Age Verification Policy

1. Purpose and Scope

1.1 Why We Verify Age

TDolls is a platform that hosts adult content and facilitates contact between adults. We have a legal and ethical obligation to ensure that no person under the age of 18 can access age-restricted content or features on the Platform.

This Age Verification Policy explains:

• Why age verification is required
• How we verify the age of users
• What happens when age verification is completed or fails
• How age verification data is collected, stored, and protected
• The legal framework underpinning our approach

1.2 Who This Policy Applies To

This policy applies to all users of the Platform — both Service Providers and Service Users (Clients) — and to unregistered visitors who encounter the Platform's public-facing age gate.

1.3 Relationship to Other Documents

This policy should be read alongside:

• Our Privacy Policy — which governs how personal data collected during age verification is handled
• Our General Platform Terms — which set out the age restriction applicable to all users
• Our Service Provider Terms of Service — which set out additional content subject verification obligations for providers
• Our 2257 Compliance Statement — which addresses record-keeping obligations for content depicting adults

2. Legal Framework

2.1 Gibraltar Law

As a platform operated by Corestack Digital Ltd, registered in Gibraltar, our age verification obligations are governed primarily by Gibraltar law, including the Gibraltar GDPR and applicable Gibraltar consumer and media legislation. The Gibraltar Regulatory Authority (GRA) is our supervisory authority for data protection matters arising from age verification.

2.2 UK Online Safety Act

Where the Platform is accessed by users in the United Kingdom, we operate in a manner consistent with the UK Online Safety Act 2023 and guidance issued by Ofcom. This requires us to implement highly effective age verification measures to prevent children from accessing content that is harmful to them. Our age verification approach is designed to meet this standard.

2.3 EU Requirements

Where the Platform is accessed by users in the European Economic Area, we operate in a manner consistent with applicable EU requirements, including the EU Digital Services Act (DSA) and any applicable national legislation implementing age verification requirements for online adult content platforms.

2.4 Compliance Principle

We apply the most stringent applicable standard across all of our domains. The age verification process described in this policy is the same regardless of which domain (TDolls.net, TDolls.eu, or TDolls.uk) a user accesses.

3. The Age Gate — Unregistered Visitors

3.1 Default Restricted Access

All visitors who arrive at the Platform without a verified account are presented with a restricted, age-appropriate (SFW) version of the Platform. This includes:

• A landing page that does not display adult content
• A clear statement that the Platform contains adult content restricted to persons aged 18 and over
• Options to register and verify age, or to leave the Platform

No adult content, full Service Provider profiles, or age-restricted features are accessible without a verified account.

3.2 The Age Gate is Not a Cookie

The SFW restriction is enforced at the account and session level, not solely via cookies. Clearing cookies, using private browsing, or switching devices does not bypass the age gate — access to age-verified content requires an active logged-in session associated with a verified account.

3.3 No Consent by Continued Browsing

We do not operate a model under which continued browsing of the SFW landing page constitutes consent to age verification or acceptance of our terms. Age verification and account creation are distinct actions that require active completion by the user.

4. Age Verification at Registration

4.1 How We Verify Age at Registration

At the point of account creation, all users — both Service Providers and Service Users — are required to provide their date of birth via a DD/MM/YYYY input field. This date of birth is used to calculate whether the user is 18 years of age or older at the time of registration.

The date of birth verification process at registration is self-declaration based. The user declares their date of birth and confirms, via an explicit declaration statement, that the date provided is accurate and that they are 18 or over.

4.2 What Is Recorded

At the point of registration, the following is recorded as part of the consent and verification record:

• The date of birth as entered
• The calculated age at time of registration
• The timestamp of submission
• The user's IP address and device information
• The explicit age declaration made by the user
• The version of this Age Verification Policy in effect at the time

This record is permanent and is not deleted upon account closure. It forms part of the compliance record for the account.

4.3 Attempted Registration by Under-18s

If a user enters a date of birth that indicates they are under 18 years of age, the registration form will not proceed. The user will be shown a message explaining that the Platform is restricted to adults aged 18 and over.

The failed attempt is logged, including the timestamp, IP address, and device information. The date of birth entered is not retained in the failed attempt log — only the fact that an underage attempt was made. These logs are retained for two years for fraud prevention and compliance purposes.

We do not contact attempted underage registrants. We do not use the failed attempt data for any purpose other than compliance monitoring and fraud prevention.

4.4 Limitations of Self-Declaration

We acknowledge that self-declaration of date of birth is not a foolproof method of age verification. A user who provides a false date of birth may successfully register. We address this limitation through:

• Technical and device data collected at registration, which provides additional signals for anomaly detection
• Ongoing monitoring and moderation of Platform activity
• Additional identity verification for Service Providers (Section 5)
• Our reporting mechanisms, which allow any person to flag suspected underage access
• Cooperation with relevant authorities where underage access is identified

Providing a false date of birth to circumvent age verification is a breach of these Terms, may constitute a criminal offence under applicable law, and will result in immediate account termination.

5. Enhanced Verification for Service Providers

5.1 Why Providers Require Enhanced Verification

Service Providers upload content, including photographs and descriptions, to the Platform. This creates a higher level of responsibility — both for the platform and for the provider — to ensure that providers are who they say they are, are of legal age, and that any content they upload complies with applicable law.

5.2 Identity Verification Process

Service Providers are required to complete identity verification as part of their onboarding process. This is in addition to the date of birth declaration made at registration. Identity verification is carried out using a contracted third-party verification provider and may include:

• Submission of a government-issued identity document (such as a passport or national identity card)
• A liveness check (selfie or short video) to confirm that the person submitting the document matches the document holder
• Automated and/or manual review of the submitted documents

5.3 What We Receive from the Verification Provider

We do not receive or store the identity documents you submit. Our verification provider processes the documents and returns to us a verification result only, which includes:

• Pass or fail status
• Confirmed age range (confirming the subject is 18 or over)
• A verification reference number for audit purposes

The underlying documents are held by our verification provider in accordance with their own data retention policies, which we will link to during the verification process. You should review their privacy policy before submitting documents.

5.4 Consequences of Failed Provider Verification

If identity verification fails or cannot be completed, your Service Provider account will remain in a restricted state. You will not be able to publish a profile or upload content until verification is successfully completed. We will notify you of the failure and provide information on how to resubmit or appeal.

5.5 Re-Verification

We reserve the right to require Service Providers to complete re-verification at any time, including where:

• We have reason to believe the verified identity does not match the account holder
• Verification data has expired or the verification provider's records are no longer current
• We are required to re-verify by applicable law or regulatory guidance

6. Content Subject Verification

6.1 Provider Responsibility

Where a Service Provider uploads content that depicts any person other than themselves, the provider is responsible for verifying and recording that all persons depicted are adults. This is a legal requirement under applicable content regulations, including those mirrored in our 2257 Compliance Statement.

6.2 What Providers Must Record

For any content depicting a third party, the provider must:

• Verify that the depicted person is 18 years of age or older
• Obtain and retain a copy of that person's government-issued identity document confirming their age
• Obtain and retain explicit written consent from that person for their appearance in the content
• Make these records available to us or to relevant authorities upon request

6.3 Platform Records

We do not collect or store identity documents relating to content subjects. The record-keeping obligation rests with the Service Provider. However, we may request confirmation from a Provider that records exist in relation to specific content, and failure to confirm may result in that content being removed.

7. Ongoing Verification and Monitoring

7.1 Continuous Compliance

Age verification at registration is the primary checkpoint, but we also maintain ongoing safeguards including:

• Content moderation to identify any indicators that a user or content subject may be underage
• Automated detection of anomalous account behaviour consistent with underage access
• User and third-party reporting mechanisms for suspected underage access
• Periodic review of our age verification processes against current legal and regulatory standards

7.2 Reporting Suspected Underage Access

If you have reason to believe that a person under 18 is accessing the Platform or has been depicted in content on the Platform, you must report this immediately using our reporting tools or by emailing safeguarding@tdolls.net.

We treat all reports of suspected underage access as urgent and will investigate promptly. Where we identify underage access, we will terminate the relevant account, remove any associated content, and report the matter to relevant authorities where required by law.

8. Age Verification Data — Collection, Storage, and Retention

8.1 Data Collected

The personal data collected in connection with age verification is described in detail in our Privacy Policy. In summary, it includes:

• Date of birth
• Age verification result (pass/fail)
• Timestamp and device/technical data at the point of verification
• For Service Providers: the verification reference number from our third-party provider

8.2 How We Use Verification Data

Age verification data is used solely for the following purposes:

• Confirming eligibility to access the Platform
• Maintaining a compliance record of age verification
• Fraud prevention and detection of false registrations
• Responding to law enforcement or regulatory requests where required by law

We do not use age verification data for marketing, profiling, or any purpose unrelated to compliance and security.

8.3 Retention

Age verification records are retained for the duration of your account plus six years following account closure. Consent and verification records are permanent compliance records and are not subject to deletion requests under data subject rights, as described in our Privacy Policy.

Failed age verification attempt logs are retained for two years.

8.4 Third-Party Verification Provider Data

Where a Service Provider has submitted identity documents to our third-party verification provider, retention of those documents is governed by that provider's data retention policy. We will provide a link to the relevant policy before you begin the verification process. You have the right to contact the verification provider directly regarding your data held by them.

8.5 Your Rights

Your rights in relation to personal data collected during age verification are set out in Section 11 of our Privacy Policy. Please note that the right to erasure does not apply to verification records that we are required to retain for legal or regulatory compliance purposes.

9. Cookies and Age Verification

The age_gate cookie records that you have passed age verification for the current browser session. It is a strictly necessary cookie and does not require consent. It expires at the end of your browser session.

This cookie is a session convenience layer only — it does not replace or represent your underlying verified account status. Full details of cookies used in connection with age verification are set out in our Cookie Policy.

10. Challenging or Appealing Age Verification Decisions

10.1 Failed Registration

If you believe your registration was incorrectly blocked due to an error in the age calculation (for example, a date entry error), you may contact support@tdolls.net to request a review. You will be asked to confirm your date of birth and may be asked to provide supporting evidence.

10.2 Failed Provider Identity Verification

If your identity verification as a Service Provider has failed and you believe this is an error, you may appeal by contacting providers@tdolls.net. We will provide you with information on the basis of the failure where possible and guide you through the resubmission process.

10.3 Account Termination for Suspected Underage Access

If your account has been terminated because we believe you are under 18 and you believe this is an error, you may appeal by contacting support@tdolls.net within 28 days of receiving notice of termination. You will be asked to provide evidence of your age.

11. Changes to This Policy

We review this policy regularly against changes in applicable law, regulatory guidance, and best practice. When we make material changes we will:

• Update the "Last updated" date and version number at the top of this document
• Notify registered users by email
• Display a notice on the Platform

The current version of this policy is always available at tdolls.net/age-verification, tdolls.eu/age-verification, and tdolls.uk/age-verification.

12. Contact

For age verification queries and appeals:

For safeguarding concerns including suspected underage access:

For data protection matters relating to age verification data:

This document is version TDOLLS-AVP-v1.0. The current version is always available at tdolls.net/age-verification, tdolls.eu/age-verification, and tdolls.uk/age-verification.