Age Assurance & Minor Protection Policy

AGE ASSURANCE & MINOR PROTECTION POLICY

Effective Date: September 17, 2026
Last Updated: September 17, 2026

1. PURPOSE AND SCOPE

SubZuu is an adults-only platform. Access to adult-oriented content, products, services, purchases, subscriptions, pay-per-view content, rentals, and other restricted features may be subject to age-assurance or age-verification requirements.

This Age Assurance & Minor Protection Policy ("Policy") describes the measures SubZuu uses to prevent minors from accessing age-restricted services and content, the information that may be processed during age assurance, the technologies that may be used, how age-assurance information is handled, and the rights and responsibilities of users.

This Policy forms part of SubZuu's legal and compliance framework and should be read together with the Fan Terms of Use, Privacy Policy, Creator Terms of Use, Content Provider Agreement, and other applicable SubZuu policies.

By using SubZuu, creating an account, requesting access to restricted functionality, or completing an age-assurance process, you agree to comply with this Policy and all other applicable SubZuu terms and policies.

Nothing in this Policy limits any additional rights or protections available to you under applicable law.

2. ADULTS ONLY

SubZuu is intended exclusively for adults who are at least eighteen (18) years of age and who have reached the age of majority required to access adult content in their applicable jurisdiction.

Minors are strictly prohibited from accessing age-restricted SubZuu content or services.

A person who is under 18 years of age, or who otherwise has not reached the legal age required to access adult content in their jurisdiction, must not attempt to circumvent, defeat, misrepresent, interfere with, or bypass SubZuu's age-assurance controls.

SubZuu may deny, restrict, suspend, or terminate access where we reasonably determine that a user does not satisfy applicable age requirements or where required by law.

3. AGE ASSURANCE

SubZuu uses a risk-based and jurisdiction-aware Age Assurance system designed to determine whether a user satisfies the minimum age required to access protected services or content.

Depending on applicable law, jurisdiction, platform policy, account history, risk level, and the type of access requested, SubZuu may use one or more age-assurance methods.

These methods may include:

* age attestation;
* date-of-birth information;
* account information;
* previous verified age-assurance status;
* facial liveness technology;
* facial age estimation;
* government-issued identification;
* document-based date-of-birth verification;
* commercially reasonable age-verification technologies;
* privacy-preserving proof-of-age mechanisms where available; and
* other lawful age-assurance methods that SubZuu determines are appropriate.

SubZuu may modify or replace an age-assurance method where necessary to comply with applicable law, regulatory guidance, security requirements, technological developments, or platform safety requirements.

4. JURISDICTION-BASED REQUIREMENTS

Age-verification laws differ by country, state, territory, and other jurisdiction.

SubZuu may therefore apply different age-assurance requirements depending on the jurisdiction associated with a request.

Where applicable, SubZuu may use technical information associated with a request, including network or geographic information made available through our infrastructure, to determine which age-assurance requirements apply.

Users may not use a virtual private network, proxy, location-spoofing technology, false account information, or any other method for the purpose of evading legally required or SubZuu-required age assurance.

SubZuu reserves the right to deny access where applicable age requirements cannot reasonably be established or where access would otherwise violate applicable law.

5. ADVANCED AGE ASSURANCE

Where enhanced verification is required, SubZuu may require an Advanced Age Assurance process before permitting access to protected transactions, services, or content.

SubZuu's Advanced Age Assurance process may use technologies provided by Amazon Web Services ("AWS"), including Amazon Rekognition technologies, to conduct facial liveness analysis and age estimation.

A facial liveness check is designed to determine whether the person participating in the verification appears to be a real, live person rather than a photograph, recording, digital reproduction, mask, automated system, or other presentation attack.

Age-estimation technology may then be used to estimate whether the person satisfies the applicable age threshold.

Age estimation is not used by SubZuu to establish a person's identity.

SubZuu does not use the Advanced Age Assurance process for advertising, marketing profiling, personalized advertising, or facial recognition searches.

6. FACIAL INFORMATION AND CONSENT

An Advanced Age Assurance process may require temporary capture and processing of facial images, video frames, liveness information, or information derived from those materials.

Before initiating such processing, SubZuu provides notice regarding the age-assurance process and requests affirmative user consent where required or appropriate.

By affirmatively continuing after receiving the applicable notice, the user authorizes the processing necessary to conduct the requested age-assurance procedure, subject to this Policy and applicable law.

If a user does not wish to complete a required age-assurance process, the user may cancel the process. However, SubZuu may be legally or contractually prohibited from providing the requested age-restricted access or transaction without successful age assurance.

7. GOVERNMENT-ISSUED IDENTIFICATION FALLBACK

SubZuu attempts to minimize the collection of government identification.

A government-issued identification document is not required in every verification.

If the initial age-assurance process cannot establish with sufficient confidence that a user satisfies the applicable age requirement, SubZuu may offer or require a government-ID verification process.

A user may be asked to submit a clear image of an accepted government-issued identification document.

The document may be processed using technologies including Amazon Textract AnalyzeID or comparable document-analysis technologies for the limited purpose of extracting information necessary to determine age, including date of birth.

SubZuu's government-ID fallback is designed to determine age eligibility and is not intended to create a permanent copy of the user's identification document.

8. DATA MINIMIZATION

SubZuu follows a data-minimization approach to Age Assurance.

We seek to collect or process only information reasonably necessary to:

* determine whether a user satisfies an applicable age threshold;
* perform required liveness or fraud-prevention checks;
* comply with applicable age-verification laws;
* protect minors from age-restricted content;
* protect the integrity and security of the verification process; and
* maintain limited records necessary to demonstrate that an age-assurance determination occurred.

Age-assurance information is not collected for advertising purposes and is not intended to be used to build advertising profiles.

9. TEMPORARY IMAGES AND DOCUMENTS

Raw facial images, liveness imagery, and government-ID images used by SubZuu for Age Assurance are intended to be temporary verification materials rather than permanent account records.

Government-ID images temporarily submitted to SubZuu for document-based age verification are deleted from SubZuu-controlled temporary storage following processing in accordance with the operation of the Age Assurance system.

SubZuu does not intentionally maintain a permanent copy of a government-issued identification image submitted solely for Age Assurance after the verification process for which it was collected has been completed, except where retention is required by applicable law, necessary to investigate fraud or abuse to the extent legally permitted, or otherwise legally required.

SubZuu configures its Age Assurance processes with the objective of minimizing the retention of raw facial and identification materials.

Certain temporary processing may occur within infrastructure operated by technology service providers necessary to perform the verification. Such processing is subject to the provider's applicable service terms, security controls, and data-handling practices.

10. AGE-ASSURANCE RECORD

SubZuu may retain a limited record establishing that an age-assurance process was successfully completed.

This record may include information such as:

* verification status;
* assurance level;
* verification method;
* verification date or timestamp;
* verification reference or transaction identifier;
* jurisdiction or policy information relevant to the determination; and
* limited audit or security information.

This record is intended to allow SubZuu to recognize that a user has previously satisfied an applicable age-assurance requirement without requiring the user to repeatedly provide sensitive verification materials.

Unless required by law or necessary for an authorized security or compliance purpose, the durable verification record is not intended to contain the raw government-ID image or raw facial verification media.

11. PURPOSE LIMITATION

Information collected specifically for Age Assurance will be used for age assurance, legal compliance, minor protection, verification security, fraud prevention related to the verification process, and other directly related compliance purposes.

SubZuu does not sell raw facial images or government-ID images collected for Age Assurance.

SubZuu does not use government-ID images submitted for Age Assurance for advertising.

SubZuu does not use facial material collected specifically through the Age Assurance process to create advertising profiles.

SubZuu will not intentionally repurpose Age Assurance information in a manner incompatible with the purpose for which it was collected except where authorized or required by applicable law.

12. TECHNOLOGY SERVICE PROVIDERS

SubZuu may use qualified technology and infrastructure providers to perform portions of the Age Assurance process.

SubZuu currently uses technologies provided by Amazon Web Services (AWS), including technologies associated with Amazon Rekognition and Amazon Textract.

Information necessary to perform an Age Assurance operation may therefore be securely transmitted to and processed by AWS as a technology service provider.

Use of a technology provider does not change SubZuu's requirement that Age Assurance information be handled in accordance with applicable law, this Policy, and applicable contractual safeguards.

SubZuu may replace, supplement, or add verification providers or technologies where appropriate for security, reliability, privacy, legal compliance, or availability.

13. SECURITY

SubZuu uses administrative, technical, and organizational safeguards designed to protect Age Assurance information against unauthorized access, disclosure, alteration, misuse, or destruction.

Depending on the applicable component, safeguards may include encrypted network communications, access controls, temporary credentials, restricted infrastructure permissions, encrypted cloud services, data minimization, short-lived upload authorization, server-side verification decisions, and deletion of temporary verification materials.

No information system can be guaranteed to be completely secure. SubZuu therefore cannot guarantee absolute security, but we maintain safeguards designed to be appropriate to the nature and sensitivity of the information processed.

14. NO SALE OF AGE-VERIFICATION DATA

SubZuu does not sell personal information collected specifically for Age Assurance.

SubZuu does not permit raw government-ID images or facial materials collected specifically for Age Assurance to be used for targeted advertising or marketing profiling.

15. MINOR PROTECTION

SubZuu maintains a strict prohibition against minors accessing adult content through the Service.

If SubZuu determines or reasonably believes that an account is operated by, controlled by, or being used to provide adult-content access to a minor, SubZuu may immediately:

* restrict access;
* block protected content;
* prevent purchases;
* suspend or terminate the account;
* require additional verification;
* preserve information where legally required;
* investigate suspected circumvention or abuse; and
* make reports or disclosures where required by law.

A failed or denied age-verification result does not create a right to access age-restricted content.

16. INFORMATION INVOLVING A POSSIBLE MINOR

SubZuu's Age Assurance systems may necessarily process limited information from a person who ultimately does not satisfy the applicable adult age threshold.

Such information will be handled for the limited purposes of determining age eligibility, protecting minors, preventing unlawful access, maintaining security, and satisfying applicable legal obligations.

SubZuu's policy is to minimize such processing and not use information collected specifically for Age Assurance for unrelated commercial purposes.

Where applicable law requires deletion of information collected from or relating to a minor for age-verification purposes, SubZuu will apply the legally required deletion standard.

17. CHILDREN'S PRIVACY

SubZuu is not directed to children and does not knowingly permit children to use age-restricted portions of the Service.

SubZuu's Age Assurance program is intended in part to prevent minors from entering an adults-only environment.

Information collected solely to determine whether a person satisfies the applicable age requirement will be handled in accordance with applicable children's-privacy requirements.

Where required, SubZuu may delete, restrict, or otherwise process information associated with an underage individual to comply with applicable law and protect the individual from access to age-restricted services.

18. VERIFICATION FAILURE

Age-assurance technology is not infallible.

Lighting, camera quality, image quality, document condition, technical errors, network conditions, accessibility limitations, or other factors may prevent successful verification.

Failure of one verification method does not necessarily mean that SubZuu has determined that the user is a minor.

Where permitted, SubZuu may provide another verification method.

However, where SubZuu determines that a valid government-issued document establishes that a person is below the applicable age threshold, access to age-restricted services will be denied.

19. CHALLENGES AND CORRECTIONS

A user who believes an age-assurance determination was made incorrectly may contact SubZuu for assistance.

SubZuu may require another age-assurance method before reversing an age-related access restriction.

Requests may be submitted to:

[compliance@subzuu.tv](mailto:compliance@subzuu.tv)

A request should not include an unsolicited copy of a government-issued identification document unless SubZuu specifically instructs the user to provide it through an authorized secure verification process.

Users should never email government-ID images to SubZuu unless expressly instructed through an approved secure process.

20. ACCESSIBILITY AND ALTERNATIVE VERIFICATION

SubZuu recognizes that facial liveness or other Age Assurance technologies may not be appropriate or accessible for every user.

Where reasonably available and permitted by applicable law, SubZuu may provide an alternative age-verification method for users who cannot successfully complete a particular verification method.

Availability of an alternative method does not permit a user to bypass age verification entirely where verification is legally or operationally required.

21. PROHIBITED CIRCUMVENTION

Users may not attempt to defeat or circumvent Age Assurance.

Prohibited conduct includes:

* submitting another person's identification;
* using another person's face or likeness;
* using photographs, videos, masks, deepfakes, artificial images, or synthetic media to defeat liveness checks;
* falsifying date-of-birth information;
* manipulating verification images or documents;
* interfering with verification software;
* using automated systems to defeat verification;
* intentionally misrepresenting location to avoid applicable requirements; or
* assisting another person in circumventing Age Assurance.

SubZuu may suspend or terminate accounts associated with attempted circumvention and may preserve or disclose information where required or permitted by applicable law.

22. AUTOMATED PROCESSING

Certain Age Assurance determinations are made or assisted by automated technologies.

These technologies may evaluate facial liveness, estimated age ranges, document information, account verification status, and applicable Age Assurance policies.

SubZuu uses these results to determine whether additional verification is required or whether age-restricted access may continue.

Where required by applicable law, users may request information about, challenge, or seek review of an automated age-assurance determination.

23. UNITED STATES COMPLIANCE

SubZuu's Age Assurance program is designed to support compliance with applicable United States federal and state requirements governing access by minors to adult-oriented content.

Because requirements vary by jurisdiction, SubZuu may impose different verification requirements in different states or territories.

Where applicable law prohibits retention of identifying information collected for age verification, SubZuu will apply the legally required non-retention standard.

Where applicable law requires use of particular verification methods, privacy safeguards, independent providers, anonymous verification, or other specific procedures, SubZuu may modify the verification method offered in that jurisdiction or restrict access where an appropriate compliant method is unavailable.

Nothing in this Policy should be interpreted as reducing protections provided under applicable state or federal law.

24. INTERNATIONAL USERS

Users outside the United States may be subject to additional age-assurance, privacy, data-protection, or online-safety requirements.

SubZuu may apply jurisdiction-specific controls or restrict availability of services where necessary to satisfy applicable requirements.

For jurisdictions governed by privacy frameworks requiring proportionality, purpose limitation, data minimization, transparency, privacy by design, or similar principles, SubZuu intends its Age Assurance system to process only information reasonably necessary to establish age eligibility and related security and compliance requirements.

Where local law provides rights relating to access, correction, deletion, restriction, objection, automated decision-making, or other processing of personal information, those rights remain subject to the applicable law and SubZuu's Privacy Policy.

25. AGE ASSURANCE DOES NOT ESTABLISH IDENTITY

Unless expressly stated otherwise, an Age Assurance result establishes only the age-assurance status necessary for the relevant SubZuu access decision.

A successful Age Assurance result does not necessarily establish:

* the legal identity of the user;
* ownership of an account;
* ownership of a payment method;
* authenticity of content uploaded by the user; or
* eligibility for any purpose other than the applicable SubZuu age requirement.

Additional identity, payment, creator, or compliance verification may be separately required.

26. NO GUARANTEE OF ERROR-FREE RESULTS

Age-estimation, facial liveness, document analysis, and other automated technologies may produce incorrect, inconclusive, or incomplete results.

SubZuu does not represent that any age-assurance technology is error-free.

SubZuu may use fallback methods, additional evidence, retries, manual review where appropriate, or other safeguards to address inconclusive results.

27. FRAUD, SECURITY, AND LEGAL PRESERVATION

Nothing in this Policy requires SubZuu to delete information that was independently collected for another lawful purpose merely because the same user later completes Age Assurance.

Information associated with account security, fraud, transactions, legal obligations, abuse prevention, or other independent purposes may be maintained according to the retention requirements applicable to those purposes.

Where applicable law requires preservation of information in response to litigation, a lawful government demand, an investigation, or another legal obligation, SubZuu may preserve information to the extent legally required.

This section does not authorize retention of age-verification information where applicable law expressly prohibits such retention.

28. USER REPRESENTATIONS

By requesting access to age-restricted SubZuu services, you represent that:

* you are legally permitted to access adult content in your jurisdiction;
* information you provide for Age Assurance is accurate and belongs to you;
* any identification document submitted by you is authentic and lawfully possessed by you;
* you will not submit another person's information without lawful authorization;
* you will not attempt to circumvent Age Assurance; and
* you understand that successful Age Assurance may be required before access or a transaction is permitted.

29. CHANGES TO VERIFICATION REQUIREMENTS

Age-assurance laws, regulations, technologies, and industry standards continue to develop.

SubZuu may update this Policy, its Age Assurance technologies, verification thresholds, required methods, jurisdictional policies, or access requirements where reasonably necessary for legal compliance, security, privacy, platform safety, technological improvement, or protection of minors.

Material updates to this Policy will be reflected by an updated "Last Updated" date or through another legally appropriate notice mechanism.

Continued use of SubZuu after an updated Policy becomes effective constitutes acceptance to the extent permitted by applicable law.

30. RELATIONSHIP TO PRIVACY POLICY AND TERMS

This Policy supplements SubZuu's Privacy Policy and applicable Terms of Use.

The Privacy Policy provides additional information regarding SubZuu's broader collection, use, disclosure, security, retention, and handling of personal information.

If this Policy provides greater protection for information collected specifically for Age Assurance than a general provision of another SubZuu policy, SubZuu intends to apply the more protective Age Assurance provision to that information, except where applicable law requires otherwise.

If applicable law provides greater protection than this Policy, applicable law controls.

31. REGULATORY AND LEGAL REQUESTS

SubZuu may cooperate with regulators, courts, law-enforcement agencies, or other governmental authorities when legally required.

SubZuu does not voluntarily provide raw Age Assurance information to governmental authorities merely because a person attempted to access age-restricted content.

Any disclosure will be evaluated under applicable law and SubZuu's legal obligations.

Where applicable law prohibits transmission of identifying information collected for Age Assurance to governmental entities, SubZuu will comply with that prohibition.

32. COMPLIANCE CONTACT

Questions, privacy concerns, age-assurance challenges, or compliance inquiries relating to this Policy may be directed to:

SubZuu Compliance
Email: [compliance@subzuu.tv](mailto:compliance@subzuu.tv)

Do not send copies of government-issued identification documents by ordinary email unless specifically instructed by SubZuu through an authorized secure verification procedure.

33. SEVERABILITY

If any provision of this Policy is determined to be invalid, unlawful, or unenforceable in a particular jurisdiction, that provision will be interpreted or limited to the minimum extent necessary to make it enforceable where legally permissible, and the remaining provisions will remain in effect.

34. JURISDICTION-SPECIFIC RIGHTS

Nothing in this Policy waives any right or protection that cannot lawfully be waived.

Where the laws of a user's jurisdiction impose additional requirements regarding age verification, biometric information, children's privacy, personal information, data retention, or automated decision-making, SubZuu will apply those requirements to the extent applicable.

35. ENFORCEMENT

SubZuu may enforce this Policy through technical restrictions, transaction restrictions, content-access controls, account restrictions, suspension, termination, additional verification, or other measures permitted by applicable law and SubZuu's Terms.

Attempting to circumvent Age Assurance may constitute a violation of the Fan Terms of Use and may result in loss of access to SubZuu services.

36. CONTACT

For questions regarding this Policy:

[compliance@subzuu.tv](mailto:compliance@subzuu.tv)

For general privacy matters, please also review the SubZuu Privacy Policy available through the SubZuu Legal Center.

END OF AGE ASSURANCE & MINOR PROTECTION POLICY