Age Verification Policy

Effective 31 August 2026

Nightcloud Interactive LLC (“Nightcloud,” “we,” “us,” or “our”) operates KinkzAI as an adults-only AI companion and roleplay service.

This Age Verification Policy explains the age requirements for KinkzAI, the age-verification and age-assurance measures that may apply to users, how third-party verification is used, and what may happen if a user cannot be verified or attempts to circumvent an age-verification requirement.

This Policy should be read together with our Terms of Service, Privacy Policy, Content and Acceptable Use Policy, Content Moderation Policy, Complaints and Appeals Policy, Anti-Human Trafficking and Exploitation Policy, and AI Companion Safety Protocol.

Capitalized terms not defined in this Policy have the meanings given to them in our Terms of Service.

1. Adults Only

KinkzAI is exclusively for adults.

You must not access or use the Service unless:

• you are at least 18 years old;
• you have reached the age of majority where you are located;
• you have reached any higher minimum legal age that applies to accessing adult-oriented material or the Service where you are located; and
• you may lawfully access the Service and adult-oriented material where you are located.

If an applicable minimum age is greater than 18, the higher age requirement applies.

Parental or guardian consent does not permit a person who is below the applicable minimum age to access or use KinkzAI.

2. When Age Verification Is Required

Access to the Hosted Service requires successful age verification.

Nightcloud may also require age verification or age assurance before permitting you to:

• create or use an account;
• access particular characters, features, or adult-oriented functionality;
• download or use the Desktop App; or
• access another portion of the Service.

The point at which verification is required may depend on the portion of the Service being accessed, your location, applicable law, technical implementation, or other relevant circumstances.

Where applicable law requires age verification or age assurance before access to a particular portion of the Service, Nightcloud will require the applicable verification before providing that access.

Successful completion of age verification does not guarantee access to every feature or establish that use of the Service is lawful in every jurisdiction.

3. Third-Party Age-Verification Provider

Nightcloud uses a third-party age-verification provider to perform age verification.

The verification provider may require information directly from you to determine whether you satisfy the applicable age requirement. The information and verification steps required may depend on the verification method, your location, applicable law, and other circumstances. Depending on the verification method made available to you, the verification provider or one of its verification partners may use facial age estimation, identity-document verification, payment-based verification, email-based age estimation, or another age-verification or age-assurance method.

The verification provider performs the applicable verification process and provides Nightcloud with a limited verification result and related information.

Nightcloud relies on the verification result supplied by the provider and generally does not possess the underlying source information necessary to independently reproduce the provider’s verification determination.

Information you submit directly to the verification provider is subject to the provider’s privacy practices and to applicable law.

Nightcloud does not receive copies of identification documents submitted directly to the age-verification provider as part of the ordinary verification process.

4. Information Nightcloud Receives

Nightcloud receives limited information associated with the result of the age-verification process rather than copies of identification documents or other source identity information submitted directly to the verification provider.

Depending on the verification process, Nightcloud may receive:

• a provider-issued user or verification identifier;
• a verification or eligibility result;
• the expiration date or validity period associated with the verification;
• country;
• state, province, territory, or other subdivision;
• the assurance level associated with the verification; and
• limited technical or transaction-reference information associated with the verification result that does not include copies of identification documents or other source identity information used by the provider to perform the verification and that Nightcloud may lawfully retain.

Nightcloud does not use the age-verification process as a means to obtain copies of identification documents from users.

Our Privacy Policy explains how Nightcloud processes information associated with age verification.

5. Verification Methods May Differ

Age-verification and age-assurance requirements are not necessarily the same for every user.

The verification method, assurance level, frequency, and information required may differ based on:

• your country, state, province, territory, or other location;
• the portion of the Service you seek to access;
• applicable legal or regulatory requirements;
• requirements imposed by a payment processor, card network, service provider, or other third party necessary to provide the Service;
• available age-verification methods and technology;
• fraud, account-security, or circumvention concerns; or
• other circumstances reasonably relevant to determining whether you satisfy the applicable age requirement.

Nightcloud may change or supplement its age-verification measures when reasonably necessary to comply with applicable law, maintain access to payment or other necessary services, protect minors from accessing the Service, or respond to changes in available verification technology.

Where applicable law requires a particular level of effectiveness, including highly effective age assurance or a comparable standard, Nightcloud will apply age-assurance measures designed to satisfy the applicable requirement.

The use of a particular verification method does not represent that the method is legally required or legally sufficient for every user or jurisdiction.

6. Reverification and Additional Checks

Successful age verification may not permanently satisfy all future verification requirements.

Nightcloud may require reverification or an additional age-assurance check, including when:

• a prior verification expires;
• applicable law or regulatory requirements change;
• a different level or method of verification applies to your location or a feature you seek to access;
• information associated with an account raises a reasonable concern about the user’s age or eligibility;
• Nightcloud reasonably suspects that an age-verification process has been circumvented or manipulated;
• Nightcloud reasonably suspects that another person’s verification information or account is being used;
• a payment processor, card network, or necessary service provider requires additional verification; or
• another reasonable legal, safety, fraud-prevention, or compliance reason requires reverification.

Nightcloud may restrict access to all or part of the Service while required reverification is pending.

7. Failed, Incomplete, or Unavailable Verification

If you do not successfully complete a required age-verification or age-assurance process, Nightcloud may deny or restrict access to the applicable portion of the Service.

Nightcloud does not guarantee that every person who satisfies the applicable age requirement will be able to complete every available verification method successfully.

If a verification attempt fails because of an error or other issue, you may be permitted to retry the process, use another verification method where available, or contact us for assistance.

Because the verification process is performed by a third-party provider, Nightcloud may be unable to override a verification determination when Nightcloud does not possess the underlying information necessary to independently verify your eligibility.

If an accessibility issue prevents you from completing an available verification method, you may contact us at admin@kinkzai.com. Where reasonably available and legally permissible, Nightcloud may provide or facilitate access to an alternative verification method that satisfies the applicable age-assurance requirement.

Complaints concerning age verification are handled in accordance with our Complaints and Appeals Policy.

8. Suspected Underage Users

If Nightcloud receives information reasonably indicating that a user may not satisfy the applicable minimum-age requirement, Nightcloud may restrict or suspend access while the matter is reviewed.

Nightcloud may require the user to complete or repeat age verification before restoring access.

If Nightcloud determines that a user does not satisfy the applicable minimum-age requirement, Nightcloud will promptly restrict or terminate that user’s access to the Service.

Nightcloud will delete or de-identify age-verification information to the extent and within the period required by applicable law, subject to any applicable preservation obligation or legal requirement.

Other account, transaction, complaint, fraud-prevention, safety, or legal-compliance information that was not collected solely to verify age may be retained where permitted or required by applicable law and as described in our Privacy Policy.

If Nightcloud obtains information concerning apparent child sexual abuse material (“CSAM”), child sexual exploitation, or other conduct that applicable law requires Nightcloud to report, Nightcloud will make the required report and comply with applicable preservation obligations.

9. Circumvention Is Prohibited

You must complete required age-verification processes truthfully.

You must not:

• misrepresent your age, identity, or location;
• use another person’s identification, verification result, account, or credentials;
• provide false, altered, stolen, or misleading information to Nightcloud or an age-verification provider;
• allow another person to use your successful verification to obtain access to the Service;
• use a VPN, proxy, location-spoofing technology, or another method for the purpose of evading an age-verification or jurisdiction-specific age-assurance requirement;
• manipulate, interfere with, disable, or defeat an age-verification or age-assurance measure;
• create or use another account to evade a failed verification, restriction, suspension, or termination; or
• otherwise attempt to circumvent an age or eligibility requirement.

Nightcloud does not represent that it can identify or prevent every attempt to conceal a user’s location or circumvent an age-verification requirement.

Attempted circumvention may result in denial of access, feature restriction, account suspension, account termination, reverification, or other enforcement action permitted by the Terms of Service and applicable law.

10. Age Verification Does Not Replace Content Controls

Successful age verification establishes only that the applicable age-verification process has been satisfied.

It does not permit content or conduct prohibited by the Content and Acceptable Use Policy.

In particular, successful verification does not permit:

• content involving or sexualizing minors;
• child sexual exploitation or CSAM;
• trafficking or sexual exploitation;
• nonconsensual sexual content;
• nonconsensual intimate imagery or sexual deepfakes; or
• other content or conduct prohibited by KinkzAI’s policies.

KinkzAI’s content and safety restrictions apply to all users regardless of age-verification status.

11. Geographic Differences and Availability

KinkzAI may apply different age-verification or age-assurance requirements in different jurisdictions.

Nightcloud may restrict or discontinue access to the Service or particular features in a country, state, province, territory, or other jurisdiction where:

• Nightcloud cannot reasonably implement an age-verification or age-assurance method necessary to satisfy applicable requirements;
• the available verification provider does not support the jurisdiction or an applicable verification method;
• applicable law restricts or prohibits the Service;
• a regulator or governmental authority imposes an applicable requirement;
• a payment processor, card network, or necessary service provider restricts service in the jurisdiction; or
• Nightcloud otherwise determines that continued availability presents a material legal or compliance risk.

Availability of KinkzAI in a particular location does not represent that every user in that location may lawfully access the Service.

Users must not attempt to circumvent a geographic restriction applied by Nightcloud.

12. Privacy and Retention of Age-Verification Information

Nightcloud seeks to minimize the age-verification information that it receives and retains.

As part of the ordinary age-verification process, Nightcloud does not receive or store copies of identification documents or other source identity information that a user submits directly to the third-party verification provider for purposes of completing the provider’s verification process.

Nightcloud retains only the limited verification-result information described in Section 4 and only to the extent permitted by applicable law and reasonably necessary to administer the verification result, determine continuing eligibility, prevent fraud and circumvention, document compliance, resolve disputes, or satisfy other applicable legal requirements.

Where applicable law prohibits retention of identifying information used to verify age after verification is complete, Nightcloud will not retain that information beyond the period permitted by law. If such information comes into Nightcloud’s possession outside the ordinary verification process, Nightcloud will handle and delete or de-identify it as required by applicable law, subject to any applicable preservation obligation or legal hold.

Nightcloud may retain nonidentifying verification records or limited verification-result information where permitted or required by applicable law to demonstrate that an age-verification or age-assurance check occurred.

The third-party verification provider separately processes information submitted to it in accordance with applicable law, its privacy practices, and its contractual obligations.

Our Privacy Policy contains additional information concerning age-verification data, service providers, retention, disclosures, international transfers, and applicable privacy rights.

13. Complaints and Questions

Questions or complaints concerning KinkzAI’s age-verification process may be submitted to:

admin@kinkzai.com

Complaints are handled in accordance with our Complaints and Appeals Policy.

If your concern relates to information collected or a determination made directly by the third-party age-verification provider, Nightcloud may direct you to that provider or coordinate with the provider as appropriate.

Nothing in this Policy limits any privacy, consumer-protection, accessibility, age-assurance, or other right that applicable law does not permit Nightcloud to limit.

14. Changes to This Policy

Nightcloud may modify this Policy from time to time to address changes in the Service, applicable law, age-verification technology, regulatory requirements, card-network or payment-processor requirements, or our age-assurance practices.

Material changes will apply prospectively and will be communicated as required by applicable law.

The date at the top of this Policy identifies when it was last updated.

15. Contact Information

KinkzAI is operated by:

Nightcloud Interactive LLC
5205 Harvest Run Way
Myrtle Beach, South Carolina 29579
United States

Email: admin@kinkzai.com