Statutory Compliance Statement

Zyrcle (operated by Inifex LTD (16543165), a company registered in England and Wales) is a secondary producer as defined by 18 U.S.C. § 2257(h)(2)(B)(v) with respect to all user-generated content hosted on zyrcle.com.

All persons depicted in any visual depiction of actual sexually explicit conduct appearing or otherwise contained at zyrcle.com were eighteen (18) years of age or older at the time of the creation of such depictions.

Records required pursuant to 18 U.S.C. § 2257 and 28 C.F.R. Part 75 are kept by the designated Custodian of Records identified below.

1. Custodian of Records

Custodian of Records
Inifex LTD (16543165) dba Zyrcle
128 City Road, London, United Kingdom
Email: legal@zyrcle.com
Web: zyrcle.com/2257

Requests for record inspection by the Attorney General of the United States pursuant to 28 C.F.R. § 75.5 should be directed to the Custodian of Records at the address above.

2. Platform Role — Secondary Producer

Zyrcle functions as a secondary producer under 18 U.S.C. § 2257. Zyrcle does not produce or direct the creation of content — creators independently produce all content and upload it to the Platform. As a secondary producer, Zyrcle:

  • Requires all creators (primary producers) to certify compliance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75 as a condition of publishing content depicting actual sexually explicit conduct on the Platform.
  • Requires creators to maintain complete records including the legal name, date of birth, and copy of identity document for each performer depicted in such content.
  • Requires creators to make such records available to Zyrcle upon request within 7 business days.
  • Maintains its own secondary producer records as required by applicable regulation.

3. Creator Obligations (Primary Producers)

Any creator who publishes content on Zyrcle depicting actual sexually explicit conduct is a primary producer under 18 U.S.C. § 2257 and must:

  • Create and maintain records for each performer depicted, including:
    • Full legal name of performer
    • All names, including stage names, used by the performer
    • Date of birth
    • A copy of a government-issued photo ID confirming identity and age
    • The title and URL of any content in which the performer appears
  • Certify in their creator profile that all depicted performers were at least 18 years of age at the time of production.
  • Produce records for inspection within 7 business days upon request from Zyrcle or pursuant to valid legal process.
  • Include a 2257 compliance statement in all content published on the Platform depicting actual sexually explicit conduct.

Non-compliance: Failure to maintain or produce required 2257 records will result in immediate content removal and account suspension. Zyrcle cooperates fully with Department of Justice inspections and investigations.

4. Content Exemptions

The following types of content are exempt from the recordkeeping requirements of 18 U.S.C. § 2257:

  • Content that does not depict actual sexually explicit conduct as defined in 18 U.S.C. § 2256(2)(A)(i)–(iv).
  • Simulated sexual conduct that is not explicit as defined by statute.
  • Lascivious exhibition content that does not meet the statutory definition of actual sexually explicit conduct.

If you are unsure whether your content triggers 2257 obligations, consult qualified legal counsel before publishing.

5. Contact

For 2257 recordkeeping inquiries: legal@zyrcle.com

Inifex LTD (16543165)

128 City Road, London, United Kingdom

Questions about this policy? Email support@zyrcle.com