18 U.S.C. 2257 Compliance Statement

Statement of Compliance

XENIA, operated by [XENIA LEGAL ENTITY NAME] at xenia.studio, maintains this statement to describe how XENIA approaches compliance with United States federal record keeping requirements, including 18 U.S.C. Section 2257 and 18 U.S.C. Section 2257A, and the implementing regulations at 28 C.F.R. Part 75, as such requirements may apply to the content available through the platform. XENIA is committed to operating a lawful platform on which every account holder is a verified adult and on which no content depicting any minor is permitted under any circumstance. This statement is to be read together with the XENIA Terms of Service and the XENIA notice and takedown policy, which are incorporated by reference and which set forth the binding obligations of every creator who uploads content.

XENIA operates as a platform and host for content uploaded by independent third party creators. XENIA does not script, direct, commission, or produce the underlying source media that creators transform and upload. To the extent any provision of 18 U.S.C. Section 2257 or Section 2257A imposes record keeping obligations with respect to specific content, those obligations rest in the first instance with the uploading creator as the primary producer of that content, and XENIA relies upon the records that each creator is required to create and maintain, as further described below.

All Depicted Persons Are Adults

XENIA requires that every person depicted in any content available through the platform was at least eighteen years of age at the time the underlying source media was created. The depiction of any person under the age of eighteen is strictly prohibited. By uploading content, every creator represents, warrants, and agrees that each person depicted in that content, including the creator and any other identifiable individual, was at least eighteen years of age at the time of creation and consented to the creation and to the upload of that content to XENIA.

XENIA does not knowingly permit, host, or distribute any content that depicts, or purports to depict, a minor. Content that is reported or otherwise identified as potentially depicting a minor is subject to immediate removal, and the responsible account is subject to immediate suspension or termination, in accordance with the procedures described below and with applicable law.

Platform and Third-Party Producer Responsibilities

XENIA is a host for user generated content. Each creator who uploads content to XENIA is the primary producer of that content within the meaning of the applicable record keeping framework, and each creator bears primary legal responsibility for that content.

As a condition of using XENIA, every uploading creator agrees, under the Terms of Service, to the following obligations:

• To ensure that every person depicted in any uploaded content was at least eighteen years of age at the time the source media was created.
• To create, maintain, and securely retain records sufficient to establish the identity and date of birth of every person depicted, including a legible copy of a government issued photographic identification document for each such person.
• To obtain and retain the documented, informed consent of every depicted person, both to the creation of the source media and to the transformation and publication of the resulting content on XENIA.
• To produce such records to XENIA, or to the appropriate authorities, upon lawful request, and to retain such records for the period required by applicable law.
• To upload only content that the creator has the lawful right to upload and to refrain from depicting any person without the documented consent of that person.

XENIA acknowledges that, by selecting, managing, reproducing, and publishing the transformed content uploaded by creators, XENIA may be a secondary producer within the meaning of 28 C.F.R. Section 75.1(c)(2). In that capacity XENIA maintains the secondary producer records identified in this statement for every creator and every published item, indexed by creator legal name, by any stage name or username, and by the title, URL, or identifier of each item, and makes those records available for inspection in accordance with 28 C.F.R. Section 75.5. XENIA is not the primary producer of the underlying source media, which it never receives, and the obligation to create and maintain the original government identification records of each depicted person rests with the creator as primary producer.

Age Verification

XENIA requires every account holder to complete full government identity verification before that account holder is permitted to post any content. Verification is performed through Yoti, an independent identity verification provider, by means of a government issued identification document scan together with a live face match, or through the Yoti application. This establishes both that the account holder is at least eighteen years of age and that the person is the account holder. Each account holder must also complete email verification before posting.

An account holder who does not successfully complete age verification and email verification is not permitted to upload or publish content. These controls are designed to ensure that every creator on XENIA is a verified adult who is at least eighteen years of age. XENIA may suspend or terminate any account where verification is found to be incomplete, falsified, or circumvented.

AI Transformation and Source Media

All visual content published on XENIA is an artificial intelligence anime style augmentation and transformation of source media supplied by the uploading creator. This transformation is produced locally within the XENIA Studio desktop application on the device of the creator. The original source media does not leave the device of the creator, and XENIA does not receive, store, or retain the original source media. XENIA stores only the transformed output that the creator chooses to upload.

Because the published content is an artificial intelligence transformation, any underlying source media that depicts a real person is created and held by the creator on the device of the creator. Accordingly, the records that establish the age, identity, and consent of any real person depicted in the source media are created and maintained by the creator as the primary producer, and not by XENIA. XENIA does not possess the source media and therefore cannot, and does not, maintain the underlying records on behalf of any creator. Each creator remains solely responsible for creating and retaining those records as required by the Terms of Service and applicable law.

Custodian of Records

For purposes of inquiries directed to XENIA regarding this statement, the designated Custodian of Records for [XENIA LEGAL ENTITY NAME] is:

• Custodian of Records: [CUSTODIAN OF RECORDS NAME]
• Address: [CUSTODIAN PHYSICAL ADDRESS]
• Compliance contact: [compliance@xenia.studio]

The records described in this statement are maintained at the above address, which is the place of business of the Custodian of Records, and are available for inspection by the Attorney General or a designee at all reasonable times during normal business hours, and in any event for not fewer than twenty hours per week, in accordance with 28 C.F.R. Section 75.5. The records are organized to be retrievable by the legal name and by any stage name or username of each creator and by the URL or identifier of each item of content. XENIA retains these records for the periods required by 28 C.F.R. Section 75.4 and for so long thereafter as any depicted content remains accessible. Records establishing the age, identity, and consent of persons depicted in specific creator content are also maintained by the uploading creators as the primary producers of that content. Requests for records related information may be directed to the Custodian of Records at the address above or to [compliance@xenia.studio].

Reporting Non-Compliant Content

XENIA provides multiple channels for any person to report content believed to depict a minor, to lack the consent of a depicted person, or to otherwise violate this statement, the Terms of Service, or applicable law:

• Use the in product report tool available on the content itself to submit a report directly to the platform owner for review.
• Submit a notice through the XENIA notice and takedown page.
• Contact the XENIA compliance team at [compliance@xenia.studio].

Upon receipt of a report, the platform owner reviews the content in question and may remove the content and may freeze, suspend, or permanently ban the responsible account. XENIA takes reports of content potentially depicting a minor with the highest priority and will act promptly, and will report such content to the appropriate authorities, as required by applicable law.

Records Are Maintained Under 18 U.S.C. Section 2257

XENIA does not assert that content available through the platform is exempt from 18 U.S.C. Section 2257 on the basis of the AI transformation. The AI anime augmentation is an aesthetic restyling of source media depicting actual persons and does not render any depicted conduct simulated within the meaning of 18 U.S.C. Section 2257A. Where content depicts actual sexually explicit conduct as defined in 18 U.S.C. Section 2256(2), the full record keeping requirements of 18 U.S.C. Section 2257 and 28 C.F.R. Part 75 apply, and each creator, as primary producer, is contractually required to create and maintain those records and to produce them on lawful demand. Nothing in this statement is a representation that any specific content is exempt from 18 U.S.C. Section 2257.

The architecture under which the original source media remains on the device of the creator is a privacy measure and is not a means of avoiding records obligations or of avoiding knowledge of unlawful content. XENIA maintains pre publication and report based controls to detect and remove prohibited depictions, and conditions continued access on the compliance of each creator with that creator's record keeping obligations.

Mandatory Reporting and Preservation

XENIA complies with 18 U.S.C. Section 2258A. Upon obtaining actual knowledge of any apparent child sexual abuse material, XENIA submits a report to the CyberTipline of the National Center for Missing and Exploited Children (NCMEC) as soon as reasonably possible, and preserves the reported material and associated data for at least 90 days, or longer if requested, in accordance with 18 U.S.C. Section 2258A(h). Reported material is preserved and is not deleted while a report or preservation obligation is pending; XENIA does not return or restore reported material, removes it from public access, and cooperates with law enforcement and with lawful preservation and disclosure requests. XENIA maintains internal procedures to escalate suspected child sexual abuse material to its designated reporting officer.

Automated Age Screening and Identity Checks

The XENIA Studio application screens every detected face in the source media for apparent-adult age before any render, using conservative face-age estimation, and rejects content in which any detected face is estimated to be under age. This age screen applies to every person depicted, including persons who do not hold a XENIA account. In addition, an automated face match step confirms when the verified account holder appears in the source media; full government ID verification is required of the account holder. Full identity verification of every other depicted person is not practicable, in particular for group content, and is not performed. These automated checks reduce risk but do not replace the obligation of the creator, who as primary producer must hold and produce, on lawful demand, documented proof of age and consent for every depicted person, as set out in the Terms of Service. In addition, every published media asset carries a report control that any viewer may use; reports are reviewed by the platform owner, who may remove content and freeze or ban accounts. This community reporting operates as a continuous, peer-reviewed safeguard layered on top of the on-device age screen and account verification.

General

This statement does not constitute legal advice, and it does not waive, limit, or expand any obligation of any creator under applicable law. It is to be read together with, and is qualified in its entirety by, the XENIA Terms of Service and the XENIA notice and takedown policy. In the event of any conflict between this statement and applicable law, applicable law controls. XENIA reserves the right to update this statement at any time.