Age Verification & 18+ Policy

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] This document is a DRAFT prepared for internal review and is NOT final legal advice. It must be reviewed, adapted, and approved by qualified legal counsel before publication or reliance.

my-own-dolls.com (the "Service") is a strictly 18+ subscription platform offering erotic photographic content. The Service is operated by [[PLACEHOLDER: legal company name]], [[PLACEHOLDER: registered address]], registered under [[PLACEHOLDER: commercial register / Handelsregister no.]], VAT/USt-IdNr [[PLACEHOLDER: USt-IdNr]] (the "Operator", "we", "us").

Access to and use of the Service is restricted to adults who are at least 18 years of age (or the higher age of majority applicable in their jurisdiction). The Service is not directed at, and may not be accessed by, anyone under 18. We operate from Germany/the EU and apply German and EU youth-protection requirements to all users, supplemented by additional jurisdiction-specific measures described below. This policy should be read together with our Terms of Service, Privacy Policy, Cookie Policy, and Content & 2257-Style Records Policy.

All content on the Service is intended exclusively for adults. We maintain a zero-tolerance position towards any content depicting, or appearing to depict, minors, and towards any attempt by a minor to access the Service. We do not knowingly permit any person under 18 to register, subscribe, view content, or otherwise use the Service.

All performers and depicted persons are verified adults at the time of production. Records relating to performer age and identity verification are maintained separately under our Content & Records Policy and applicable custodian-of-records arrangements ([[PLACEHOLDER: custodian-of-records name and address]]).

Any account reasonably believed to belong to a minor will be suspended and terminated, and associated access revoked. Suspected child sexual abuse material (CSAM) or attempted access by minors will be handled in accordance with Section 10 (Reporting and Escalation).

Before any adult content is displayed, all visitors encounter a neutral, non-explicit entry page that requires confirmation of adult status. The entry gate presents a clear statement that the Service is 18+ and asks the visitor to confirm they are at least 18 (or the applicable age of majority) and that they consent to viewing sexually explicit material.

Visitors who do not confirm, or who indicate they are under 18, are denied access and redirected away from the Service to a neutral exit destination (for example a general search engine or a youth-protection resource). The entry-gate landing page is designed to remain free of explicit imagery so that it is safe to index and to display to any incoming visitor.

We treat the entry age gate as a first-layer self-declaration screen only. It is NOT, by itself, sufficient age assurance for the closed user group required for explicit content. Robust age verification (Section 4) is applied before and/or as a condition of access to age-restricted material, as further specified by counsel.

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] German youth-media-protection law (Jugendmedienschutz-Staatsvertrag, JMStV) requires that content unsuitable for minors be made available only within a "closed user group" (geschlossene Benutzergruppe) accessible solely to verified adults. A simple self-declaration checkbox does not satisfy this standard.

To meet this requirement, access to explicit content is gated behind a recognised age-verification system (Altersverifikationssystem, AVS) that performs a one-time face-to-face or equivalent strong identity/age check and an authentication step on each access. We use [[PLACEHOLDER: recognised AVS provider name]], an age-verification concept assessed positively by the Kommission für Jugendmedienschutz (KJM) / a recognised body ([[PLACEHOLDER: KJM positive-assessment reference, if applicable]]).

Typical verification flows offered by such providers may include identity-document checks, bank/SCHUFA-style identity confirmation, eID/Personalausweis-based verification, video-ident, or other KJM-recognised methods, combined with re-authentication (for example login credentials, a hardware token, or a one-time code) to ensure the verified adult is the person accessing each session. The specific methods and the precise legal characterisation of our closed user group are subject to confirmation by counsel and by the AVS provider's current certification status.

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] The legal landscape for adult-content age verification is changing rapidly and varies by country and, in the United States, by individual state. The notes below are indicative only and must be confirmed against current law for each market we actually serve.

United Kingdom: Under the Online Safety Act 2023 (OSA) and Ofcom's implementing guidance, services that publish or allow pornographic content accessible from the UK are expected to use "highly effective age assurance" to prevent under-18 access. Where we make the Service available to UK users, we will apply age-assurance measures intended to meet the OSA standard (for example via [[PLACEHOLDER: UK-applicable age-assurance provider/method]]).

United States: A growing number of US states (for example [[PLACEHOLDER: list of relevant states]]) have enacted age-verification statutes for sites with a material proportion of adult content, often requiring government-ID or transactional/database verification and creating private rights of action. Depending on our risk assessment and on counsel's advice, we may apply state-specific age verification, geofence or restrict access from certain states, or rely on card-network and processor requirements. [[PLACEHOLDER: confirm per-state approach and any geoblocking with counsel.]]

Independently of statutory rules, our payment processors and the card networks (Visa, Mastercard) impose their own adult-merchant requirements, including age and identity verification of subscribers, consent and content-provenance controls, and prohibitions on illegal or non-consensual content. We align our age-assurance and onboarding processes with these requirements as a condition of accepting card payments.

Because card-network rules effectively extend certain US-style record-keeping and verification expectations (including practices modelled on 18 U.S.C. §2257) to non-US operators, we maintain performer-verification and content-provenance records as described in our separate Content & Records Policy, and we cooperate with processor ([[PLACEHOLDER: processor name(s)]]) audits and attestations.

Where processor or network rules require stricter age assurance than local law alone, the stricter standard applies.

We strongly support parents and guardians in preventing minors from reaching adult content. While we apply the controls described above, parental supervision and device-level filtering remain an important additional safeguard.

We provide machine-readable content labelling so that filtering software can recognise and block the Service. This includes labelling the Service as adult/restricted (for example via the RTA "Restricted To Adults" label and appropriate metadata) and the age-de.xml / age-classification mechanisms relevant under German youth-protection practice ([[PLACEHOLDER: confirm specific labelling standards implemented]]).

We encourage parents/guardians to use operating-system and network-level parental controls and reputable filtering tools, such as those offered by device platforms, home routers, mobile carriers, and third-party services (for example [[PLACEHOLDER: examples of filtering tools/resources]]). Helpful starting points include national youth-protection resources such as [[PLACEHOLDER: e.g. jugendschutz.net / relevant local resource]].

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] Age verification necessarily involves processing of personal data and, depending on the method, potentially identity-document or other sensitive data. We apply the principles of data minimisation, purpose limitation, and storage limitation under the GDPR, and we process such data only for youth protection, legal compliance, and fraud prevention.

Wherever possible, identity and age checks are performed by the specialist AVS/verification provider, and we receive only a verification result or a verification token (for example a confirmation that the user has been verified as an adult, with a status flag or token identifier) rather than copies of identity documents. We aim to store tokens and verification status only, not underlying ID images, on our own systems.

Where the verification provider acts as our processor, processing is governed by a data-processing agreement under Article 28 GDPR. Retention periods are limited to what is necessary for compliance and dispute/audit purposes ([[PLACEHOLDER: retention period(s)]]). For details of lawful bases, recipients, international transfers, your data-subject rights, and contact details for our Data Protection Officer ([[PLACEHOLDER: DPO contact]]), please see our Privacy Policy. Cookies and similar technologies used in connection with the age gate and session authentication are described in our Cookie Policy and handled in line with the German TDDDG/TTDSG and the GDPR.

By accessing the Service you confirm and warrant that you are at least 18 years of age (or the applicable age of majority in your jurisdiction), that you are legally permitted to view sexually explicit content where you are located, and that you are accessing the Service for your own private use.

You must keep your login credentials and any verification token or device confidential and must not allow any other person — and in particular any minor — to access the Service through your account or your devices. You must not share, resell, or redistribute access or content, and you must not attempt to circumvent the entry gate or age-verification measures.

If you become aware that a minor has accessed or may access the Service through your account or device, you must immediately secure the account and notify us at [[PLACEHOLDER: contact email]].

[[PLACEHOLDER — REPLACE WITH LAWYER-REVIEWED TEXT]] We maintain reporting channels for suspected underage access, suspected CSAM, and non-consensual intimate imagery (NCII). Reports can be sent to [[PLACEHOLDER: abuse/reporting email]] or via our in-service reporting tools, consistent with our obligations as a service under the EU Digital Services Act (DSA).

We have zero tolerance for CSAM. Confirmed or strongly suspected CSAM is removed expeditiously, preserved as required by law, and reported to the competent authorities, including the Bundeskriminalamt (BKA) and/or via INHOPE-affiliated hotlines, in accordance with applicable law and counsel's guidance. We respond to valid NCII removal requests, including under frameworks such as the US TAKE IT DOWN Act and comparable EU/Member-State rules, and we handle copyright complaints under our DMCA/notice-and-takedown procedure described in our Terms of Service.

We may suspend or terminate access, refuse service, and take any other lawful measures in response to violations of this policy, suspected underage access, or suspected unlawful content. Nothing in this policy limits any reporting or cooperation obligation we have under applicable law.

We may update this policy to reflect changes in law, regulatory guidance, card-network rules, or our verification providers. Material changes will be communicated as required and the effective date below will be updated.

Effective date: [[PLACEHOLDER: date]]. Last reviewed: [[PLACEHOLDER: date]]. Questions about this Age Verification & 18+ Policy can be directed to [[PLACEHOLDER: contact email]] or in writing to [[PLACEHOLDER: legal company name and registered address]]. For data-protection matters, contact our DPO at [[PLACEHOLDER: DPO contact]].