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DRAFT — PENDING LEGAL REVIEW. This statement reflects Ollage, LLC's current honest position regarding record-keeping for re-published third-party adult content. Open counsel question: Whether Ollage, LLC's re-hosting of primary-produced content creates its own secondary-producer record-keeping obligations under 18 U.S.C. § 2257A, or falls within the exemptions at 18 U.S.C. § 2257(h)(2)(B)(v) and 47 U.S.C. § 230(c). This page will be finalized only after qualified adult-industry counsel confirms Ollage, LLC's compliance posture. Qualified counsel review is REQUIRED before public launch.

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

Version 2026-08-21-draft2 · Effective 2026-08-21

Position of Ollage, LLC

Ollage, LLC is a secondary producer within the meaning of 18 U.S.C. § 2257 and 28 C.F.R. § 75. Ollage, LLC does not produce, film, photograph, digitize, or otherwise create visual depictions of sexually explicit conduct. All visual depictions hosted on Ollage, LLC originate from third-party platforms and creators, who retain primary responsibility for production-related record-keeping under 18 U.S.C. § 2257.

Ollage, LLC's role is limited to transmission, storage, retrieval, hosting, and formatting of material that may depict sexually explicit conduct. This re-publication model is consistent with 18 U.S.C. § 2257(h)(2)(B)(v) and the safe-harbor provisions of 47 U.S.C. § 230(c).

Content Origin & Discovery Model

Ollage discovers and re-hosts clips originally published on third-party creator platforms. Creators may claim their profile and control what appears on Ollage. Removal on request is honored across all sources.

Minimum Age Representation

Ollage, LLC requires that all visual depictions on the platform depict individuals who were at least 18 years of age at the time of production. Ollage, LLC enforces this through:

  • Indexing only from third-party platforms with verified 18+ performer policies;
  • Immediate removal of any content where the age of a depicted person is in doubt;
  • Acceptance of age-doubt reports via in-app flags, Content Removal Form, or Take-It-Down Report.

Records Maintained by Ollage, LLC

Ollage, LLC maintains the following records in connection with account-holder age verification:

  • Date-of-birth attestations provided during account registration;
  • Results of third-party age-verification checks (where applicable per jurisdiction tier);
  • Audit trail of age-verification decisions and appeals.

These records are retained for 7 years from the date of account creation or last activity, per Ollage, LLC's Privacy Policy.

Records NOT Maintained by Ollage, LLC

Ollage, LLC does not maintain identification, age-verification, performer-consent, or production-related records for individuals depicted in re-hosted third-party content. Such records are the responsibility of the primary producers (the original platforms and creators who hold the content) and are held by them pursuant to 28 C.F.R. § 75. Ollage, LLC does not have custody of, access to, or control over those records.

If you need performer identification or production records for content re-hosted on Ollage, LLC, you must contact the original creator platform where the content was initially published.

Custodian of Records (Age-Verification Audit)

[2257 Custodian of Records — pending appointment]

[Custodian address]
[City, State ZIP]

Available: Monday–Friday, 10:00–17:00 local time (by appointment)

Contact: [email protected]

Requests for age-verification audit records must be made in writing, must identify the account or identifier in question, and are subject to legal process. Response target: 30 business days per privacy law requirements.

Reporting Suspected Child Sexual Abuse Material (CSAM)

If you believe any content on Ollage, LLC depicts minors or child sexual abuse material, report it immediately:

  • Via Ollage, LLC: In-app report button (reason: "Depicts a minor") or Take-It-Down Report Form
  • Email (target 24-hour response): [email protected]
  • Directly to NCMEC: CyberTipline.org

All confirmed CSAM reports are escalated to the National Center for Missing & Exploited Children within 24 hours.

Content Removal & Appeals

Ollage, LLC honors removal requests from account holders, content owners, copyright holders, and parties concerned about age or legality. Processes:

  • Content Removal & Appeal Form — general submissions, age doubt, legality concerns, attribution
  • Take-It-Down (NCII / CSAM) Report — suspected child exploitation
  • DMCA Takedown Notice — copyright or performer-consent violation
TermsPrivacyAcceptable UseDMCA§2257Take-It-DownContent RemovalCookiesRTA