18 U.S.C. § 2257 Compliance Statement

1. Statement

All visual depictions appearing on or generated by noiretta.com (the "Service") are computer-generated images produced by artificial-intelligence models. They are not photographs or recordings of real human beings, and they do not depict actual human beings engaged in actual sexually explicit conduct.

Accordingly, Vantage Loop LLC asserts that the visual depictions produced by the Service are not subject to the record-keeping and labelling requirements of 18 U.S.C. §§ 2257 and 2257A, or 28 C.F.R. Part 75, because those requirements attach to depictions of actual human beings engaged in actual sexually explicit conduct.

The characters depicted are fictional. Any resemblance between a generated character and a real person arises either from a reference image supplied by a user under the consent rules described in Section 3, or by coincidence.

2. Record-keeping

Because the Service produces no depiction of an actual human being engaged in actual sexually explicit conduct, no Custodian of Records is designated under 28 C.F.R. § 75.6.

This is not an absence of records. Vantage Loop LLC maintains the records described in Section 3 as a matter of policy, and will produce them in response to lawful process. Enquiries may be directed to [email protected].

[Owner decision 2026-10-10: assert the exemption without designating a custodian. Counsel to confirm this position before publication, and to advise if the Service's handling of user-supplied reference images of real adults changes the analysis.]

3. Records we do maintain

Although we assert that §§ 2257 and 2257A do not apply, we voluntarily maintain records that serve the same protective purpose, and we will produce them in response to lawful process:

• an adult attestation from every account holder at registration, with timestamp and IP address;
• for every reference image depicting a real person, an express attestation by the uploading user that the subject is an adult and has consented to the generation of sexually explicit material depicting their likeness, recorded immutably with a timestamp;
• a separate, express likeness-model attestation before any per-character identity model is trained from a real person's images;
• automated age-appearance screening of every uploaded reference image and every generated output, with the outcome recorded against the asset;
• a full provenance record for every generated asset: the account, the character, the prompt, the model and settings used, and the safety assessments applied;
• records of all content reports, removal requests, and the action taken.

These records are retained for the period described in our Privacy Policy and for as long as necessary to establish or defend legal claims.

4. Zero tolerance for minors

Vantage Loop LLC has a zero-tolerance policy toward any depiction of a minor, or of any person who appears to be a minor, in any sexual or sexualized context. This applies to photographic, computer-generated, animated, and AI-generated depictions alike.

Every reference image uploaded and every image generated is screened by an automated age-appearance classifier before it is delivered or stored for delivery. Material assessed as possibly depicting a minor is blocked, is never delivered to the user, the generation is refunded, and the event is recorded for review.

Accounts that attempt to produce such material are terminated. We report apparent child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC) and to law enforcement as required by 18 U.S.C. § 2258A, and we preserve material and records as required by law.

[Counsel to confirm the Company's registration and reporting workflow with NCMEC, and the preservation obligations that attach once a report is made — these are mandatory and time-bound.]

5. Contact

Questions about this statement: [email protected]. Requests for removal of a likeness: [email protected], and see our Content Removal and Non-Consensual Imagery Policy.