“SETTING THE STANDARDS IN AGE VERIFICATION”

Adult Entertainment Industry Specific Document

May 2019

Entry into force date 15th July 2019

Introduction
AVSecure has evolved into an innovative and formidable technology company with multiple
facets centred around privacy, security and technical innovation, including our own private
blockchain.

With approximately 25 million consumers needing to age verify due to the Digital Economy
Act, we remain aware of the importance to protect them. AVSecure holds no personal data
so it is simply not possible for us to suffer a data breach that would impact your customers.

We offer multiple verification methods including mobile, credit card, debit card, driving
license, passport, YOTI, paysafecard, YOTI facial scanning and The Age Verification Card,
available at up to 60,000 retail outlets. We provide the widest and most versatile choice for
all consumers, including the highly privacy conscious with the intention of making sure
everyone has a method that suits them.

AgePass by AVSecure has been designed to enable compliance with the Digital Economy Act
and protect both adult industry merchants and their customers with the safest and most
secure age verification system available.

Our age verification solution has applications for multiple sectors that offer age restricted
goods and services including gaming, gambling, solvents and acids, pharmaceuticals, lottery,
live streaming events, e-cigarettes and vapes, and much more.

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Integration, Testing and Launch Phase
Our developer sandbox is now available for all merchants and developers.

https://avsecure.com/developers/getting-started

Here you will find a registration area which will allow you to test the AgePass by AVSecure
Age Verification service and decide which one of the many integration methods are most
suitable. You can also review the Terms & Conditions.

This will prepare you for the full production version so that you can be confident you are
compliant for the go-live date on 15th July 2019.

In early June, we will release a “pre-launch” phase. This will help educate your visitors about
the need to age verify and provide them the choice to do so before the 15th July deadline.

There will also be a “not now” button allowing easy access to your site, if they prefer to verify
later.

On the 15th July, the “not now” button will be removed, and the full live service deployed.

We feel messaging and communicating the need to age verify is important and this period
will be most helpful.

We will remove the pre-live page and deliver the final full production AgePass wall that has it
is your responsibility to place that page live in accordance with the start date and time of the
law. A point to note is that AVSecure are not responsible for when you decide to comply.

It is worth the noting the report from MojoHost:

https://www.xbiz.com/news/241428/mojohost-integrates-avsecure-with-outstanding-
results

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The Digital Economy Act 2017
The entry into force date for the Digital Economy Act is July 15th, 2019.

Here is the Government press release:

https://www.gov.uk/government/news/age-verification-for-online-pornography-to-begin-
in-july

Under s14(1) of the Digital Economy Act 2017 (DEA), all providers of online commercial
pornographic material accessible from the UK are required to carry age-verification
arrangements for UK consumers to ensure that their content is not normally accessible to
children, and does not contain extreme pornography, as defined in the Criminal Justice and
Immigration Act 2008.

The DEA requires adults to demonstrate that they are 18 or over before accessing online
pornography. This legislation is an important step in making the internet a safer place for
children.

If an online commercial pornographic service does not comply with s14(1) of the DEA, the
BBFC, who are the UK Regulator, may use a number of enforcement powers. These include
requesting ancillary service providers to withdraw services such as advertising, asking
payment service providers to withdraw services, and requiring internet service providers and
mobile network operators to block access to the non-compliant service.

All online pornography services operating on a commercial basis, wherever they are based,
are covered by the law. The government defines what ‘commercial basis’ means in the Online
Pornography (Commercial Basis) Regulations. This includes websites which offer
pornographic content for free, but which generate revenue through advertising or through
'premium' content which must be paid for.

To make sure that you comply with the requirements of s14(1) of the DEA, please refer to
the BBFC website: https://www.ageverificationregulator.com/

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BBFC Guidelines on Content
What content can your website display in front of age- verification controls?

This explains what type of content may be displayed on online commercial pornographic
services before a user has age-verified.

The BBFC will investigate pornographic websites to ensure that they carry effective age-
verification controls and do not carry extreme pornographic material, the possession of which
is illegal in the UK. The BBFC will report to Parliament on the effectiveness of age-verification.

The BBFC recognises that pornographic services may wish to display some content to
consumers before they have age-verified in order to demonstrate the nature of their service.
It is acceptable to display non-pornographic content to consumers before they age-verify.
This document provides some guidance on what that content may or may not look like.

The following sets out the type of content that is unacceptable to show before age-
verification has taken place on an online commercial pornographic service.

Before a user has age-verified, the following content, both still images and video, is not
permitted:

• detailed depictions of sexual activity (for example penetration, masturbation, oral

sex)
• full frontal nudity or exposure of the breasts or genitals
• fetish themes which involve violence or aggression
• sexual poses that draw attention to breasts, genitals and/or buttocks whether
exposed or not, (for example a person bending over and/or spreading their legs)

Before a user has age-verified, the following is permitted:

• Non-sexual posing in swimwear of underwear

• Non-sexual nude posing where breasts, genitals and/or buttocks are hidden by the
positioning of the pose or masked by other graphics.
• Images where nudity or sexual activity is fully masked by heavy pixilation or blurring.

The BBFC will take account of these factors when determining whether an online commercial
pornographic service is compliant with section 14(1) of the Digital Economy Act 2017.

More information can be found at the Age Verification regulators website.

https://www.ageverificationregulator.com/

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BBFC Voluntary Accreditation Scheme
AVSecure have applied and will be completing this
voluntary accreditation scheme to provide
additional comfort to merchants and consumers.

You can read the Standard for the scheme here:

https://www.ageverificationregulator.com/assets/bbfc-age-verification-certificate-
standard-april-2019.pdf

The scheme appears to have VERY strict rules.

It seems it will be heavily promoted to consumers to provide them with comfort that any AV
provider who attains accreditation has met stringent standards regarding data handling and
privacy.

Consumers will likely be advised against using any systems or methods where the
prominent green AV accreditation “kite mark” symbol is not displayed.

The guidance is focused on ensuring the purity of age verification and we draw to your
attention to the following important clauses:

• Only the MINIMUM amount of personal data required to verify a user’s age shall be
collected.
• A user’s IDENTITY SHALL NOT be verified as part of the process.
• Information about the requesting website that the user has visited SHALL NOT BE
COLLECTED AGAINST THE USER’S ACTIVITY.
• Age-verification providers shall ONLY SHARE the result of an age-verification
check (PASS OR FAIL) with the requesting website.
• Personal data relating to the PHYSICAL LOCATION OF A USER SHALL NOT BE
COLLECTED as part of the age-verification process.
• Personal data used for fraud prevention and detection and to verify a user’s age for
access to commercial online pornographic material SHALL NOT BE USED FOR ANY
OTHER PURPOSES, SUCH AS MARKETING OR THE CREATION OF DIGITAL WALLETS.
AGE-VERIFICATION PROVIDERS SHALL NOT MARKET OTHER SERVICES TO THESE
USERS DURING OR AFTER THE AGE- VERIFICATION PROCESS.
• A user shall be given the OPTION TO VERIFY THEIR AGE WITHOUT BEING REQUIRED
TO SET UP AN ACCOUNT with the age-verification provider.

The intent seems clear. AV providers should not aim to do anything with a user other than
to age verify them. Methods or systems that attempt otherwise will likely not attain
accreditation from the BBFC. Please see this advisory notice from the BBFC:

http://www.bbfc.co.uk/about-bbfc/media-centre/regulator-advises-age-verification-
providers-about-use-digital-wallets

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AVSecure was built from conception along these lines. We retain zero consumer data like
email (which we don’t even collect) or IP address and never market to users.

Our FREE verification system can solve any issues you may have relating to being able to
offer a trusted, accredited product.

The Age Verification Guidance does not preclude your business from carrying out separate
and distinct data capture, or membership processes, but this should be done AFTER and
SEPARATE from the age verification process itself.

Our recommendation is, and has always been that, for those merchants looking to use this
opportunity to “sign-up” new members etc, the best way to do it is immediately AFTER a
quick, smooth, successful, certified, simple, non-intrusive AV check has been made and do it
as a separate, optional, flow on process.

Thereby, if any customer abandons the merchant sign up process no traffic is lost.

It appears that some solutions or methods may have intended to try to effectively disguise a
sign-up scheme by collecting billing details proffered by the user as part of the AV method,
or to force consumers into a localized platform or marketing product.

AgePass by AVSecure
Built on our own private blockchain, the code you install on your site will automatically detect
a UK IP address and display a regulatory acceptable landing page with the AgePass iframe.
The consumer is offered multiple options for verifying their age and can choose from mobile,
credit card, debit card and address check, passport, Yoti, the Age Verification Card from retail
stores or online and the exclusive Paysafecard.

Once a user is verified, AgePass will generate a unique 12 digital Access key (similar to the
technology used by Apple and the US Government) which is combined with a simple 4-digt
PIN created by the user.

With the Access Key and PIN, the user can easily enable up to 5 devices in their control.

The user also has the unique ability to set the access controls for each device independently.
For example, if it was a private mobile, the user may elect to opt for straight through browsing
which means they would access any site using AgePass exactly as they would now without
any age wall.

If it was a shared device, for example a desktop or tablet that may be accessed by younger
members of the family OR for deniability, the user can set access so the age wall will appear,
asking that user to verify their age OR enter their chosen 4-digit PIN.

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We know from experience and research that this flexibility and control is important for
consumers.

Using the AgePass app, the user is able to manage their devices with greater flexibility. If the
user is privacy conscious and does not wish to install the APP, has an inability to do so or
prefers not to have a “tell” on their device, they can access and manage their settings directly
at avsecure.com/settings by entering their PIN.

Due to the combination of our zero-knowledge proof technology and our private blockchain,
we are unable to know who a user is and retain no data on anyone. A blockchain authorised
component installed in the user’s browser issues a new code upon each browsing instance
and therefore we are not able to track an individual’s surfing habits.

Lastly, as we do not collect an email from your customer, there is no centralised database
that may be at risk of hacking.

AgePass APP

Available from both Google Play and Apple’s App Store, the AgePass app
offers consumers additional controls and flexibility for managing their
AgePass credential. It is easy to use, free to download and has several clever
functions that enable swift verification on mobile and driving license. Once
verified, if a user wishes to delete the APP, they can.

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AVSecure Private Blockchain
The AVSecure Platform uses our innovative and private blockchain, with the associated
security that comes with its cryptographic processes.

Consumers are offered a selection of age-authentication checks via trusted third- parties who
then validate them. The AVSecure software creates an anonymous AgePass for each cleared
individual which generates one-time use tokens when consumers visit websites in the future.
These tokens are passed to the website providers and ensure that the consumers leave no
traceable information where verification doesn’t need to be linked to identity.

Central to the AVSecure Platform is a customized version of the JPM Quorum Blockchain; an
Ethereum-based chain with added privacy features, capable of processing thousands of
attestations per second.

For anonymous verification methods our core concept delineates 'creating trusted
statements about a known person' and 'the use of those statements'. This mean that the user
will go through a one-time initial validation process to produce their AgePass. Once the user
has this, they can use this trusted age-credential without having to re-validate and so its use
will only be known to them.

We currently have several blockchain nodes running on AWS and in Florida on AVSecure
servers and in the Netherlands on MojoHost Servers. If you have an interest in running your
own blockchain node, please contact us.

Home Page options

The AgePass iframe allows you to design your home page in accordance with the BBFC
guidelines OR chose our regulatory acceptable landing page that takes over the whole page.
For mobile, due to the limited screen size, the age wall takes up the whole area.

Incognito Browsing
We are able to provide all incognito users the ability to access sites using their 4-digit PIN
only. This is a significant benefit over many other solutions as they will likely reply on the need
for an email and password to be entered.

The consumer journey and ease of use was paramount to the technology team at AVSecure
and we know of no other solution that is safer, easier to use or has the levels of flexibility that
we offer.

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Age Verification Card
https://www.ageverificationcard.com/

The Age Verification Card is the ultimate way to

prove you are over 18 at online sites. Simply
purchase a card and the unique 16-digit number it
carries can be used to validate your age with
participating online partners.

It can be used to access age restricted sites like

online gaming, gambling, e-cigs, vapes, alcohol,
sunbed bookings, pharmaceuticals, lottery and much more, without sharing information
about your identity.

You can buy the Age Verification Card e-Voucher over-the-counter at up to 60,000 ePay and
Paypoint stores across the UK, including major supermarket chains.

It allows face-to-face age verification to be completed at the point of sale. If you appear to be
over 18, no additional proof is required.

If the retailer is unsure you are over 18 they may request to see an official photo ID, such as
driving licence or passport, but no record of the documents will be retained. The Age
Verification card is unique to AVSecure and AgePass

paysafecard
paysafecard is a market leader in online prepaid payment methods and AgePass by AVSecure
has a global exclusive agreement to use the 18+ paysafecard as proof of age. It can be bought
at any of the 27,000 outlets in the UK and used to verify age at AgePass without revealing
anything about your identity. A truly anonymous method and unique to AgePass.

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Data & Privacy
We love to take every opportunity to remind merchants and consumers alike that we retain
no data. It was always a critical part of our design that we collected no email from YOUR
customers and in the event that AVSecure got hacked (which we have to assume it will), the
consumer will ALWAYS get
unfettered access to your site due
to our safety features.

In the unlikely event the blockchain

got hacked, it would reveal nothing
that would ever link random
numbers to an individual.

We have even removed Google

Analytics from our websites to
prevent any tracking and in
consequence, our privacy policy reflects this.

Industry Partners
We are proud of our partnerships with industry leading firms which offer clients of theirs
added benefits. These being MojoHost, CCBill, Segpay, Cybersocket, YOTI, Paysafe and many
more.

We offer 8 different verification methods, including the YOTI products which include facial
recognition and their full YOTI App.

MojoHost, as one of the industry’s leading hosting companies, offers a ticket system for
anyone that requires help or assistance in the installation of AgePass by AVSecure. They have
fully tested the system with outstanding results and will be recommending AVSecure to their
clients.

https://www.xbiz.com/news/241428/mojohost-integrates-avsecure-with-outstanding-
results

Surveys
Having completed two surveys with YouGov 12 months apart, we asked the UK consumer
numerous questions and have a full understanding of what matters.

We know what methods of verification they prefer, how worried they are about giving up
even an email address, their fear of having data leaked or hacked and their preference in
using an independent third party.

This has been invaluable, as it reinforces our approach and underpins the very high standards
we have set.

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Terms & Conditions
We engaged the services of Lawrence Walters, Walters Law Group, as our US counsel and his
firm prepared the Terms and Conditions for Merchants.

We do not have any onerous terms, no fees, no cancellation terms and seek to retain your
business by doing our job as we say we will. All documents will be available from our
developer section.

Security
AVSecure's security model applies the principle of 'least privilege' in the internet environment
to make sure that all participants in the age verification process only have access to the
information and resources necessary to perform their specific function. To achieve this, we
have implemented a 'Zero Knowledge' trust network where consumers can interact safely
and independently with other parties on the network. As there is no knowledge maintained
at a network level there is no personal information outside the consumers control which
means no possibility for us to track and leak information to third parties.

We take the security and stability of our system very seriously and have full time security
reviews by multiple parties, both in house and external, across all our properties.

AVSecure in the press and Media

We have an extensive and targeted PR campaign on several social media channels and the
mainstream UK press. This is all designed to help educate consumers on the Digital Economy
Act and promote the compliance of the adult industry and of course, AVSecure and our
products.

You can read more about us here:

https://avsecure.com/press
We also author many blogs which you can read here:
https://avsecure.com/blog

Finally, we hope you choose AVSecure. We are proud of our company and our achievements
and will be by your side when other countries also adopt age verification. Remember it is
FREE to use AgePass by AVSecure and is the safest solution available for both you and your
valuable customers.

We really do appreciate your business and the trust you place in us.

Thank you.

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Contact Details
Technical support
support@avsecure.com

General questions
info@avsecure.com

Stephen Winyard- CMO

saw@avsecure.com

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