PRIVATE GATHER

18 U.S.C. § 2257 RECORDKEEPING STATEMENT

Effective Date: August 27, 2026

Last Updated: August 27, 2026

Private Gather is an online community and technology platform operated by Privora Labs.

1. PURPOSE OF THIS STATEMENT

This statement explains Private Gather's position regarding the federal recordkeeping requirements contained in 18 U.S.C. § 2257 as they relate to member-generated content hosted or transmitted through the Private Gather platform.

2. PRIVATE GATHER IS AN ONLINE PLATFORM

Private Gather provides technology and online community services that allow consenting adults to:

Create member profiles
Upload photographs and other media
Communicate with other members
Create posts and comments
Exchange private messages
Participate in clubs and events
Use community and discovery features
Use club, host, ticketing, membership, admission, Door Mode, CRM, and event-management tools

Private Gather does not employ, hire, contract with, recruit, manage, direct, or arrange performers for the purpose of producing sexually explicit visual depictions submitted by members.

Private Gather does not commission member-uploaded sexually explicit content.

Private Gather does not direct the creation of member-uploaded sexually explicit content.

Private Gather does not operate as a producer of adult films, photographs, videos, or other sexually explicit member-generated material.

3. MEMBER-GENERATED CONTENT

Content displayed or transmitted through Private Gather may be created and uploaded independently by members, clubs, hosts, or other authorized users.

With respect to independently created member-generated content, Private Gather generally acts as an online service provider providing functions that may include:

Transmission
Storage
Retrieval
Hosting
Formatting
Delivery
Access control
Account functionality
Security
Content moderation
Fraud prevention
Safety screening

Private Gather does not consider itself a primary or secondary producer of member-generated content for purposes of 18 U.S.C. § 2257 merely because it provides these platform and hosting services.

Where Private Gather's role with respect to particular member-generated material is limited to transmission, storage, retrieval, hosting, formatting, or similar online-service functions without selecting or altering the underlying communication in a manner that would make Private Gather the producer of the depiction, Private Gather does not consider the federal producer recordkeeping requirements of 18 U.S.C. § 2257 applicable to Private Gather with respect to that material.

4. PRIVATE GATHER DOES NOT CREATE MEMBER ADULT CONTENT

Private Gather does not:

Hire performers to create member-uploaded adult content
Pay performers to create member-uploaded adult content
Direct sexual performances appearing in member-uploaded content
Arrange sexual performances for the purpose of creating member-uploaded content
Operate a production studio for member content
Commission sexually explicit member content
Determine what sexual acts members must depict
Create sexually explicit member photographs or videos on behalf of members

Members independently determine whether to create lawful content before uploading it to Private Gather.

5. CLUBS, HOSTS, AND PARTNERS

Lifestyle clubs, hosts, event organizers, businesses, and other partners using Private Gather are independent persons or organizations.

The mere use of Private Gather's:

Club-management tools
Website tools
Event tools
Ticketing tools
Membership tools
Admission tools
Door Mode
CRM tools
Community tools
Hosting services

does not, by itself, make a club, host, partner, or other user a producer of sexually explicit material under 18 U.S.C. § 2257.

Private Gather does not impose § 2257 producer recordkeeping requirements upon clubs, hosts, or partners merely because they use Private Gather technology.

However, each club, host, partner, member, content creator, or other independent third party remains responsible for determining whether its own activities independently cause any federal or state recordkeeping requirement to apply.

Private Gather does not provide a legal determination or guarantee that every activity undertaken by every independent club, host, partner, or member is exempt from 18 U.S.C. § 2257.

6. MEMBER AND CONTENT-CREATOR RESPONSIBILITY

Members are responsible for content they create and upload.

Any member, club, host, content creator, or other person who independently produces material that may fall within the scope of 18 U.S.C. § 2257 is responsible for determining and complying with any legal requirements applicable to that person's own production activities.

Private Gather's status as an online platform does not relieve an independent producer of obligations that may apply to that producer under federal, state, or local law.

7. PRIVATE GATHER AGE AND IDENTITY VERIFICATION

Private Gather maintains age, identity, consent, and content-safety requirements as part of its own platform safety rules.

These measures may include:

Date-of-birth requirements
Age verification
Identity verification
Profile verification
Automated media screening
Manual content review
Consent requirements
Member reporting
Account enforcement
Content restrictions

Private Gather's use of age-verification, identity-verification, moderation, or content-safety systems does not constitute an admission or representation that Private Gather is a producer subject to the recordkeeping requirements of 18 U.S.C. § 2257.

These systems are maintained to protect members, prevent abuse, enforce Private Gather policies, and promote compliance with applicable law.

8. ALL PERSONS DEPICTED MUST BE ADULTS

Private Gather is an adults-only platform.

Every person represented as a member of Private Gather must be at least 18 years of age.

Every identifiable person appearing in nude, sexually explicit, intimate, or other adult member content must have been at least 18 years old at the time that content was created.

Content involving a person under 18 is strictly prohibited.

9. CONSENT REQUIREMENTS

Private Gather requires lawful consent for intimate and sexually explicit content.

A member may only upload or distribute intimate, nude, or sexually explicit media when:

Every identifiable person depicted was at least 18 years old at the time the material was created
Every identifiable person consented to the creation of the material
Every identifiable person consented to its distribution or upload through Private Gather
The uploader owns the material or otherwise has sufficient legal rights to distribute it

Private Gather prohibits:

Child sexual abuse material
Sexual content involving minors
Nonconsensual intimate imagery
Revenge pornography
Hidden-camera sexual content
Hacked intimate content
Stolen intimate content
Sexual exploitation
Trafficking-related content

10. PROFILE AND COVER PHOTO RESTRICTIONS

Private Gather does not permit nudity or sexually explicit material in:

Primary profile photographs
Profile avatars
Cover photographs

Lawful consensual adult content may be permitted only in designated areas of the Private Gather platform and remains subject to all Private Gather verification, consent, safety, visibility, and content rules.

11. NO WAIVER OR ADMISSION

Nothing in this statement should be interpreted as:

An admission that Private Gather is a producer under 18 U.S.C. § 2257
An admission that Private Gather is required to maintain performer records under § 2257
An admission that a club, host, partner, or member is a producer
A representation that an independent third party can never become subject to § 2257
A waiver of any statutory exclusion, exemption, defense, immunity, or other legal protection available to Privora Labs or Private Gather

12. CHANGES IN PLATFORM ACTIVITY

This statement reflects the current nature of Private Gather as an online community and technology platform.

If Private Gather were in the future to directly produce, commission, direct, or otherwise participate in creating sexually explicit visual depictions in a manner that materially changes its legal status, Privora Labs may revise its policies and compliance practices as required by applicable law.