This statement explains the position of HB Technologies LLC, operator of friendswith.ai (the “Service”), with respect to the federal record-keeping requirements of 18 U.S.C. §2257 and 28 C.F.R. Part 75.

No real performers

All visual depictions, photographs, video, audio, and likenesses appearing on the Service are computer-generated, fictional, and do not depict any real human being. Imagery is produced through machine-learning and image-synthesis models trained on properly licensed datasets, and is reviewed by our content team before publication.

Because no actual human performers engage in any sexually explicit conduct on the Service, the record-keeping and labeling requirements of 18 U.S.C. §2257 and §2257A do not apply to the visual content produced and hosted by HB Technologies. To the extent any image, alone or in combination, could be construed as actual sexually-explicit conduct under 18 U.S.C. §2256(2)(A), HB Technologies relies on the safe-harbor provisions of 18 U.S.C. §2257A(h) for entirely simulated content.

User-uploaded content

Users may, with their account, upload photographs of themselves to send to a Character. By uploading such content, each user represents and warrants that:

• they are at least 18 years of age (or the age of majority in their jurisdiction, whichever is greater);
• all individuals depicted in the content are at least 18 years of age and have given informed consent to the depiction and to its transmission to a Character on the Service;
• they have the right to upload the content and to grant HB Technologies the licenses described in our Terms of Service;
• the content does not violate applicable law.

HB Technologies does not produce user-uploaded content within the meaning of 18 U.S.C. §2257(h)(2)(B)(v); we are a passive host of user-submitted material and rely on the protections of 47 U.S.C. §230 and 17 U.S.C. §512.

Custodian of records

The custodian of records for any visual content for which §2257 record-keeping obligations might apply is:

HB Technologies LLC
Attn: §2257 Custodian of Records
c/o Registered Agent (available on request)
New York, New York, USA
compliance@friendswith.ai

Inquiries from law-enforcement officers and others with a legal right to inspect records should be directed to the email address above. Records, where required, are maintained in accordance with 28 C.F.R. Part 75.

Reporting concerns

If you believe any content on the Service violates this statement, applicable law, or our Terms of Service — including any concern that a depiction may resemble a real person without consent or appears to depict a minor — please contact trust@friendswith.ai immediately. We review all such reports within 24 hours and remove any content that does not comply with our standards.

Changes

We may update this statement to reflect changes in our content production methods or applicable law. The “Last updated” date above reflects the latest revision.