Age Verification Policy

1. Purpose

Red Hot Xtra is an adult subscription platform that provides access to sexually explicit content intended solely for adults.

This Age Verification Policy establishes the procedures used to prevent minors from accessing adult content and to verify the age and identity of all performers and other participants appearing in content published on the platform.

No public visitor may access or view adult material until the applicable age gate has been completed for that visitor's jurisdiction.

This policy exists to:

• Protect minors
• Safeguard performers and production participants
• Ensure compliance with applicable laws, card-network rules, and payment processor requirements

2. Scope

This policy applies to:

• All visitors, account holders, and subscribers seeking access to adult content
• All performers, models, and other identifiable participants appearing in published content
• All contracted studios and production partners supplying content for publication

No exceptions are permitted.

3. Consumer Age Gating and Access Controls

Red Hot Xtra applies age-gating before any adult material is visible. No public access to adult content is provided until the relevant access control has been completed.

Restricted jurisdictions are routed through strict identity and age verification before any adult material becomes visible. Non-restricted jurisdictions are routed through self-confirmation before adult content is displayed.

• Restricted jurisdictions complete strict verification through Ondato
• Non-restricted jurisdictions must complete self-confirmation before access is granted
• No adult content is shown before the applicable gate is satisfied

4. Strict Verification in Restricted Jurisdictions

Where Red Hot Xtra designates a jurisdiction as restricted, users must complete identity and age verification through Ondato before they are permitted to view adult content.

The strict verification process includes:

• Submission of a valid government-issued photo ID (e.g. passport, driving licence, national ID card)
• A live selfie or liveness check to match the user to the document
• Document and age validation performed by Ondato before access is granted

Access to adult content is not granted until the strict verification process is successfully completed.

5. Performer and Production Participant Verification

All performers and other identifiable participants appearing in content on Red Hot Xtra must be verified to be at least 18 years of age before any content is published. This applies to:

• Performers contracted directly by Red Hot 100 Limited
• Any participants supplied through contracted studios or production partners

Performer verification includes:

• Submission and validation of a government-issued photo ID
• A liveness or selfie check to confirm identity where required
• Signed consent and model release documentation for all performers
• Confirmation that Red Hot 100 Limited holds the rights and releases required for publication

No content featuring an unverified or undocumented individual will be made available on the platform.

6. Record Keeping

Red Hot Xtra maintains records of all age and identity verification checks in compliance with applicable legal requirements, including but not limited to 18 U.S.C. § 2257.

Records include:

• Verification timestamps and outcomes
• Document type used for verification
• Confirmation of age eligibility
• Consent and release documentation for performers
• Rights and publication approvals relating to the content released

These records are retained securely and are available for inspection by authorised regulatory bodies upon lawful request.

7. Third-Party Verification Provider

Red Hot Xtra uses Ondato as its third-party provider for strict identity and age verification in restricted jurisdictions. Ondato validates government-issued identity documents and performs liveness checks before a user is approved for access.

Ondato operates independently from Red Hot Xtra and processes personal data in accordance with its own privacy policy and applicable data protection laws.

Red Hot Xtra does not store raw identity documents. Only the verification result (pass or fail), the applicable routing method, and associated metadata are retained.

8. Consequences of Non-Compliance

Any attempt to circumvent or falsify age verification will result in:

• Immediate account suspension or termination
• Referral to law enforcement where appropriate
• Removal of all associated content from the platform

9. Policy Updates

This policy may be updated from time to time. Continued use of the platform after changes are posted constitutes acceptance of the updated policy.