Our USC2257 statement for affilaites
 

Our offices, content production, and business model are based in Europe. Having produced 98% of all our own content our model papers have always been in perfect order. Any 3rd party content we did purchase in the past, is being removed from our servers/sites.

All our paperwork is available for inspection between office hours 11am through until 3.30pm daily from our Central European office where we run and maintain our business.

Our affiliate program of course has webmasters from both the US and Europe.
For USA based webmasters they can, if they so wish link only to our hosted galleries , use non explicit content , text links, or take advantage of hosted banners, hosted adds (being updated). If any CURRENT US based webmaster wishes to use our regular content (which does include graphical content) then they can email us for a copy of the Models ID. They will have to sign a non disclosure agreement before hand , and when we supply the model papers these will include photo ID - model - age - date of shoot - etc but the models address phone number etc will be blanked out along with any other information which does Not effect the ability to verify that the model in question is over 18.

For new USA based webmasters who join our program, that email in requiring paperwork for content, we will need to see them working with our program first, before releasing any documents. Its not just a case of "join up, give us some content, send me model IDs - new webmaster wanking over pic of model etc within 10 minutes" We would want to see traffic, conversions, and get know a little about the (usa) webmaster. We would make sure that new USA based webmasters are given a number of fully exclusive hosted galleries, hosted adds, hosted banners etc to help kick start their program.

Now I can already hear people saying "hold on what about the models real name being out on the net" well this could happen But to fully accommodate our US webmasters this is something we cant avoid. If we do find any webmaster in breech of the confidentiality agreement then we would close of that account, hold all funds, and possibly take legal action against the individual.

For European based webmasters there is no need to change anything and business continues as normal. (kind of reminds me of the old VISA USA / VISA EU region issue ))

Links to our USC2257 documents will remain in place (currently being updated)for any webmaster to link to if they so wish. It could be said that we need not do anything, however as matter of course we have always followed the rule of complying as closely as possible US law when this does not contravene any EURO laws.

That?s about all I gotta say on that - now time for coffee.

... great sites, great policy :thumbsup

Thanks :winkwink:

Though it is great you are in compliance and on top of things, I would bet my house that you will never have a single inspection in Europe. The USA will not have the budget or manpower (or cooperation from your country) to do international inspections. :2 cents:

However, it is nice to see a Euro company in compliance with US law. :thumbsup

Well some day we want to sell - and who knows the buyout could come from the USA, who would require paperwork etc. My view is if you can comply -comply. And hell you never know, the day you have 1 paper missing is the day your number is called up - like roulette - you cover zero everytime and soon as you drop it the fucker comes rolling home :upsidedow

Thanks for the info...

:thumbsup Your thinking way ahead. I like you.

Well I could never imagine doing this for the rest of my life - I remember the first shoot we did around 5 years ago. Fucking awfull - embarressing in fact when I look back at the stills. But we still got a bit of paper with the models passport on it and a document that was by todays worthless as far as copyright is concerned. Even though she looked about 50 years of age (and was almost :upsidedow - Dumped those early sets long time ago -) But still then I thought if I can make bling maybe one day I can sell this on. Glad I did all the docs now.

good to atleast see programs starting to state their policies

I agree - this industry has a way of adapting and responding no matter what bullshit is thrown at it.

Congrats man!!!

Why would you leave your door open to inspectors from the US? They can't exacly inspect a foreign company or person. How about the laws in the country you're living in? I know that I for instance can't give out any papers due to privacy laws where I live and I know many european countries have the same laws.

What about Canadian webmasters. Will we get a copy of the models IDs as well or is it only restricted to Americans?

We are not leaving the door open we are just stating a fact. And as our records are in perfect order we would show them to any legal body that requested them.

Canadian Webmasters if they feel they need model info then the same rules apply yes. Join the program - work with us - we get to know how each other work and then request the documents and non disclosure aggrement.

Keep in mind in comparision to other programs who may have or do have 1000s of webmasters we have always prefferd to work with a smaller number. Building up solid working partnerships. Hell if an affiliate is converting well I would fly the docs out myself. We have had some of our best affiliates into our offices - into our shoots - at our expense. Its good for them - good for us and builds a great working partnership. :thumbsup

and to others that might need them. I'm just saying that I hope you've checked your own countries laws before giving them away. I'm not trying to be a pain in the ass here, just pointing out that all countries have different laws and you can be a bit fucked if you try to follow them all.

Yep I can see this and every move we make is always passed by our lawyer who drafts our docs - plus we shoot models from differnt regions and not just one country. Most of them are "imports"

Thanks :thumbsup

What about people that don't use hosted galleries?

I THINK you state that you'll consider "References" from other programs, or something along those lines. Is that accurate?

Then before any paper word is released we would need to have worked with you for a while. Getting paperwork is not automatic if you request it. However if you managed to come through with good refs etc then yes it could be discussed. And even if you dont use hosted galleries as such, we would build you custom galleries to your specs or let you build the page - we add the images then upload the whole thing to one of our domains.

They are answers to every problem.

hey sol hit me up on icq bro

Looks like you guys are really on the ball with this.

Well we took advise - watched what others were doing and basically had to draw our own lines on this :upsidedow

They will have to sign a non disclosure agreement before hand , and when we supply the model papers these will include photo ID - model - age - date of shoot - etc but the models address phone number etc will be blanked out along with any other information which does Not effect the ability to verify that the model in question is over 18.


this will not meet the requirements of the new 2257. read the law.

true, euro content producers won't be pinched for this---their usa affiliates will be breaking the law.

LOTS of folks just don't get it yet. the law will be effective in a few days.

let me just say the basic thing:

any content producer anywhere in the world who DOES NOT PROVIDE unaltered docs to USA secondary producers will be out of business within 6 months in the american market (unless the law is invalidated).

I don't promote you (yet) but that sounds like the best compromised policy I heard so far. Very good idea about contracting.
:thumbsup

Nice looking sites you have

We are not a US BASED producer. All our smut has and is produced outside of the USA. EU webmasters do not need USC2257 information
USA based webmasters who require documention when using our content to promote our sites can apply directly us. We would then look at this as per our statement on this. As for model info - let us deal with this, trust me we know what we are doing :thumbsup

Thanks :thumbsup

certainly YOU may know what your are doing.

BUT if you do not provide unaltered docs to USA affiliates you put THEM at risk.

because THEY will be violating USA statutes, and risk time in US federal prison. lots of cavalier attitudes about this. doesn't matter to you---you're not going to risk being pinched.

i stand by my original response.

read the law.

it is in english.

Nice job!

"best compromised policy"

haha. love it.

reminds me of the line in the old "Cool Hand Luke" movie:

"now what we have here---is a failure to communicate"

read the fucking law if you are a USA based primary or secondary producer.

READ THE FUCKING LAW.

Hi like I said we got the base coverd and I have our lawyers bill right here to prove it . Im not going to get into a discussion of it is matters to us or not. But I will say if it didnt matter I would not have made any statment and just continued with our buisness as normal. But it does matter hence our post on this. The papers we and over will be fully compliant with US based law on this issue. Nuff said.

Ohhh you angry boy today - take a chill pill. Im not the first nor will I be the last to produce protocols of dealing with this issue - (And remaining compliant) :thumbsup

i will say it again, unless the new 2257 law is overturned or stopped by injunction all content producers all over the world who want to sell to USA-based webmasters will have to comply to the letter of the law.

or they will lose the USA webmaster market.

your attorney has either not read the law, or english is not his native language.

Never heard of you guys before.... But I liked what I've read...

I could not agree more :)

no sunshine, not angry. just speaking about business---i don't give a shit what you do in your business.

but i see many threads like this, of primary producers trying to make "compromised" solutions that to them seem palatable, but simply put USA webmasters at risk.

and because it seems the VAST MAJORITY of vendors and attorneys have not read (or do not understand the statute) they rely on others who are giving misinformation in threads like this.

do whatever you want.

but i will say it again---unless you provide unaltered docs to your usa-based webmasters you will have problems holding that market (unless the 2257 is invalidated or an injunction sticks.)

Glad to hear it ... we taking on board all comments - good and bad - and working towards a fully workable solution for both US and EU webmasters without cutting anyone out of the frame - or finding models dead on the street after being stalked by a manic webmaster - and still remaining fully legal. My own personal opionion on this is webmasters will adjust where they host, what they offer, where they incorp , in fact if your biz is making good buxx your going to do what it takes to keep in the loop. Who knows it might yet get struck down ... but doubt it somehow.

This is not a compromised solution. We are offering USC2257 compliant documents to US based webmasters who request them (after a probabtionary period - before then they can if they wish run with exclusive hosted gs etc) and I agree - unaltered docs - is the way to go - like I said to you in post before ... I agree ...

We collect a hell of alot of data on our models parts of which are not required under US law. Such as breast size -- how hard they can take a spanking - sub - dom etc ... im sure Mr Doj who although may enjoy reading this would not require this info.

Now my chicken surprise just arrived time to eat :upsidedow

:thumbsup I second that.

Hi u in DK ?

Where exactly does it say secondary producer has to have unsanitized docs ? According to 2 lawyers I've spoke to, blacked out addresses on ID's are still perfectly legal as long as you have the primary producer information with the paperwork .

great sounds like a good deal

read the DOJ comments section, where it is declining to implement various suggestions by commenters---also foreign producers should read it.

under the subheading "privacy".

the fact that this commentary is not fully articulated in the actual reg is very troublesome---because it does lead to some ambiguity.

IMO this will be resolved in the courts.

and who's going to be the great martyr that fights this?

Someone will fight that, The State Of New Hampshire was sued and lost the case for forcing residents to have their home address on their driver license instead of a secondary or mailing address .
Not the same circumstances but the issue is privacy and personal safety .
Well either way best thing for any model to do is not have a home address on their ID and for any US webmaster to have an office outside the home .

I'm not US based, but I read it.

If you read what they say: "send traffic to FHGs, use non-sexual explicit content, text links" .... NO ONE are put at risk! After that, when they know you, and you want to use sexual explicit content, THEN you can have your IDs.
I say that is a good compromise, because you are not in risk and the security of the models is better. If you can't handle that, then get out of the industry, because this is how its gonna be from now on.

Yep thats pretty much it well said! You have to adapt and make choices - those that do will prosper in the long term :thumbsup