1. Objective
To establish the contractual principles and general terms and conditions that govern access, use and participation in the Seacrets platform. This policy seeks to harmonize best international practices in the adult digital entertainment sector with regulatory compliance of relevant regulatory frameworks, including the Digital Services Act (DSA) of the European Union, applicable US legislation such as FOSTA-SESTA, and child protection guidelines such as COPPA (Children's Online Privacy Protection Act).
This policy is intended to:
Establish the rights and obligations between Seacrets and users, content creators, and third parties involved.
Ensure a transparent, safe digital environment in compliance with legal provisions on platform liability, informed consent and control of unlawful content.
Promote responsible use of services, protecting both freedom of expression and fundamental rights, privacy, and digital integrity of users.
2. Acceptance and Scope
2.1 User Acceptance
When creating an account, interacting with content or using any service offered by the Seacrets platform (including access to its website, mobile applications, live broadcasts or API), the user ("User") declares and guarantees that:
They are at least 18 years of age and have reached the age of majority in their jurisdiction of residence.
They have full legal capacity to accept these Terms of Service (hereinafter, "TOS"), and
Access to sexually explicit content is legal in accordance with the local laws of the country or territory where they reside and from which they access the platform.
2.2 Scope and Applicability
These TOS constitute a legally binding agreement between the User and Seacrets, and govern access, use and participation in all services provided through:
Official Seacrets website;
Mobile applications (iOS, Android or others);
API, integrations and connected platforms;
Real-time functionalities (live broadcasts, private chats, interactions with user-generated content).
The TOS apply across all types of users and roles, including but not limited to:
Content Creators: registered users who upload, stream or monetize their own content;
Fans or consumers: registered users who access, view or purchase content;
Authorized third parties: including payment processors, moderators, business partners, advertisers or technology providers that interact with the platform.
2.3 Supplementary Documents and Contractual Nature
The acceptance of these TOS entails the express and full acceptance of the following complementary policies, which form part of the binding contractual framework between the User and Seacrets:
Anti-Money Laundering and Counter-Terrorism Financing Policy
KYC (Know Your Customer) Policy
Parental Control Policy
Chargeback Disputes and Refunds Policy
Non-Consensual Content Policy
Acceptable Use Policy
Privacy Policy
Complaints Policy
Information Security Policy
Code of Ethics and Digital Conduct
These documents – or summaries of them – will be permanently available on the platform and may be updated in accordance with regulatory or technological changes. Users will not be required to be notified of any substantial modification that affects their rights or obligations; it will be each user's responsibility to regularly review available policies and documentation.
3. Key Definitions
| Term | Meaning |
|---|---|
| Platform | Refers to the Seacrets digital ecosystem, including its official website, subdomains, mobile applications, application programming interfaces (API) and integrated third-party services (such as payment processors, live streaming tools or KYC solutions). |
| Content | All audiovisual or informational material uploaded, shared or transmitted through the Platform, including but not limited to: videos, audio, images, texts, live broadcasts, interactive publications, downloadable files, digital assets such as NFTs, and any other form of digital expression. |
| Verified Creator | A user who has passed the identity verification process required by Seacrets, including document validation, proof of majority of age and, where applicable, presentation of clear evidence of informed consent from all persons appearing in the generated or published content. |
| Proactive Moderation | Set of preventive mechanisms implemented by Seacrets to detect, block or review content before and after publication. Includes human review and automated tools such as digital fingerprinting (hash-matching), age estimation (age-estimation), and filters for prohibited words or expressions (banned-keywords), in accordance with digital security standards and protection against non-consensual or unlawful content. |
4. Guiding Principles
The operation of Seacrets is governed by a set of fundamental principles that ensure respect for user rights, legality of content and sustainability of the digital business model in compliance with global regulatory frameworks.
4.1 Legality and Transparency
Seacrets strictly complies with:
The Digital Services Regulation of the European Union (DSA-EU);
The provisions of Title 18 U.S.C. § 2257 on mandatory documentation for explicitly sexual content in the US;
Consumer protection laws in each jurisdiction where it operates; and
The compliance standards required by brands such as Visa and MasterCard, with regard to adult content, clear business practices and prevention of unlawful activities.
The provisions established by payment gateways with regard to this type of content.
All platform actions will be traceable, documented and accessible in accordance with regulatory requirements.
4.2 Consent, Non-Coercion and Child Protection
Seacrets maintains a zero-tolerance policy against:
Child Sexual Abuse Material (CSAM);
Non-consensual content;
Any form of coercion, impersonation or misrepresentation without documented authorization.
All content involving people must be supported by verifiable evidence of informed, voluntary and revocable consent.
4.3 Privacy and Security by Design
The Platform's systems have been developed under the principles of Privacy by Design and Security by Default, including:
Encryption of personal and financial data in transit and at rest;
Minimal data retention in accordance with the Privacy Policy;
Access controls and data segmentation;
Procedures for the exercise of ARCO rights and secure data deletion.
4.4 Creator Due Diligence
Before enabling a Creator as an active user, Seacrets requires strict compliance with verification and documentation processes, which include:
KYC (Know Your Customer) process with biometric authentication and document validation;
Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) controls;
File and preservation of records in accordance with 18 U.S.C. § 2257 regulations and other regulatory provisions.
4.5 Proportionate Moderation
Seacrets applies a dynamic moderation policy that seeks a responsible balance between:
The freedom of expression of users;
The legal and reputational security of the platform;
And cross-border regulatory compliance.
Moderation includes automated filters, human review, appeal mechanisms and rapid removal processes upon well-founded notices.
5. Acceptable Use Rules
Access and use of the Seacrets Platform implies express acceptance of the following rules of conduct. Failure to comply may result in immediate account suspension, content removal, notification to authorities and legal action, as appropriate.
The User is obligated to refrain from:
5.1 Intellectual Property Rights Infringement
Uploading, sharing or monetizing content that violates copyright, trademarks, image rights or any other intellectual property right without proper legal authorization.
Using third-party material (photos, videos, audio) without documented proof of ownership or valid license.
5.2 Prohibited Content Publishing
It is strictly prohibited to publish, distribute, transmit or allow access to content that includes, represents or advocates:
Child Sexual Abuse Material (CSAM), in any form, real or simulated.
Bestiality, necrophilia, incest, extreme sexual violence, mutilation or non-consensual degrading representations.
Fetishes considered illegal or pathological in accordance with applicable criminal regulations.
Sexual "Deepfakes" or synthetic representations of a sexual nature involving another person's image, without verified, verifiable and documented informed consent.
5.3 Violation of Third-Party Privacy or Integrity
Publishing, disclosing or sharing third-party personally identifiable information without their express authorization ("doxing"), including real names, addresses, phone numbers, official documents or private images.
Engaging in blackmail, sexual extortion (sextortion) or any form of threat related to the disclosure of intimate content.
5.4 Circumvention of Security Mechanisms
Manipulating, bypassing or circumventing the age verification systems, facial recognition or biometric tests established by the Platform.
Using proxies, VPNs, bots or other technical means to falsify geographic location, evade regional blocks, manipulate traffic or interfere with authentication processes.
5.5 Unlawful or Unauthorized Use of the Platform
Using Seacrets as a direct or indirect channel to offer, advertise or facilitate prostitution services, sexual exploitation, human trafficking or other conduct classified as a crime in the applicable jurisdiction or prohibited by payment network compliance schemes such as Visa/MasterCard.
Promoting fraudulent conduct, "sugar dating" networks with explicit exchange of sexual favors for money, or any type of transaction that exposes the platform or user to legal or contractual sanctions.
6. Verification and Records (18 U.S.C. §2257 & DSA Art. 28)
Seacrets implements a rigorous system of identity verification, proof of consent and record retention in accordance with child protection laws and explicit sexual content, in particular:
18 U.S.C. § 2257 (USA): obligation to maintain records of age verification and consent for all sexually explicit content.
Article 28 of the Digital Services Regulation (DSA, EU): requirement for traceability and enhanced due diligence for certain professional users, including monetized content creators.
6.1 Processes and Required Evidence Table
| Step | Document / Evidence | Support Systems |
|---|---|---|
| Creator Verification | Valid official identity document (passport, ID, license) + verifiable biometric selfie (KYC) | External KYC Platform with facial recognition and document matching analysis |
| Participant Consent (Performers) | Standard contract in accordance with 2257 model, digitally accepted by Creator, and "Release" acceptance by each participant identified in the content | Electronic contracting with timestamp and evidence of acceptance. |
| Records Retention | Minimum retention of 7 years after the last activity for each set of documents related to monetized content | Encrypted digital vault with AES-256, segmented by creator, with restricted access and regular audits |
6.2 Compliance and Audit Notes
Records are available for inspection in accordance with law by competent authorities (FTC, DOJ, payment platforms, CNIL, etc.).
Traceability and verification metadata are auditable and retain digital fingerprints (SHA-256 hash) as proof of integrity.
Access to these records is limited to the Seacrets legal and compliance team, under a "least privilege" policy and continuous monitoring.
7. Moderation, Reporting and Escalation
Seacrets applies a hybrid moderation model (human + automated) with preventive review protocols, proportionate response, documentary traceability and special channels for high-risk alerts. Measures are implemented in accordance with Articles 16, 17 and 20 of the DSA, as well as best practices from organizations such as NCMEC, StopNCII and trusted platforms.
All user-generated content will be reviewed or pre-screened before publication.
7.1 Pre-publication Moderation
Before the publication of any content, Seacrets activates mandatory preventive filters:
24/7 human review, using ethical/legal criteria.
Automatic detection systems based on Artificial Intelligence, with integration to global databases:
Content Moderation System.
Private CSAM scanning system via hash
StopNCII.org (protection against non-consensual pornography).
7.2 Post-publication Moderation
Once content is published, the Platform activates continuous monitoring cycles:
Sampling: Random manual reviews of publications every 6 hours by the Moderation team.
Community feedback system, through "Report" buttons on each publication, "Report User" on each profile and "Report Chat" on each conversation accessible to registered users and visitors.
7.3 Trusted Flagger Program
Non-Governmental Organizations (NGOs), regulatory entities and law enforcement that join the "trusted flaggers" program have access to priority reporting channels, with enhanced guarantees:
Receipt and validation of reports with documented response in ≤ 24 hours.
Encrypted record of each alert, with processing traceability and resolution adopted.
Applies to CSAM, impersonation, violence, exploitation, deepfakes and data trafficking cases.
7.4 Internal Complaints and Appeals Process
Seacrets offers users a structured mechanism to challenge moderations, suspensions or content removals, in compliance with Article 17 of the DSA:
Maximum initial resolution time: 5 business days.
Right to a single appeal, analyzed by a team different from the one that made the initial decision.
The user will receive a reasoned notification, which will include the legal or community grounds for the action taken, as well as the available remedies (including external mediation or competent authorities).
7.5 Progressive Measures and Escalation
Seacrets' response to TOS violations is proportionate and escalated, except in cases of manifest severity:
1. Formal warning (strike 1)
2. Temporary content or profile demonetization
3. Preventive access blocking
4. Definitive account termination
Serious reoccurrences (such as CSAM publication, non-consensual deepfakes, account trafficking or sexual coercion) imply:
Freezing of retained funds
Immediate reporting to competent authorities (LEA)
Proactive cooperation with judicial or regulatory processes
8. User Rights and Obligations
Users of the Seacrets Platform, in any of their roles (Creators, Fans, Third Parties), accept the following contractual provisions relating to content use, economic participation, data protection and cancellation mechanisms.
8.1 Limited License over Content
By publishing content on the Platform, the User (in particular, the Creator) grants Seacrets a worldwide, non-exclusive, transferable and sublicensable license, for the duration the account remains active, to:
Host, store, publish, transmit, distribute and promote such content within the Seacrets ecosystem and on integrated platforms (for example, CDN networks, monetization APIs or internal promotional media).
Adapt the content for technical adjustment (resolution, quality, compatible formats), without altering its substantial integrity.
The Creator retains ownership of the copyright to their content and may withdraw it at any time in accordance with the deletion procedure provided, without prejudice to applicable legal obligations.
8.2 Digital Intermediation Fee
Seacrets will charge Creators a fixed percentage fee of 20% for digital intermediation services, which includes payment processing services, infrastructure, licenses, security and general platform use for their monetization. This fee may vary without notice and will be notified to all Creator users. Additionally, the following conditions are established:
Content creators may withdraw their funds through the various options that Seacrets makes available for their geographic area.
The minimum amount for each withdrawal must be equal to or greater than USD 100.
Income generated by creators will be available for withdrawal once a processing period of fifteen (15) continuous days has elapsed from the date of the corresponding transaction (for example, subscriptions, renewals or tips). This means that if a transaction occurs on day 1 of the month, funds will be available for withdrawal starting on day 16 of the same month. This system applies continuously and automatically to each individual transaction.
All payments are subject to approval of identity verification, KYC/AML review and compliance with tax and financial crime prevention regulations.
8.3 Privacy and Digital Rights
The User has the right to:
Access their personal data, review and correct information recorded in their account.
Request data portability (export in structured format).
Exercise their right to be forgotten, by requesting account and content deletion, unless there are legal or regulatory reasons that justify their retention.
Exceptions to immediate deletion:
Files mandatory under 18 U.S.C. § 2257;
Judicial or administrative requirements in force;
Fraud prevention or regulatory investigations in progress.
See more in the Privacy Policy and Parental Control Policy
8.4 Account Cancellation and Closure
Any User who is not a Content Creator may request voluntary cancellation of their account at any time from the control panel or by direct contact with support.
Once cancellation is initiated:
The User's content will be delisted immediately and deleted within a reasonable timeframe.
Seacrets will retain technical records (activity logs, metadata, financial and operational traceability) for a maximum period of 180 days from the date of closure, solely to address:
Open regulatory or legal investigations;
Internal audits;
Litigation or requests from competent authorities.
In the case of a Creator User, the retention period for technical records will be 7 years.
9. Limitation of Liability
Seacrets provides access to its platform, tools and services "as is" and "as available", without granting any warranties whatsoever—express, implied or legal—with respect to:
The suitability of content for a particular purpose;
The continuity, availability, accuracy or security of services;
The absence of errors, interruptions or vulnerabilities.
9.1 Exclusion of Indirect Liability
In no event shall Seacrets be liable for:
Loss of income, profits, savings or economic opportunities;
Indirect, incidental, consequential, punitive or exemplary damages;
Loss, corruption or unauthorized access to personal data or content;
Damages arising from interactions between users, including fraud, impersonation, harassment or misuse of content.
This exclusion applies even if Seacrets has been warned of the possibility of such damages.
9.2 Exception for Willful or Gross Negligence
Nothing in this clause shall limit Seacrets' liability in case of:
Willful misconduct;
Gross negligence;
Intentional breach of non-derogable legal obligations.
9.3 Aggregate Liability Limit
In all cases permitted by applicable law, the maximum cumulative financial liability of Seacrets to the same User, for any cause and under any legal theory (contractual, non-contractual, strict or otherwise), shall be limited to:
The total amount of fees actually paid by such User to Seacrets in the twelve (12) months preceding the event giving rise to the claim.
This clause is understood without prejudice to the minimum guarantees that cannot be excluded under applicable legislation in the User's jurisdiction.
9.4 Content that Puts Life or Physical Integrity at Risk
The Platform reserves the right, but not the obligation, to suspend, block or delete any live broadcast, recording or content that, in the reasonable judgment of Seacrets, involves activities that pose an imminent risk to the physical or mental health, life or integrity of persons involved, including Content Creators.
This power may be exercised immediately, without prior notice, and without right to compensation or reimbursement of unreceived income. Seacrets may notify competent authorities if situations of emergency or vital risk are identified.
9.5 Exemption for Damages Arising from Voluntary Participation
Seacrets shall not be liable for any physical, psychological, emotional damage, nor for health incidents, injuries or death that may result from voluntary actions taken by Content Creators before, during or after any broadcast, publication or activity conducted through the Platform.
Content Creators assume full responsibility for their participation, guaranteeing that they are in fit physical and mental condition to perform the activities they decide to share, and release Seacrets from any claims arising from such decisions.
10. Regulatory Compliance and Cooperation with Authorities
Seacrets commits to operating in accordance with international legal standards on child protection, cybersecurity, human rights and unlawful activity control, maintaining an active cooperation policy with competent authorities.
10.1 Notifications from Authorities (LEA – Law Enforcement Agencies)
Official requests from judicial, police or regulatory authorities must be sent through the exclusive email: [email protected]
Requests must include:
Legal basis, issuing authority and case number
Nature of the information required
Response deadline
If applicable: requirement for temporary preservation of data or specific content
Reimbursement of administrative and processing costs will be applied in accordance with international guidelines adopted by platforms such as Aylo, when permitted by applicable law.
10.2 Transparency in Accordance with DSA
As an active digital platform in the European Union, Seacrets complies with the Digital Services Regulation (DSA, Art. 15 and 24) by publishing a transparency report every six months, which includes:
Volume and type of content removal requests received
Average response time per category
Disciplinary actions applied to infringing accounts
Results of the Trusted Flaggers moderator program
Metrics on use of automated moderation systems
This report will be publicly available on the official website, following the model adopted by other industry platforms.
10.3 Geographical Blocking and International Sanctions
Seacrets implements geoblocking mechanisms and access restrictions in accordance with:
International sanctions lists (OFAC, European Union, United Kingdom, Canada)
State or local restrictions on adult content or related financial activities
Banking exclusion policies (for example, by Visa and MasterCard networks)
The system detects and blocks access from prohibited jurisdictions through IP verification, geolocation, document matching and KYC alerts.
11. Changes and Validity
Seacrets may modify these Terms of Service to reflect relevant legal, technical or commercial updates. Modifications will be governed by the following principles:
Any modification will be notified at least fifteen (15) days before its entry into force.
Notification will be made through:
Registered email of the User; and
Notification to affected users by the change.
Continued use of the Services after the effective date of changes shall constitute implicit and binding acceptance of the new Terms.
In case of disagreement, the User may exercise their right to cancel in accordance with clause 8.4 – Account Cancellation and Closure – without penalty or loss of access to accumulated balances, unless they are frozen for compliance reasons.
12. Version History
| Version | Description | Date | Approved By |
|---|---|---|---|
| 0.9-Draft | Internal circulation | 01-01-2025 | Legal Office |
| 1.0 Review | Initial publication | 10-15-2025 | Board of Directors |
Board of Directors Approval
Policy Identification
| Policy Name | Terms of Service Policy |
|---|---|
| Version | 1.0 |
| Effective Date | October 15, 2025 |
| Responsible Department | Legal Office |