make such records available to FansClique upon request and to any duly authorised inspector as required by law.

3. Creator Record-Keeping Obligations (Primary Producers)

Each Creator who produces Content featuring one or more persons engaged in sexually explicit conduct is the Primary Producer of that Content and bears the primary record-keeping obligation under 18 U.S.C. 2257. Specifically, each Creator must:

• Maintain records containing the legal name, date of birth, and any aliases of every performer featured;
• Retain copies of at least one identification document for each performer verifying age (passport, driving licence, government ID);
• Keep such records for a minimum of 7 years from the date of production or last date of distribution, whichever is later;
• Make records available for inspection by authorised government officials during normal business hours.

4. Platform Obligations (Secondary Producer)

As a Secondary Producer — an entity that reproduces, distributes, or makes available content produced by others — Mediagaze Limited adopts the following compliance measures:

1. Requires Creators to certify, at the point of upload, that all performers are 18 years of age or older and that required 2257 records are maintained by the Creator;
2. Maintains records of Creator KYC verification confirming Creator identity and age eligibility;
3. Retains upload metadata including timestamps and Creator account associations for all Content;
4. Reserves the right to request and review Creator 2257 records at any time;
5. Cooperates fully with law enforcement and regulatory authorities in any investigation relating to content compliance;
6. Immediately removes any Content found to violate age verification requirements and refers confirmed violations to law enforcement.

5. Custodian of Records

6. Zero Tolerance for Non-Compliance

FansClique maintains a zero-tolerance policy toward any Content involving persons under 18. Any such Content is:

• Removed immediately upon detection;
• Reported to the Internet Watch Foundation (IWF), the National Crime Agency (NCA), and the National Center for Missing & Exploited Children (NCMEC) within 24 hours;
• Referred to all applicable law enforcement authorities.

Creator accounts associated with such Content are permanently terminated with no right of appeal and all associated funds are forfeited.

7. Non-US Platform Notice

Mediagaze Limited is a United Kingdom company. While FansClique adopts the 18 U.S.C. 2257 framework as a best-practice compliance standard, this statement also reflects compliance with the UK Online Safety Act 2023, UK age verification requirements, and applicable international standards for platforms hosting adult content. FansClique's compliance obligations are interpreted in light of all applicable UK and international law in addition to US federal requirements.

8. Contact

2257 / Compliance:  [email protected]

Legal:  [email protected]