Privacy Policy

DRAFT FOR ATTORNEY REVIEW — NOT LEGAL ADVICE. This is a starting template generated to speed up a licensed adult-industry attorney's review. Do not publish or rely on it until an attorney has reviewed and finalized it. Bracketed [PLACEHOLDERS] must be completed.

Privacy Policy — Underground TV

Effective date: [EFFECTIVE DATE] Last updated: [LAST UPDATED DATE]

Underground TV (the "Site," "we," "us," or "our") is operated by Ghetto Media Group LLC, a New Mexico limited liability company. This Privacy Policy explains what information we collect when you visit or use ugtv.tv, how we use and share it, how long we keep it, and the choices and rights you have. It applies to visitors, account holders ("subscribers" or "members"), and content creators ("creators") who use the Site.

This document is general information about our data practices. It is not legal advice.

By using the Site, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Site.

1. Who We Are and How to Reach Us

The data controller/business responsible for your information is:

Ghetto Media Group LLC [OPERATOR / ENTITY MAILING ADDRESS] Privacy contact: [PRIVACY CONTACT EMAIL] General / support contact: [SUPPORT CONTACT EMAIL]

If you have questions about this policy or wish to exercise a privacy right, use the privacy contact above. See Section 18 for full contact details.

2. Adults Only — This Site Is Not Directed to Minors

Underground TV is an adults-only (18+) platform that hosts sexually explicit adult material. The Site is intended solely for adults who are at least 18 years old (or the age of majority in their jurisdiction, whichever is greater). It is not directed to children, and we do not knowingly collect personal information from anyone under 18. See Section 15 (Children's Privacy) for more detail.

3. Information We Collect

We collect the following categories of information:

a. Account and profile information. When you register, we collect your email address, a password (stored only in hashed/encrypted form — we do not store passwords in plain text), and any display name or username you choose.

b. Creator identity, verification, tax, and recordkeeping information. If you register as a creator (or otherwise upload or appear in content), we — or our verification and payout partners acting on our behalf — collect additional information required to publish and pay for adult content and to meet our legal obligations. This may include your legal name; date of birth; a government-issued photo identification; verification that you (and every individual depicted in content you upload) are at least 18 years old and consented to the creation and distribution of that content; tax information (such as a Form W-9, Form W-8BEN, or equivalent) and a taxpayer identification number for payout and tax-reporting purposes (including issuing IRS Form 1099 where required); and payout account details. Some of this information is collected and retained to comply with federal adult-content recordkeeping law (18 U.S.C. § 2257 / 2257A) and with payment card network rules that require documented age and identity verification and consent for all persons depicted in uploaded content. See Sections 4 and 10.

c. Age-verification result (subscribers and visitors). Before granting access to adult content, we require age verification through our third-party verification provider, VerifyMy (VerifyMyAge / VerifyMy). VerifyMy performs the identity/age check on its own systems and returns to us only a pass/fail result together with a verification reference or token and a timestamp. We are designed to store only that result (verified: yes/no), the reference/token, the verification method, and the time — not the underlying government-ID images, selfie/biometric data, or document numbers you may provide to VerifyMy. VerifyMy's handling of the identity data you submit to it is governed by VerifyMy's own privacy policy at [VERIFYMY PRIVACY POLICY URL]. See Section 9 for our data-minimization commitments on age verification.

d. Subscription and payment information. When you purchase an All-Access pass, a subscription to a creator, or other paid content, our payment processor, CCBill, handles the transaction on its own hosted pages. We do not receive or store your full payment-card number, card security code (CVV), or bank-account credentials. We receive and store limited transaction data from CCBill needed to manage your access and comply with law — for example, a subscription/transaction identifier, subscription status, billing cycle, the amount and date, the payment brand/last four digits and approximate billing location as provided by CCBill, and whether a payment succeeded, failed, was refunded, charged back, or canceled. CCBill's processing of your payment information is governed by CCBill's own privacy policy and terms.

e. Content and activity information. For creators, this includes the photos, videos, captions, prices, and other content you upload and the settings you configure. For all users, we collect information about how you interact with the Site — for example, which creators or posts you view, purchase, like, or message; support tickets you submit; and preferences you set.

f. Technical and device information. We automatically collect certain information when you use the Site, such as your IP address, browser type and settings, device and operating-system information, general/approximate location inferred from IP address, referring and exit pages, access dates and times, and interaction logs. This information helps us operate the Site, keep it secure, and prevent fraud and abuse.

g. Communications. If you contact us for support or otherwise, we collect the content of your messages and our correspondence with you.

4. Adult-Content Recordkeeping (18 U.S.C. § 2257)

Federal law requires producers of certain sexually explicit content to create and maintain records verifying that every performer was at least 18 years old at the time the content was produced. To comply, we and/or our creators collect and retain age-and-identity verification records and consent documentation for individuals depicted in content on the Site. A federal recordkeeping compliance statement and the name and location of the Custodian of Records are published separately as required by law:

Custodian of Records: [CUSTODIAN OF RECORDS NAME] [CUSTODIAN OF RECORDS ADDRESS]

[ATTORNEY: confirm the correct § 2257 / § 2257A compliance posture, the custodian designation, which content is subject to primary vs. secondary producer obligations, and the required record-retention periods; ensure this policy is consistent with the separate 2257 compliance statement.]

5. Cookies and Similar Technologies

We use a small number of cookies and similar technologies:

• `age_verified` cookie — records that you have confirmed you are of legal age and/or completed age verification, so you are not re-prompted on every visit. This cookie stores a simple flag and expiry, not your identity.
• Session / authentication cookies — keep you logged in and maintain your session as you move between pages. These are strictly necessary for the Site to function.
• Security and fraud-prevention cookies — help us detect abuse, bots, and unauthorized access.
• [Analytics/measurement cookies, if any] — [DESCRIBE ANY ANALYTICS COOKIES/SDKs USED, OR STATE "We do not use third-party advertising cookies and do not use your data for targeted advertising."]

Most browsers let you refuse or delete cookies through their settings. Because some cookies (such as session and age_verified cookies) are strictly necessary, disabling them may prevent parts of the Site from working. Where required by applicable law, we will present a cookie notice/consent tool and honor applicable browser signals (see Section 14 on Global Privacy Control).

6. How We Use Your Information

We use the information we collect to:

• create, authenticate, and manage your account;
• verify that you are of legal age before showing adult content, and enforce the age gate;
• verify the identity, age, and consent of creators and of individuals depicted in content, and maintain the records required by law and card-network rules;
• process subscriptions, All-Access passes, one-time purchases, rebilling, refunds, and chargebacks through CCBill;
• deliver, host, and stream the content you are entitled to access;
• for creators, enable you to publish content, set prices, receive payouts, and meet tax-reporting obligations;
• provide customer support and respond to your requests;
• operate, maintain, secure, and improve the Site;
• detect, investigate, and prevent fraud, abuse, unauthorized access, non-consensual or unlawful content, and violations of our Terms;
• maintain records and comply with legal, tax, card-network, and regulatory obligations (including age-verification, § 2257 recordkeeping, and reporting requirements applicable to adult content); and
• send you service-related communications (such as transaction receipts, security notices, and important account or policy updates).

We do not sell your personal information, and we do not use it for cross-context behavioral (targeted) advertising. See Section 14.

7. Legal Bases for Processing (Where Applicable)

Where a legal basis is required (for example, for users protected by non-US privacy laws), we rely on: performance of our contract with you (providing the Site and your subscription); compliance with legal obligations (such as age verification and recordkeeping); our legitimate interests (securing the Site and preventing fraud); and your consent where consent is required (for example, certain cookies or processing of sensitive data). You may withdraw consent at any time where processing is based on consent.

8. How We Share Information

We share personal information only as described below. We do not sell your personal information.

a. Service providers ("processors"). We share information with vendors that help us run the Site, under contracts that limit their use of the information to providing services to us:

| Provider | Purpose | What it receives | |---|---|---| | CCBill | Payment processing, subscriptions, rebilling, refunds, chargebacks | Payment-card and billing data you enter on CCBill's pages; transaction identifiers | | VerifyMy | Third-party age/identity verification | Identity data you submit to VerifyMy for the age check (handled on VerifyMy's systems); returns only a pass/fail result and reference to us | | Bunny.net | Content delivery network (CDN) for hosting/streaming media | Media files and technical delivery data such as IP address and request logs needed to serve content | | [PAYOUT / TAX PROVIDER, IF ANY] | Creator payouts and tax reporting | Creator identity, taxpayer, and payout information | | [HOSTING PROVIDER NAME] | Application and database hosting/infrastructure | Account, content, and transaction records stored to operate the Site | | [EMAIL/MESSAGING PROVIDER, IF ANY] | Transactional email/notifications | Email address and message content | | [ANALYTICS PROVIDER, IF ANY] | Usage measurement | [Technical/usage data as configured] |

b. Legal, safety, and mandatory reporting disclosures. We may disclose information when we believe in good faith it is required to comply with a law, regulation, subpoena, court order, or lawful government request; to enforce our Terms; to detect, prevent, or address fraud, security, or technical issues; or to protect the rights, property, or safety of Underground TV, our users, or the public. As required by law, we report apparent child sexual abuse material (CSAM) and related information to the National Center for Missing & Exploited Children (NCMEC) and/or law enforcement (18 U.S.C. § 2258A), and cooperate with resulting investigations.

c. Business transfers. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to this Privacy Policy or a successor policy.

d. With your direction. We share information when you direct us to or otherwise consent (for example, content and messages you choose to share with a creator).

Creators and subscribers interact through the Site; information you voluntarily share with a creator or other user (such as messages, tips, or requests) is shared with that person and is subject to their own handling of it, which we do not control.

9. Age Verification — Data Minimization and No Retention of ID (Subscribers/Visitors)

We take a data-minimization approach to subscriber and visitor age verification:

• Age/identity verification is performed by VerifyMy, a specialized third-party provider. The government ID, selfie, facial-estimation image, or other identity data you submit is provided to and processed by VerifyMy, not by us.
• We are designed to receive and retain only the outcome of that check — a pass/fail result, a verification reference/token, the method used, and a timestamp — so that we can demonstrate the check occurred and re-verify when required, without holding your identity documents or biometric data ourselves.
• Any biometric or facial-estimation processing used to estimate or confirm age is carried out by VerifyMy under its own privacy practices and applicable biometric-privacy laws; we do not retain biometric identifiers.
• Several US state laws that require age verification for adult sites also restrict retaining identifying information after verification. Our design — keeping only a result rather than the underlying identity data — is intended to support compliance with those minimization and non-retention requirements. [ATTORNEY: confirm the specific state age-verification statutes UGTV must comply with and that both our and VerifyMy's data handling satisfy the applicable retention/deletion rules.]

Note: this minimization approach applies to subscriber/visitor age-gating. Separate, legally mandated identity and recordkeeping obligations apply to creators and persons depicted in content (see Sections 3(b) and 4), where certain identity records must be created and retained rather than minimized.

10. Data Retention

We keep personal information only as long as necessary for the purposes described in this policy:

• Account information is retained while your account is active and for a reasonable period afterward.
• Subscriber/visitor age-verification results (pass/fail, reference, timestamp) are retained as needed to demonstrate compliance and to support re-verification, consistent with applicable law and the minimization principles in Section 9.
• Creator identity and § 2257 recordkeeping records are retained for the period required by federal recordkeeping law and card-network rules. [ATTORNEY: confirm required 2257 retention period and secure storage requirements.]
• Tax records are retained as required by applicable tax law. [ATTORNEY: confirm.]
• Transaction and billing records are retained as required by tax, accounting, anti-fraud, chargeback, and card-network rules — typically for at least [DATA RETENTION PERIOD — e.g., 5–7 years]. [ATTORNEY: confirm required retention period.]
• Technical logs are retained for a limited period for security and troubleshooting.

When information is no longer needed, we delete or de-identify it. We may retain limited information after an account is closed where required by law or to resolve disputes, prevent fraud, or enforce our agreements.

11. How We Protect Your Information

We use administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit (HTTPS/TLS), hashing of passwords, access controls, and limiting the identity data we hold in the first place (see Sections 9 and 12). No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your login credentials confidential; please notify us promptly at [PRIVACY CONTACT EMAIL] if you believe your account has been compromised. If we experience a data breach affecting your personal information, we will notify affected individuals and applicable authorities as and where required by applicable law.

12. Payment Data — We Do Not Store Your Card Numbers

Payments are processed by CCBill, a specialized adult-industry payment processor that represents itself as PCI-DSS compliant. When you pay, you enter your card or payment details on CCBill's secure hosted pages, not on our servers. Underground TV does not collect, receive, or store your full card number, CVV, or bank credentials. We receive only limited confirmation and transaction data (see Section 3(d)) needed to grant access and meet our legal, tax, and card-network obligations. Please review CCBill's privacy policy to understand how CCBill handles your payment information.

13. Your Choices and Rights

You can:

• Access and update your account information by logging in, or by contacting us.
• Request a copy of, or deletion of, your account and associated personal data by emailing [PRIVACY CONTACT EMAIL]. We will verify your identity before acting on a request. We will honor verified deletion requests, except for information we are legally required or permitted to retain (such as transaction records, tax records, and § 2257 recordkeeping records kept for legal, anti-fraud, chargeback, or recordkeeping obligations).
• Cancel your subscription at any time (this stops future rebilling; see our Terms of Service).
• Manage cookies through your browser settings (see Section 5).
• Opt out of non-essential emails using the unsubscribe link, though we may still send required service and transaction messages.

We do not discriminate against you for exercising your privacy rights.

14. US State Privacy Rights (California and Other States)

Depending on your state of residence, you may have additional rights under laws such as the California Consumer Privacy Act, as amended by the CPRA (CCPA/CPRA), and comparable laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws. Subject to those laws and applicable exceptions, you may have the right to:

• Know / access the categories and specific pieces of personal information we have collected about you;
• Delete personal information we have collected from you;
• Correct inaccurate personal information;
• Data portability — receive a copy in a portable format;
• Opt out of the "sale" or "sharing" of personal information and of targeted advertising; and
• Limit the use of sensitive personal information.

No sale; no targeted advertising. We do not sell personal information and do not "share" it for cross-context behavioral advertising as those terms are defined under California law, and we do not use your information for targeted advertising.

Sensitive information. Because this is an adult platform, information about your use of the Site (and any information related to your sex life or sexual orientation) may be considered "sensitive." We use such information only to provide the Site and services you request, to verify age, to process payments, to secure the Site, to meet legal recordkeeping obligations, and as otherwise permitted by law — not to infer characteristics for advertising.

Global Privacy Control (GPC). Where required by law, we honor recognized opt-out preference signals such as the Global Privacy Control transmitted by your browser.

How to exercise your rights. Submit a request to [PRIVACY CONTACT EMAIL]. We will verify your identity (and, for California residents, honor authorized agents acting on your behalf with proper authorization). If we deny a request, you may appeal by contacting us at the same address; where your state provides an appeal right, we will respond as required by law. California residents may also have the right to information about our data practices under the "Shine the Light" law; contact us for details. [ATTORNEY: confirm whether UGTV meets any applicable thresholds and add any state-specific "notice at collection," metrics, or Data Broker registration disclosures required.]

15. Children's Privacy

The Site is strictly for adults 18 and older and is not directed to children. We do not knowingly collect, use, or store personal information from anyone under 18 (or under the applicable age of majority). If we learn that we have collected information from a person under 18, we will delete it and terminate any associated account. If you believe a minor has provided us information, or that any content depicts a minor, contact us immediately at [PRIVACY CONTACT EMAIL]; we report apparent child sexual abuse material to NCMEC and/or law enforcement as required by law.

16. International Users and Data Transfers

The Site is operated from the United States and is intended for users in the United States. If you access the Site from outside the United States, your information will be transferred to, stored, and processed in the United States and other countries where we or our service providers operate, which may have data-protection laws different from those in your location. Where required, we implement appropriate safeguards for international transfers. By using the Site, you understand that your information will be processed in the United States. [ATTORNEY: confirm whether UGTV intends to serve, or block, users in the EEA/UK and other regulated regions, and add GDPR/UK-GDPR-specific disclosures if applicable.]

17. Third-Party Links and Content

The Site may contain links to third-party websites or services (including creators' external links, CCBill, and VerifyMy). We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing them information.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, for material changes, provide additional notice as required by law (for example, by email or an on-Site notice). Your continued use of the Site after an update takes effect constitutes acceptance of the revised policy to the extent permitted by law.

19. Contact Us

Questions, requests, or complaints about this Privacy Policy or our data practices may be directed to:

Ghetto Media Group LLC — Underground TV Attn: Privacy [OPERATOR / ENTITY MAILING ADDRESS] Email: [PRIVACY CONTACT EMAIL] Support: [SUPPORT CONTACT EMAIL]

This Privacy Policy is governed by the laws of the State of [GOVERNING-LAW STATE], without regard to its conflict-of-laws rules, except where a mandatory consumer-privacy law of your state of residence provides otherwise.

End of draft. This template is general informational drafting, not legal advice, and must be reviewed and finalized by a licensed adult-industry attorney before publication.

Placeholders to complete

• [EFFECTIVE DATE]
• [LAST UPDATED DATE]
• [OPERATOR / ENTITY MAILING ADDRESS]
• [PRIVACY CONTACT EMAIL]
• [SUPPORT CONTACT EMAIL]
• [VERIFYMY PRIVACY POLICY URL]
• [CUSTODIAN OF RECORDS NAME]
• [CUSTODIAN OF RECORDS ADDRESS]
• [PAYOUT / TAX PROVIDER, IF ANY]
• [HOSTING PROVIDER NAME]
• [EMAIL/MESSAGING PROVIDER, IF ANY]
• [ANALYTICS PROVIDER, IF ANY]
• [DESCRIBE ANY ANALYTICS COOKIES/SDKs USED, OR STATE "We do not use third-party advertising cookies and do not use your data for targeted advertising."]
• [DATA RETENTION PERIOD — e.g., 5–7 years]
• [GOVERNING-LAW STATE]

Operator notes

COMPLIANCE REVIEW RESULTS.

(3) Banner: PRESENT and verbatim at the top; kept intact. The closing "not legal advice" footer is also retained.

(1) REQUIRED elements that were MISSING or WEAK — now added:

• 18 U.S.C. § 2257 / 2257A recordkeeping and Custodian of Records: entirely absent in the original. This is mandatory for a US platform hosting user-uploaded sexually explicit content. Added new Section 4, a data-collection category (3(b)), a retention line, and [CUSTODIAN OF RECORDS NAME]/[CUSTODIAN OF RECORDS ADDRESS] placeholders. Note the 2257 compliance STATEMENT itself is normally a separate public notice — flagged for the attorney.
• Creator identity / KYC / tax data (legal name, DOB, gov ID, W-9/W-8BEN, TIN, 1099 reporting): original waved this off as "handled through our payment processor." Platform-level collection is now disclosed in 3(b), Section 6, the sharing table, and retention.
• Card-network (Visa/Mastercard specialty-merchant) requirement to verify age/identity and documented CONSENT of every person depicted in uploaded content: added to 3(b) and Section 6.
• NCMEC / 18 U.S.C. § 2258A CSAM mandatory reporting: added to sharing (8(b)) and Children's Privacy (15).

(2) OVERPROMISING / RISKY language — softened:

• "PCI-DSS-compliant adult-industry payment processor" (asserting a third party's compliance as fact) → "represents itself as PCI-DSS compliant."
• Breach clause "we will notify you and applicable authorities as required by law" → "affected individuals and applicable authorities as and where required by applicable law" (avoids promising notice beyond legal triggers).
• "We do not discriminate or degrade your service" → "We do not discriminate against you" (the CCPA statutory phrasing; "degrade" is an over-broad self-imposed promise).
• "constitutes acceptance of the revised policy" → added "to the extent permitted by law."
• Left the absolute no-sale / no-targeted-advertising statements in place (they are commitments the operator appears to intend) but attorney must confirm they remain true, especially if any analytics SDK is added.

OTHER: renumbered sections after inserting Section 4; distinguished subscriber age-gate MINIMIZATION (delete ID) from creator/performer records (must RETAIN ID) so the two obligations don't contradict. All existing [PLACEHOLDERS] preserved; new ones added for custodian and payout/tax provider. Multiple [ATTORNEY: ...] confirmation notes retained/added for state age-verification statutes, 2257 retention periods, GDPR scoping, and state privacy thresholds. Still not legal advice — requires licensed adult-industry attorney sign-off before publication.