Legal
Last updated: 31 August 2026
Every character, portrait, image and video on this service is generated by machine-learning models. No content is photographed, filmed or recorded from a real person. This is not a styling choice; it is the core design of the product.
Because no real person is depicted, there are no performers, models or depicted persons whose identity or age records could be kept or produced. There is no person behind any character on Flirtly.
18 U.S.C. § 2257 imposes record-keeping and labelling obligations on producers of visual depictions of actual human beings engaged in sexually explicit conduct. Flirtly produces no depictions of actual human beings: all media is machine-generated from synthetic sources, no photography of any person occurs, and no user may upload an image of any person. On that basis, the § 2257 record-keeping duty does not attach to this service, because there is no performer for whom records could be kept.
There is no upload surface in the product. No code path exists from any user-supplied image to any generation capability, and we have no roadmap item to add one. Character creation is descriptive: you describe a companion in words and choose from generated results. This is enforced in software, not by a rule that could be ignored.
All characters are fictional synthetic adults. No character is derived from a real person and none is intended to resemble one. We do not claim coincidental resemblance is impossible — a generative model can produce a face that reminds someone of someone — so the commitment we make is the one we can keep: we refuse prompts that target real people — by name, or by phrasing like “looks like” — and we remove content reported to depict a real person under the Removal Policy.
For every canonical portrait and every published asset we keep a provenance log: model, prompt, negative prompt, seed, timestamp, generation task id, and the safety-classifier verdicts. The log is kept for the life of the asset and is available to regulators and processors on request. If the legal position on wholly synthetic imagery is ever tested, this is the evidence that exists.
This statement relies on two facts being permanently true: no real-person likeness enters the generation pipeline, and no user upload exists. If either changed, the § 2257 analysis would change with it — and this page would be updated before any such content shipped.
All characters and media on Flirtly are AI-generated, and the service labels them as such. For users in the European Union, this disclosure also serves our transparency obligations under Article 50 of the EU AI Act.
Questions about this statement go to legal@flirtly.co. No custodian of records is named here, and that is deliberate: section 3 sets out why the § 2257 record-keeping duty does not attach to a service with no performer, and designating a custodian would assert the opposite.