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, including:
  • 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.
• Good Faith Determination: Make a good-faith determination regarding the validity of the request and the nature of the content.

4.3. Removal of Content

• 48-Hour Takedown: Upon determining that a request is valid and the content constitutes NCIVD, the content will be removed or disabled within 48 hours.
• Reasonable Efforts to Identify and Remove Copies: Reasonable efforts will be made to remove identical copies, including technological tools such as hash matching.
• Notification of Removal: The complainant will be notified once content has been removed or disabled.

4.4. Exceptions and Good Faith Disclosures

This policy does not require removal of NCIVD disclosed in good faith, including:

• To law enforcement.
• In legal proceedings.
• For legitimate medical, scientific, or educational purposes.
• To seek support regarding unsolicited intimate imagery.
• Where an individual publishes their own lawful content.
• Other exceptions specified by the TAKE IT DOWN Act.

4.5. Protection from Liability

Reflected Networks shall not be held liable for any claim based on good-faith disabling or removal of material claimed to be NCIVD based on apparent unlawful publication.

5. Enforcement and Compliance

Failure to comply with TAKE IT DOWN Act requirements may constitute an unfair or deceptive act under the FTC Act. If a customer fails to comply with this Policy, Reflected Networks reserves the right to take corrective actions.

6. User Education and Transparency

• Communicate this Policy through its website.
• Provide accessible reporting information.
• Regularly review and update this Policy.

7. Data Retention

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