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LUMIARDI
International Media Regulation

Records Custody Statement — 18 U.S.C. § 2257

Record-Keeping Requirements & Compliance Statement

1. Records Custody Statement

In strict compliance with Title 18 of the United States Code, Section 2257 (18 U.S.C. § 2257) and the Code of Federal Regulations, 28 C.F.R. Part 75, LUMIARDI GESTÃO DE CONTEÚDO LTDA. declares that all models, creators and participants in audiovisual or photographic content displayed or managed on the platform were at least 18 (eighteen) years of age on the date of the respective production or registration.

2. Location and Custody of Physical and Digital Records

Original documentary records, certified copies of government-issued photo identification and biometric date-of-birth records are kept in secure custody by Lumiardi’s Official Custodian of Records.

Designated Custodian: Lumiardi Compliance & Legal Affairs Department

Contact Address: Av. Brigadeiro Faria Lima, São Paulo - SP, Brasil

Email for Official Notices: compliance@lumiardi.com

3. Exemption and Secondary Media

For material produced by third parties or accredited agencies where Lumiardi acts merely as a secure hosting intermediary (Safe Harbor), the primary production records remain in the legal custody of the original producer or the contracting agency.