COMPLIANCE STATEMENT REGARDING 18 U.S.C. §§ 2257 AND 2257A
This statement is published by LusyChat (operating at lusychat.ai, hereafter "we" or the "Operator") with respect to all visual depictions of actual sexually explicit conduct that appear on the Service.
All visual depictions of fictional characters that appear on the Service and that may include sexually explicit conduct are produced entirely by computer-generated artificial-intelligence models. These depictions are not, and do not purport to be, photographs, films, or videotapes of actual human beings engaged in actual sexually explicit conduct. The depicted characters do not exist; they have never existed; and any resemblance to an actual person, living or deceased, is unintended and coincidental.
As a result, fully synthetic AI-generated material produced by the Service is not "actual sexually explicit conduct" within the meaning of 18 U.S.C. § 2256(2)(A) and is not subject to the record-keeping requirements of 18 U.S.C. § 2257 or 18 U.S.C. § 2257A. See, e.g., the explanatory rules at 28 C.F.R. Part 75.
Notwithstanding the above, we have voluntarily adopted record-keeping and verification practices designed to meet or exceed the policy goals of §§ 2257 and 2257A, as described below.
The Service does not accept any user uploads of photographs, video, voice recordings, or other media files. Users interact with the Service only through text-based character configuration, text chat messages, and selection from pre-curated, internally-reviewed libraries of fictional avatars and licensed synthetic voices. Because users cannot upload any depiction of any person — themselves or anyone else — the Service does not create or distribute "actual sexually explicit conduct" derived from user-supplied imagery.
Identity and age verification through Sumsub (Sum and Substance Ltd.) may be required for access to paid features or where required by applicable law. KYC artefacts (government-issued ID images, live selfie, and verification results) are processed solely for verification of identity and age; they are not used as user-facing avatars, are not incorporated into any generated output, and are retained only for the period necessary to complete the check and defend against fraud claims.
The Custodian of Records for any material that, despite the position taken in Section 1, may be deemed to be subject to 18 U.S.C. § 2257 or § 2257A is:
LusyChat
Attn: Custodian of Records
Villa Malitah, The Village, Triq Il-Mediterran, San Giljan STJ 1870, Malta
Email: contact@business.lusychat.ai
Original records are maintained at the address above and are available for inspection in accordance with applicable law during normal business hours, by appointment, by a duly authorized representative of the United States Attorney General.
Where the Operator licenses any depiction of actual sexually explicit conduct from a third-party content provider, the Operator obtains, before publication, (a) a written agreement with the provider, (b) documented proof that each depicted performer is at least 18 years of age, and (c) documented written consent from each depicted performer to the use of the depiction. The Operator retains copies of these documents and makes them available for inspection by the Custodian of Records in accordance with applicable law.
The Operator does not produce, host, knowingly distribute, or knowingly facilitate the production of any depiction (real, synthetic, or otherwise) of (a) any minor, (b) any person who appears to be under 18, or (c) any real, identifiable person without that person's verifiable written consent. Confirmed or suspected child-sexual-abuse material is reported to the National Center for Missing & Exploited Children (NCMEC CyberTipline), INHOPE, the Internet Watch Foundation, the Malta Police Force, and any other competent authority.
By using the Service, every user warrants and represents that they are at least 18 years of age and that any material they upload depicts only themselves. Unauthorized uploads, attempts to depict minors, attempts to depict third parties, attempts to circumvent verification, and any other violation of our Content Policy may be reported to law enforcement.
We may amend this Statement from time to time to reflect changes in law, in our verification procedures, or in our content offering. The current version is always published on the Service.
Questions about this Statement, requests for inspection of records by an authorized officer of the United States Attorney General, and any other 2257-related correspondence should be addressed to the Custodian of Records at the address in Section 3, with email subject "2257 Custodian of Records".
