Questions asked by Models/Stars/Chathosts:

Q: Can ClickCash Affiliates, or other third parties, ever see sensitive information from my iFriends 18+ ID Card?

A: No. A ClickCash affiliate has only "Level 1" authorization – the lowest level of authorization – which is limited to identification of the model's performer name only (not his or her legal name), and verification that an image or a movie file originating on iFriends, and depicting the model, contains the embedded "18+ barcode" that is present in all content distributed through the iFriends platform. No other information is provided, and your private information stays private. (Prove it to yourself: save one of your iFriends archive images to disk, then click the "Extract Model ID from Content File" link to inspect it.) Only authorized law-enforcement agents performing valid records inspections under 18 USC 2257 can obtain the necessary higher levels of authorization to gain access to more sensitive information.

Q: On my own web page, do I have to disclose my name, home address and other private information in an 18-2257 statement?

A: No. If you host your website using the iFriends fanclub system (http://www.fanclubs.com), and/or the iFriends "MyiFriends" system (http://www.MyiFriends.net), and your site presents only individuals that are already documented under the iFriends 18+ system (i.e., any individuals who already have their own iFriends 18+ ID Cards), you may hotlink your 18-2257 statement directly to the full iFriends' statement at this link: http://www.all-amateur.net/ifpage.dll?t=ALT/182257/General/Cert-Compliance.

Q: I'm confused. I see other services reacting differently to the new regulations. Why does iFriends take such a unique approach?

A: There are three primary reasons why "iFriends is Different:"

1. We're prepared: Because iFriends' extensive proof-of-age requirements and identification technologies are already so comprehensive and over-the-top (remember, we invented the concept of webcam hosting many years ago, coined the term "chathost," and pioneered other important innovations such as the iFriends 18+ ID Card, digitized Age Documentation Sessions (ADS) and Video Age Documentation Sessions (VADS)), the revised 18-2257 regulations do not impose any new substantial restrictions or requirements upon our operations. In other words, iFriends already is compliant with the new regulations, so the impact upon our chathosts and most marketing affiliates is virtually nil, and the status quo is maintained.



2. Proprietary "18+ Certified" embedded barcode technology: As the only source of original adult content where model ID information is embedded within each .jpg or movie file, our platform is already 100% digital and adapts far more easily to the spirit and intent of the new recordkeeping regulations than platforms which lack this technology. (Although 100% in digital form, paper versions of all proof-of-age documentation materials are nevertheless also maintained.)



3. Comprehensive Familiarity with iFriends Content: Unlike most internet services, iFriends is already comprehensively familiar with each and every file users post to the platform, before the file is even made available on the platform. iFriends maintains an array of compliance departments which include among their responsibilities the actual review and inspection - by a human being - of all visual matter that any iFriends user publishes or distributes on the platform. In fact, such materials actually undergo at least three separate reviews: twice by iFriends' own compliance personnel in the course of their regular duties, and a third time by an independent panel of credentialed experts in the fields of sexuality, medicine and psychology to ensure that each and every depiction of sexually-explicit conduct appeals to a normal and healthy interest in human sexuality. (Learn more.) At any of the three stages of content review, the content may be rejected before it is ever made available on the iFriends platform.

Questions asked by Marketing Affiliates:

Q: iFriends and ClickCash take a unique approach towards the new 18-2257 regulations that I haven't seen any other operation take. Why?

A: Numerous factors and advantages exist which make iFriends/ClickCash very different from virtually every other operation active in the adult internet today:

1. Exclusivity: All material available in the 100-million-file iFriends Content library is sourced solely from the iFriends platform itself. iFriends does not purchase or obtain any content from third parties.



2. Pre-existing 18+ IDs: All material available in the 100-million-file iFriends Content library is backed by a complete set of records documentation obtained directly by iFriends' trained compliance personnel. This set of records documentation includes drivers' licenses, birth certificates, passports, social security cards, plus a complete collection of headshots, bodyshots, video interviews, signed releases and model agreements, all obtained before any model ever appears on the iFriends platform.



3. Embedded 18+ Bar Codes: All material available in the 100-million-file iFriends Content library appears on the iFriends platform in .jpg, .asf and .wmv formats, and every single file contains within it a unique, embedded, digitally signed, encrypted and tamper-proof "18+ barcode." This barcode can be extracted to varying degrees, based on different levels of authorization. When fully extracted by a law-enforcement agent or officer of the court performing a bonafide records inspection pursuant to 18 USC 2257, the barcode discloses the entire set of model age-documentation records.



4. Size & Scale: The iFriends content library of more than 100 million movies and images presents approximately 300,000 individuals with complete 18+ records documentation. The unique scale of this undertaking, combined with our 10+ years of experience in digitally programming our record-keeping, provides us with a level of expertise and sophistication that you can take full advantage of when you host your 18-2257 records at http://iFriends.18-2257.com.

Q: Can I use content that I find on the iFriends platform to promote iFriends on my own web pages?

A: Yes. You may use any content available on the iFriends platform where the chathost has not indicated privacy block zones. (This content is easily identified by the existence of the statement "This content is clickcash-compliant" at the bottom of any webpage featuring an iFriends image or video archive; see example.) Additional tools for locating and identifying suitable content are described on the ClickCash website.

Q: Can I use sexually explicit content?

A: Yes - provided that such sexually-explicit content is not made available to minors or presented to others who have not expressed a desire to encounter and view sensitive erotic material. (See ClickCash Marketing Agreement.) Further, if you are yourself subject to 18 USC 2257, sexually-explicit content from the iFriends Content Library may be used to the extent that you are using the iFriends SafeRecords™ program and taking such other steps as you deem appropriate, in consultation with an independent legal advisor, to make certain you are compliant with 18 USC 2257.

Q: Do I need to have an 18-2257 statement on my own web pages?

A: No, unless you meet the following conditions:

1. You present actual sexually-explicit conduct on your own web pages;



2. In consultation with an independent legal advisor, you conclude you are subject to the requirements of 18 USC 2257. (Although you should consult with your own attorney on such matters, new regulations require that a web site subject to 18 USC 2257 carry a "Record-keeping Requirements Compliance Statement" on its home page, any known major entry points, or principal URL, or in a separate window, that includes a statement describing the location of records establishing the majority age of persons depicted; see here.)

Q: My attorney advises me that it's a good idea for me to present 18-2257 information on my own web page. But I don't like the idea of disclosing my legal name and residential street address to stalkers. Under what circumstances can I present an 18-2257 hotlink that refers users directly to iFriends' own 18-2257 compliance statement?

A: All affiliates and webmasters are free to link to iFriends' own compliance statement provided each of the following conditions exist (we always encourage you to consult with your own independent legal advisor):

1. You are operating your web page as an individual and not as an organization



2. The only visual content that appears on your page is content you have obtained from the iFriends Content Library



3. You use the convenient and automated iFriends SafeRecords™ program to create and maintain records associated with any sexually-explicit iFriends-originated material that you present.

Q: How can I distinguish between "sexually-explicit" content and content that is not sexually-explicit?

A: Sexually-explicit content, for purposes of 18 USC 2257 compliance, means content depicting actual sexual intercourse (including genital-genital, oral-genital, anal-genital, or oral-anal), masturbation, or "lascivious exhibition of the genitals or pubic area of any person" (read the text of the law here). We encourage you to consult with an independent legal advisor, as you deem appropriate, to determine whether visual content on your web pages depicts actual sexually-explicit conduct, but we also encourage you to, like iFriends itself, err on the side of being overly-inclusive in determining what visual content merits the creation and maintenance of proper age-documentation records under the SafeRecords™ program. (In other words, we feel that it's always a good idea to maintain and create records establishing the majority age of every individual depicted in mature-themed content involving any sort of nudity.)

Q: If I use a "starburst"-censored version of iFriends content which in uncensored form is sexually-explicit, is that considered "sexually-explicit" content under the new regulations?

A: 18 USC 2257 establishes record-keeping requirements for any producer of content containing visual depictions of "actual sexually-explicit conduct." We encourage you to consult with an independent legal advisor to determine if visual content used on your web pages constitutes actual sexually-explicit conduct. However, we feel that it's always a good idea to maintain and create records establishing the majority age of every individual depicted in mature-themed content involving any sort of nudity. (Fortunately, all iFriends content – including images and movies that are not sexually explicit – contains 18+ ID Barcodes and therefore is directly supported by SafeRecords™.)

Q: How do I tell if I am subject to the new regulations I've heard so much about?

A: iFriends is not authorized to provide you with legal advice, but we can refer you to the text of the regulation itself, so you can review its contents and determine whether the new regulations apply to you. The link to the statute is here, and the link to the new regulations is here. We strongly encourage you to review both the governing statute and the new associated regulations with your own independent legal advisor in order to determine whether you are subject to them.

Q: My name is Bob. I am a ClickCash Affiliate. I live in the U.S. I present sexually-explicit content on my own web pages for the purpose of promoting iFriends. I obtain this content from the iFriends website itself. My web pages are hosted in the U.S. In exchange for promoting iFriends on these pages, I receive commissions whenever iFriends obtains a new customer as a result of my promotion.
Because of these circumstances, my attorney tells me that I clearly meet the definition of a "secondary producer" under the new 18-2257 regulations. My attorney further tells me that as a consequence, I am therefore required to "create and maintain" my own records that correspond with the sexually-explicit materials I host.

Please tell me how I can create and maintain such records, using the remote iFriends.18-2257.com records hosting and management system.

A: Bob, when you joined ClickCash, you were automatically provided your own "18-2257 file cabinet" located on servers hosted and operated by iFriends/ClickCash. (Your file cabinet is created automatically when you create your ClickCash account.) For example, if your affiliate account code is "MyAccount," your 18-2257 file cabinet is located at http://iFriends.18-2257.com/MyRecords/MyAccount.

Automatic Record-Keeping System: Numerous records required by 18-2257 are automatically posted on your behalf to your 18-2257 file cabinet, such as all URL addresses and dates from which you direct traffic to iFriends, under the auspices of the ClickCash Affiliate Program.

Model-specific/file-specific Record-Keeping System: For affiliates who are subject to the "Secondary Producer" requirement under 18-2257, and who present sexually-explicit materials selected from the iFriends Content Library in their promotions, we encourage you to take full advantage of the additional 18-2257-compliant record-keeping features we offer. These features are easy to use, simple to operate, and enable you to fully meet the required "create and maintain records" provisions under those regulations. In this facility, you create your own 18-2257 record-keeping file entry for each model/file that you use, by submitting just two items:

1. The file you are using from the iFriends content library



2. The URL address from which you will be presenting this file