18 U.S.C. §2257 Compliance Statement

Compliance statement

All models, actors, and other persons who appear in any visual depiction of actual or simulated sexually explicit conduct appearing on, or produced for, the Sealed Rose platform were over the age of eighteen (18) years at the time the content was created.

With respect to all such visual depictions, the records required by 18 U.S.C. §2257 and 18 U.S.C. §2257A, and their implementing regulations at 28 C.F.R. Part 75, are kept by the Custodian of Records identified below.

How Sealed Rose keeps these records

Sealed Rose does not store copies of creators’ government-issued identification documents in its own systems. Instead, Sealed Rose’s identity-verification partner — Persona — maintains the identification records, age-verification records, and associated documentation required by §2257/§2257A in its own compliant records vault, as part of the verification process every creator completes before they can post or sell content on the platform.

To be precise: a copy of each verified creator’s identification does exist and is retained, as federal law requires — it is retained by the verification partner’s vault rather than in Sealed Rose’s own application database. This is a deliberate architectural and legal choice (the “vault-as-record” approach). Sealed Rose retains only the verification result and the minimal index fields necessary for the Custodian of Records to locate the underlying record on request.

Custodian of Records

Custodian of Records: Derek Gallardo, Kinetic Helix LLC (d/b/a Sealed Rose)
Business address: 3256 SW 23rd St, Miami, FL 33145
Records available for inspection: during regular business hours, as required by 28 C.F.R. Part 75, upon request from an authorized inspecting official.

Scope

This statement applies to visual content depicting actual or simulated sexually explicit conduct — images and video — made available on the Sealed Rose platform on or after Sealed Rose’s launch date. It does not, by itself, apply to content that is solely text-based (conversation with no accompanying visual depiction), or to visual content that does not depict actual or simulated sexually explicit conduct as defined by 18 U.S.C. §2256.