Introduction

Indieline S.L. B56433113 (“Xtok,” “we,” “our,” or “us”), a company registered in Spain at Paseo Marques de Monistrol, 5, 28011, Madrid, Spain, operates the Xtok platform (http://xtok.one) (“Site” or “Platform”), a content sharing service where “Creators” upload and monetize content (e.g., videos) and “Fans” subscribe to or purchase that content via subscriptions, pay-per-view (PPV), or donations. Upon registration, users receive 69 internal credits.

This 18 U.S.C. §2257 Statement (“Statement”) is provided in compliance with the record-keeping requirements of 18 U.S.C. §2257 and 28 C.F.R. Part 75, which mandate that producers of visual depictions of actual or simulated sexually explicit conduct maintain and make available records verifying the age and identity of performers. Xtok acts solely as an interactive computer service and hosting provider (analogous to 47 U.S.C. §230 in the U.S.), facilitating the transmission, storage, and display of user-generated content. We are not a primary or secondary producer of such content but require Creators to comply with these regulations.

1. Age of Models

All persons appearing in any visual depiction of actual or simulated sexually explicit conduct on this Platform were over the age of eighteen (18) years at the time the visual content was created. We require all Creators to confirm and warrant that:

• All individuals depicted are 18 years of age or older at the time of production.
• Age verification is conducted via our third-party provider, SumSub, which collects government-issued identification (e.g., passport, driver’s license) and a selfie for each Creator and Content Collaborator.

2. Our Role as a Service Provider

Xtok acts solely as an interactive computer service and hosting provider under principles analogous to 47 U.S.C. §230, facilitating the transmission, storage, retrieval, hosting, and formatting of content posted by Creators. Indieline S.L. (Xtok) is not a “producer” (primary or secondary, as defined in 18 U.S.C. §2257 or §2257A) of any content appearing on the Platform:

• We do not create, commission, direct, or otherwise exercise editorial control over user-uploaded content.
• All visual depictions displayed on Xtok are, to the best of our knowledge, exempt from the record-keeping requirements of 18 U.S.C. §2257 and §2257A because our activities are limited to hosting and transmission of user-generated content, unless otherwise indicated by specific content ownership.

3. Creator Responsibility and Compliance

All persons who upload or publish content on Xtok (“Creators” and “Co-Creators”) must adhere to and comply with 18 U.S.C. §2257, §2257A, and 28 C.F.R. Part 75 where applicable. This includes:

• Maintaining proper age-verification records for each individual depicted in actual or simulated sexually explicit conduct, including:
  • Full legal name and date of birth.
  • Government-issued photographic identification (e.g., passport, driver’s license).
  • Signed consent forms from each performer.
• Retaining these records for a minimum of 7 years from the date of creation or last use of the content, as required by 28 C.F.R. § 75.5.
• Providing such records to Xtok or any duly authorized inspector (e.g., U.S. Department of Justice) upon request within 7 business days.

Creators represent and warrant that all required compliance steps have been taken. Failure to comply may result in account suspension or termination.

4. Notice of Removal

Pursuant to 18 U.S.C. §2257(h)(2)(B)(v) and 47 U.S.C. §230(c), Xtok reserves the right to remove or disable access to any content at our discretion, including but not limited to content that we believe is:

• Indecent, obscene, defamatory, or otherwise in violation of our Terms of Service or Acceptable Use Policy .