18 U.S.C. § 2257 Records Statement
Last updated August 13, 2026
18 U.S.C. § 2257 and § 2257A require producers of certain sexually explicit visual depictions of actual human beings to create and maintain age-verification records for each such depiction, and to post a statement identifying the custodian of those records. This page is that statement, and an honest description of where Twindra's content falls relative to that requirement.
Content that does not depict an actual person
A substantial portion of content generated on Twindra depicts fully synthetic AI personas — built entirely from selected attributes, with no real person's photo involved at any point. Depictions that do not depict an actual, identifiable human being fall outside § 2257's scope, which applies specifically to depictions of real people. We do not maintain § 2257 records for this content because the statute does not require it for content of this kind.
Content built from uploaded photos
Twindra also allows personas to be built from photos a user uploads — either of themselves or of an AI-generated persona created elsewhere. Where an uploaded photo does depict a real, identifiable person, § 2257's record-keeping requirement is intended to apply to that underlying depiction.
Stated plainly, this is a known gap, not a claim of compliance: at upload time, Twindra currently collects a self-attestation (checkbox-based confirmation of age 18+, ownership/rights, and consent — see our Terms of Service, Section 5) rather than the documentary, ID-verified age records § 2257 contemplates. A real identity/age-verification pipeline — collecting and retaining a copy of government-issued ID against each uploaded-photo persona, per § 2257's actual requirements — is planned but not yet built. This statement discloses that gap rather than implying a compliance posture that doesn't exist yet.
Custodian of records
To the extent § 2257 records are maintained, the custodian of records is:
Kilian Becher
Twindra (trade name of an Austrian sole proprietorship / Einzelunternehmer)
Linzer Straße 18, 1140 Vienna
Austria
Reporting a concern
If you believe Twindra is hosting content that depicts a real, identifiable person without their consent — including content that may depict a minor — use our content report page immediately. See Terms of Service Section 7 for our zero-tolerance policy on content depicting or appearing to depict minors.
Contact
Questions about this statement: support@twindra.app.