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NCIVD Notice and Takedown Policy

Reflected Networks Policy for Notice and Takedown of Nonconsensual Intimate Visual Depictions (NCIVD) in Compliance with the TAKE IT DOWN Act

Effective Date: January 23, 2026

1. Purpose

This policy (the “Policy”) outlines Reflected Networks’ procedures for receiving, processing, and responding to requests for the removal of Nonconsensual Intimate Visual Depictions (NCIVD), including digital forgeries (deepfakes), in compliance with the Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks Act (the “TAKE IT DOWN Act”). While Reflected Networks, as a hosting service provider is not a “Covered Platform” under the TAKE IT DOWN Act, Reflected Networks is committed to protecting individuals from the harmful publication of such content while upholding principles of lawful speech, and will pass along relevant requests to any Reflected Networks customer which is a “Covered Platform” according to the terms set forth herein.

2. Scope

This policy applies to all user-generated content (if any) hosted, published, curated, or made available by customers of Reflected Networks through customer platforms hosted by Reflected Networks – which platforms fall under the definition of a “covered platform” as per the TAKE IT DOWN Act. This includes, but is not limited to, images, videos, and other visual media. This Policy does not apply to customers of Reflected Networks that do not provide a forum for user-generated content

3. Definitions

  • Nonconsensual Intimate Visual Depiction (NCIVD): As defined by the TAKE IT DOWN Act, an intimate visual depiction of an identifiable individual that is published without the individual's consent, or, in the case of an authentic depiction, was created or obtained under circumstances where the individual had a reasonable expectation of privacy. This includes digital forgeries (deepfakes) that, when viewed, as a whole, by a reasonable person, are indistinguishable from an authentic visual depiction of the individual.
  • Identifiable Individual: An individual who appears in whole or in part in an intimate visual depiction and whose face, likeness, or other distinguishing characteristic (including a unique birthmark or other recognizable feature) is displayed in connection with such intimate visual depiction.

  • Covered Platform: A website, online service, online application, or mobile application that serves the public and either primarily provides a forum for user-generated content or for which it is in the regular course of trade or business to publish, curate, host, or make available NCIVD.
  • Complainant/Requestor: The identifiable individual depicted in the NCIVD, or their authorized legal representative, who is submitting a removal request.

4. Notice and Removal Process

Removal requests relating to NCIVD should be directed to: legal@reflected.net. Reflected Networks will forward requests to any relevant customer which is a Covered Platform.

4.1. Submission of a Removal Request (Notice)

To be considered valid, a removal request must be submitted in writing through the legal@reflected.net email address and must include all of the following information:

  • Physical or Electronic Signature: A physical or electronic signature of the identifiable individual making the request, or their authorized legal representative.
  • Identification of NCIVD: Sufficient information to identify and locate the specific NCIVD on our customer’s platform. This should include:
    • Direct URL(s) to the content.
    • Screenshots of the content (if available).
    • Usernames of the poster(s).
    • Date and time the content was shared.
    • Any other information reasonably sufficient for Reflected Networks to locate the content.
  • Statement of Good Faith: A statement, under penalty of perjury, that the requestor has a good-faith belief that the intimate visual depiction was published on our customer’s platform without the consent of the identifiable individual depicted therein.
  • Contact Information: Information reasonably sufficient to permit Reflected Networks to contact the complainant, including:
    • Full legal name.
    • Mailing address.
    • Email address.
    • Telephone number.
  • Confirmation of Identity (for NCIVD of Requestor): If the requestor is the identifiable individual depicted in the NCIVD, they may be required to provide reasonable proof of identity to verify their claim. This may include a government-issued ID (with sensitive information redacted) or other secure verification methods. This information will be used solely for verification purposes and will not be stored longer than necessary.
  • Representation (if applicable): If the request is submitted by an authorized legal representative, the request must include documentation demonstrating their legal authority to act on behalf of the identifiable individual.

4.2. Review and Verification of Request

Upon receipt of a removal request, Reflected Networks will forward the request to the relevant Reflected Networks customer. The Reflected Networks customer will be expected to:

  • Acknowledge Receipt: Send an automated or manual acknowledgment of receipt to the complainant.
  • Review for Validity: Promptly review the request to ensure it meets all the requirements outlined in Section 4.1.
  • Assess Content: Evaluate the reported content against the definition of NCIVD as per the TAKE IT DOWN Act. This includes assessing whether the depiction is intimate, whether the individual is identifiable, and whether there is a reasonable claim of nonconsensual publication. For digital forgeries, Reflected Networks’ customer will assess if, when viewed as a whole by a reasonable person, it is indistinguishable from an authentic visual depiction of the individual.
  • Good Faith Determination: Reflected Networks’ customer will make a good-faith determination regarding the validity of the request and the nature of the content.

4.3. Removal of Content

The Reflected Networks customer will be expected to:

  • 48-Hour Takedown: Upon determining that a request is valid and the content constitutes NCIVD under the TAKE IT DOWN Act, Reflected Networks’ customer will remove or disable access to the content as soon as possible, and in no case later than 48 hours after receiving the valid request.
  • Reasonable Efforts to Identify and Remove Copies: Reflected Networks’ customer will make reasonable efforts to identify and remove any known identical copies of the removed NCIVD on its platform. This may involve using technological tools (e.g., hash matching) to prevent re-uploads of the same content.
  • Notification of Removal: Reflected Networks’ customer will notify the complainant once the content has been removed or access disabled.

4.4. Exceptions and Good Faith Disclosures

This policy does not require the removal of NCIVD that is disclosed in good faith:

  • To a law enforcement officer or agency.
  • As part of a document production or filing associated with a legal proceeding.
  • As part of medical education, diagnosis, or treatment or for a legitimate medical, scientific, or educational purpose.
  • To seek support or help with respect to the receipt of an unsolicited intimate visual depiction.
  • Reasonably intended to assist the identifiable individual.
  • Where the person possesses or publishes an intimate visual depiction of himself or herself engaged in lawful sexual conduct.
  • Other exceptions as specified by the TAKE IT DOWN Act.

4.5. Protection from Liability

Reflected Networks shall not be held liable for any claim based on its or its customers’ good-faith disabling of access to, or removal of, material claimed to be a nonconsensual intimate visual depiction based on facts or circumstances from which the unlawful publishing of the intimate visual depiction is apparent.

5. Enforcement and Compliance

Failure to comply with the notice and takedown requirements of the TAKE IT DOWN Act may constitute an unfair or deceptive act or practice under Section 18(a)(1)(B) of the Federal Trade Commission Act (FTC Act), enforceable by the Federal Trade Commission (FTC). In the event that Reflected Networks’ customer fails to act in accordance with this Policy, Reflected Networks reserves the right to take actions including, without limitation, those set forth in Clauses 4.2 and 4.3.

6. User Education and Transparency

Reflected Networks will:

  • Clearly communicate this Policy to its customers through a link on its website.
  • Provide readily accessible information on how users can report NCIVD (through this policy).
  • Regularly review and update this policy to ensure ongoing compliance with the TAKE IT DOWN Act and evolving best practices.

7. Data Retention

Information related to removal requests and removed content will be retained only as long as necessary for compliance with legal obligations and internal record-keeping, consistent with Reflected Networks’ privacy policy.


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