DRAFT — ATTORNEY REVIEW REQUIRED BEFORE PUBLISHING
Counsel to confirm the exemption position under 28 C.F.R. § 75.1(c), and separately to opine on the watermarking transformation before that SKU launches. Strategy §8.6 names Full-File Retention and per-subscriber watermarking as the two facts that could move us toward secondary-producer territory. Do not publish a watermarking product page until that opinion exists.
We are a service provider, not a producer. Here is the statement that says so.
§1 — The exemption statement
FOUNDER: entity legal name, doing business as Leak Cleaner, is not a producer, whether primary or secondary, of any visual depiction of actual or simulated sexually explicit conduct, as those terms are defined at 18 U.S.C. § 2257 and § 2257A and the regulations at 28 C.F.R. Part 75.
Our activities fall within 28 C.F.R. § 75.1(c), which excludes from the definition of producer activities that are limited to the transmission, storage, retrieval, hosting, formatting or translation of a communication, without selection or alteration of the content.
All content on this website is non-explicit. This site contains no depictions of sexually explicit conduct and never will.
§2 — Custodian of Records
Records required under 18 U.S.C. § 2257, to the extent any are required of this entity, are maintained by:
Custodian of Records
FOUNDER: entity legal name
FOUNDER: registered agent address
That is a registered-agent address. It is not a home address, and no address associated with any client, contractor or officer of this company appears in any public record we control.
§3 — What we do not do, stated as specifics
This is the part of the page that matters, because the exemption depends on facts rather than on a heading.
- We do not create, produce, direct, film, photograph, or commission any visual depiction.
- We do not digitize, alter, edit, retouch, crop, resize, transcode, or reproduce any depiction of sexually explicit conduct.
- We do not select, curate, publish, distribute, sell, licence, or make available any depiction of sexually explicit conduct.
- We do not host any content publicly. There is no public upload surface and there is no portal on day one.
- We do not display thumbnails of client reference content anywhere in our interface, our reports, our marketing, or our emails.
What we do instead. We do not ask a client for copies of her content and we do not hold any. Ownership is verified from links to her own posts and the dates they went out. The only depictions that reach us are page captures of the infringing material itself, held as evidence under the schedule on /trust/.
Full-File Retention is not available today. If it ships it will be an explicit opt-in and never the default, and this page changes before it does.
There is no portal on day one. Until it ships, every request about what we hold runs by email. One line to FOUNDER: privacy email, no call and no questions, and we start it the same working day. When the portal ships it becomes one button.
What we store and for how long →
§4 — Watermarking, scoped honestly
Per-subscriber watermarking is not offered today, on any tier, at any price. It is described here because it is the one adjacent thing that could move this analysis, and the position belongs on the page before the product rather than after it.
If it is ever offered, it would work only where a unique file is served to a single recipient, which means paid direct messages and custom content, never feed posts. It would be performed only on files supplied by the depicted rights holder, only under written instruction from her, and only for the purpose she specifies. Nothing would be watermarked on our own initiative and no source file would be retained beyond the instruction.
§5 — What our clients warrant
Every client agrees, in the signed service agreement, that:
- Every person depicted in any material supplied to us was at least 18 years of age at the time of creation.
- The client is the producer of that material or holds the rights to it, and maintains any records required under 18 U.S.C. § 2257.
- The client names its own Custodian of Records and that custodian's address in the signed agreement.
- The client indemnifies Leak Cleaner against any deficiency in those records.
We ask about this at intake. We ask who shot each set, whether a collaboration partner was involved, and whether any management agreement assigns rights. Those questions slow onboarding down. They are there on purpose.
§6 — The hard stop
If material involving a person who was under 18 appears at any point, in any channel, this stops being a commercial matter immediately.
We preserve. We do not download and we do not forward. We report to the NCMEC CyberTipline. We notify the platform. We contact outside counsel the same hour. We contact nobody else. Nothing about it is monetized, and the commercial relationship ends.
There is a written, dated procedure for this, with a named responsible person. Everyone who works a search or a notice here follows it from their first day or they do not start.
Last updated LAST_UPDATED.