Legal · draft for review

2257 Compliance.
Custodian of records.

Vantly is custodian of the platform-held records described in this statement. Each creator is custodian of performer-side records for the content they publish. This page is a first-pass draft — not final, counsel-approved text.

Draft banner.

This page is a draft produced for the operator to review before general access. The custodian statement should be reviewed and finalized by qualified counsel familiar with the prevailing 18 U.S.C. 2257 rules before the platform is opened to general access.

01

What this statement covers.

Vantly is an adults-only service. This page sets out the custodian-of-records statement published under 18 U.S.C. 2257 and related recordkeeping rules, the categories of records held, and the contact channel for inspection requests.

This statement is a draft for the operator to review before general access. It is not legal advice and not a substitute for review by qualified counsel familiar with the prevailing recordkeeping rules.

The terms of the statute and the implementing regulations can change. The current version of this page is the operative statement; updates are published at the same URL and noted as they occur.

02

Custodian of records.

Vantly is the custodian of records for platform-held records required by 18 U.S.C. 2257. Each creator is custodian of performer-side records for content the creator publishes. Both halves of the custodian trail matter, and neither substitutes for the other.

The custodian of records for platform-held records is Vantly. The custodian contact for inspection requests is trovewell-we9yit@polsia.app.

The custodian contact is the same inbox used across the platform for takedown notices, press inquiries, and creator support. Mark the subject line clearly so the inspection request is routed correctly.

03

What Vantly stores.

The platform stores the verification artifacts collected at onboarding and the upload metadata needed to satisfy the custodian trail for content hosted on Vantly.

Verified identity and age verification: the verification result and the supporting evidence the verification vendor returns, retained as required by the statute.

Account-of-record data: the verified account holder’s legal name and any documented alias, the contact channel on file, and the verification artefacts.

Upload metadata: the timestamp and geolocation metadata attached to each upload, plus the labels applied to the content at the time of publication.

Production metadata: the production dates and the production-location fields supplied by the creator at the time of upload, retained as part of the platform-held custodian trail.

04

What creators retain.

Each creator is custodian of performer-side records, including records of any third-party performers who appear in the creator’s work. The categories of records a creator must retain are described below.

Performer records: legal name, any documented stage alias, identification sufficient to verify age (typically a government-issued ID), the production date, and the production location for each performer depicted.

Third-party performer records: the same categories for every third-party performer who appears in the creator’s work, regardless of whether the third party is a Vantly user.

Signed consent records: written or otherwise durable evidence that each performer depicted was a willing adult participant whose consent was documented at the time of production.

05

Retention period.

Records are retained for the period required by the statute in force at the time the depiction was produced. Vantly does not delete platform-held records during the retention period, and creators may not delete their copies either.

The current retention period defined by the federal rules is at least several years after the last depiction was produced. The exact period is set by the prevailing federal rules and may be extended by state law in some jurisdictions.

On closure of a creator account, compliance records (identity verification, age verification, custodian records, takedown history) move into a segregated retention store and are not surfaced publicly. They are retained for the statutory period and then deleted in line with the retention policy.

06

Inspection by authorized persons.

Inspection requests from authorized persons are answered through the designated custodian contact on proper request. The procedure is described in this section.

Requests must identify the requester as an authorized person within the meaning of the statute, identify the content or performers in question, and include a contact channel for the response.

On receipt of a properly-formatted request, the custodian contact acknowledges receipt and answers the request in line with the statute. Records are made available for inspection at the custodian’s offices during normal business hours, in line with the prevailing rules.

07

Content labeling.

Age-restricted-content labeling is enforced at upload and surfaced to viewers at every interaction. The labeling scheme is part of the upload flow and is documented in the platform’s content guidelines.

All explicit content carried on the platform is labeled at upload and at every playback. The label is visible to viewers and drives age-restriction enforcement in jurisdictions where that is required.

Mislabeling content is grounds for review of the creator’s account. The label is set by the creator at upload and is verified as part of the platform’s review process.

08

Contact for inspection requests.

Inspection requests go to the custodian contact below. Mark the subject line clearly so the request is routed to the custodian of records on the team.

Inspection requests: trovewell-we9yit@polsia.app. Mark the subject line with the keyword "2257 inspection" so the message is routed correctly.

Reports involving minors are escalated immediately and reported to the appropriate authorities. The custodian-of-records channel is not the right channel for those reports; use the takedown channel on the FAQ instead.

trovewell-we9yit@polsia.app

Records referenced in the platform-held custodian trail are made available to authorized persons on proper request through the custodian contact. See the recordkeeping clause in the Terms of Service for the platform-side framing of the same duty.

See also the Privacy Policy and the Terms of Service.