Identity Verification and Consent Procedures

Hayati AI — Hayati Labs Limited

Document Type: Compliance and Operational Procedures Operator: Hayati Labs Limited Website: https://hayati.ai Contact: info@hayati.ai

Purpose and Scope

These Identity Verification and Consent Procedures (“Procedures”) describe the measures adopted by Hayati AI (“Hayati,” “we,” “us,” or “our”) to address user eligibility, age assurance, identity-related risks, consent, fictional AI-generated characters, and the prevention of unauthorized or exploitative content.

Hayati is an artificial intelligence companion platform operated by Hayati Labs Limited, a company registered in the State of New York, United States, with an office at 2004 Brockwell Ave, Monterey Park, CA 91754, United States.

These Procedures are intended to support compliance reviews by payment processors, acquiring banks, and other authorized compliance stakeholders.

They should be read together with Hayati's User Registration Policy, Terms and Conditions, Privacy Policy, Content Monitoring & Prohibited Content Policy, Anti-Human Trafficking & Sexual Exploitation Policy, and reporting and complaints procedures.

These Procedures distinguish between measures currently implemented and additional controls that may be introduced where legally or contractually required. They do not represent that Hayati currently conducts identity-document verification for every user.

Nature of the Platform

2.1 AI-Generated Companions

Hayati provides interactive experiences involving fictional, AI-generated companion characters.

Characters are presented as synthetic digital personas rather than real individuals offering personal companionship or live performer services.

The platform may provide text conversations and supported AI-generated media features, including images and, where available, audio or video.

2.2 No Real-Person Performer Model

Hayati does not operate as a marketplace connecting users with real-person adult performers, escorts, or individuals offering live sexual services.

Its fictional AI companions are not presented as actual human performers.

Accordingly, traditional performer identity verification and performer release procedures do not automatically apply to fictional characters that have no underlying human performer.

This distinction does not eliminate Hayati's obligations to prevent the misuse of real individuals' identities, likenesses, or personal information.

2.3 User-Submitted Material

Under the current product model, users provide text-based inputs and are not offered a general-purpose facility for uploading photographs, videos, or audio recordings for adult-content publication.

If the platform introduces user media uploads, real-person content, or performer participation, Hayati will reassess the applicable verification, consent, recordkeeping, and content-review requirements before enabling those features.

User Eligibility and Age Assurance

3.1 Adults Only

Hayati is restricted to individuals aged 18 or older, or the applicable legal age of majority where higher.

Minors are prohibited from accessing, registering for, or using the Services.

Parental or guardian consent does not override this restriction.

3.2 Current Age Confirmation Mechanism

Hayati currently uses an age confirmation prompt at the website entry point.

Visitors must affirm that they satisfy the applicable minimum age requirement before proceeding.

This process is based on user self-declaration.

Hayati does not currently perform routine government-issued identity-document verification or third-party identity-based age verification for all users.

A self-declaration is an age confirmation measure, not independent proof of age or identity.

3.3 Additional Verification Requirements

Where applicable law, an acquiring bank, a payment processor, or a relevant risk assessment requires stronger age assurance, Hayati may introduce proportionate measures such as:

Verification through an authorized third-party age assurance provider;
Government-issued identification checks, where lawful and necessary;
Additional eligibility verification for higher-risk accounts or transactions;
Access restrictions pending satisfactory verification;
Geographic restrictions where applicable legal requirements cannot be met.

Any such measures must be implemented in accordance with applicable privacy and data protection requirements.

Hayati will not treat self-declaration as sufficient in a jurisdiction where legally mandated age verification requires a stronger method.

3.4 Suspected Underage Users

Where credible information indicates that a user may be below the required age, Hayati may restrict access, suspend the account, request appropriate verification, investigate the report, or terminate the account.

Any relevant information will be handled under the Privacy Policy and applicable law.

Identity Verification Procedures

4.1 Ordinary User Registration

Users register through the authentication methods supported by the platform.

Registration and authentication information may include an email address, account identifiers, and associated technical or security records.

Account authentication establishes control of the relevant login credentials; it does not, by itself, establish a user's legal identity or independently verify their age.

4.2 Risk-Based Verification

Additional verification may be considered where there is a reasonable indication of:

Underage access;
Identity impersonation;
Account takeover;
Fraudulent or unauthorized transactions;
Repeated circumvention of platform restrictions;
Use of an identifiable real person's likeness without authorization;
Other conduct requiring investigation under applicable law or payment partner requirements.

Verification measures should be proportionate to the risk, legally permitted, and limited to information reasonably necessary for the relevant purpose.

4.3 Handling Identity Documents

Hayati does not routinely collect government identity documents from all users.

If identity documentation becomes necessary, Hayati will establish an appropriate collection, access, security, retention, and deletion process before requesting it.

Where practical, specialized third-party verification providers may be used to minimize Hayati's direct handling of sensitive identification documents.

4.4 Verification Outcomes

Where additional verification is required, access may remain restricted until the relevant requirement is satisfied.

A failure or refusal to complete a legally or contractually required verification process may result in denial of access or account suspension, subject to applicable law.

Consent to Use the Services

5.1 Age and Eligibility Declaration

By completing the age confirmation process, users declare that they satisfy the applicable minimum age requirement and are legally permitted to access the Services in their jurisdiction.

5.2 Acceptance of Contractual Terms

Users must comply with Hayati's Terms and Conditions and applicable platform policies.

Where the law requires an affirmative acceptance mechanism, Hayati must obtain the necessary acceptance through the applicable registration or service interface.

5.3 Privacy and Data Processing

Personal data is processed in accordance with the Privacy Policy and applicable law.

Acceptance of contractual terms does not automatically constitute valid consent for every form of personal data processing.

Separate consent must be obtained where required, including for certain optional cookies, marketing communications, or other processing activities that legally require consent.

5.4 Consent Is Not Permission for Prohibited Content

A user's agreement to access adult-oriented AI entertainment does not authorize the generation, distribution, or facilitation of unlawful, exploitative, or non-consensual content.

Consent to the platform's terms cannot override the rights of third parties or applicable law.

Consent and Fictional AI Characters

6.1 Synthetic Character Status

Hayati's companion characters are designed and presented as fictional AI-generated personas.

A fictional AI persona is not a human performer capable of providing legal consent, signing a model release, or undergoing government identity verification.

Accordingly, performer consent documentation is not applicable merely because an adult fictional AI character appears in a synthetic image or interaction.

6.2 Adult Character Representation

Hayati prohibits sexualized representations of minors, including fictional or AI-generated persons represented as minors.

Adult-oriented character experiences must not depict or imply that a participant is underage.

6.3 Real-Person Identity and Likeness

Hayati prohibits the unauthorized use of identifiable real individuals' identities or likenesses to create sexual content, including non-consensual intimate imagery and sexual deepfakes.

Where a complaint alleges unauthorized use of a real person's identity or likeness, Hayati may restrict the relevant content, investigate available information, and request appropriate evidence of authorization where necessary.

The absence of a real performer in Hayati's standard character model does not excuse misuse of real-person likenesses.

6.4 Changes to the Content Model

Before introducing real performers, user-uploaded adult media, or content based on identifiable real individuals, Hayati must assess whether additional controls are required, including:

Government identity and age verification;
Documented, specific, informed consent;
Performer or model releases;
Consent withdrawal and content removal procedures;
Applicable recordkeeping obligations, including 18 U.S.C. § 2257 where relevant;
Enhanced content moderation and payment partner approval.

Such features must not be treated as covered automatically by these existing Procedures.

Prohibited Content and Consent Violations

Hayati prohibits use of the Services to request, generate, distribute, or facilitate:

Child sexual abuse material (CSAM) or other unlawful sexual content involving minors;
Sexualized representations of persons presented as minors;
Non-consensual intimate imagery;
Unauthorized sexual deepfakes involving identifiable real people;
Human trafficking, sexual exploitation, coercion, or abuse;
Sexual violence or other content prohibited by applicable law or platform policies;
Impersonation or identity misuse intended to facilitate exploitation;
Attempts to circumvent safety or consent-related controls.

Suspected violations may result in content restriction, account suspension, investigation, termination, and lawful escalation.

Content Monitoring and Review

Hayati uses AI-based content moderation mechanisms to assess user inputs and platform-generated outputs for prohibited or high-risk content.

Depending on the nature of the concern, potential violations may be addressed through automated restrictions, additional review, account enforcement, or escalation.

Automated systems may produce errors and cannot guarantee detection of every violation.

Where a serious incident requires human assessment, Hayati should arrange authorized human review appropriate to the nature and urgency of the case.

Detailed moderation standards are addressed in the Content Monitoring & Prohibited Content Policy and related procedures.

Reporting and Consent-Related Complaints

Users, affected individuals, and third parties may report:

Suspected underage access;
Impersonation or identity misuse;
Unauthorized use of a real person's likeness;
Non-consensual sexual content;
Suspected CSAM or sexual exploitation;
Fraudulent accounts or related safety concerns.

Reports may be submitted to info@hayati.ai.

Reports should include sufficient information to identify the concern, such as the relevant account, character, content description, approximate date, and supporting information where available.

Complainants should not be required to distribute or resubmit unlawful sexual imagery merely to make a report.

Reports will be assessed under Hayati's Report Policy and Complaints, Content Removal & Appeals Policy.

Investigation and Escalation

Where a report or internal detection indicates a potential identity, age, or consent violation, the appropriate response may include:

Recording the concern and identifying the affected account or content;
Assessing the nature, credibility, and urgency of the allegation;
Restricting access to potentially harmful material where warranted;
Reviewing relevant information through authorized personnel or systems;
Requesting additional verification or clarification where lawful and necessary;
Taking proportionate account or content enforcement action;
Preserving relevant evidence where legally required or permitted;
Referring the matter to competent authorities when required by law or otherwise lawfully appropriate.

Suspected CSAM, child exploitation, trafficking, or imminent threats must be treated as high-priority safety matters and handled under the relevant specialized procedures.

Hayati will not conduct independent criminal investigations or make determinations reserved to competent law enforcement authorities.

Recordkeeping and Data Protection

Hayati may maintain records reasonably necessary to support account administration, security, compliance, complaints, and enforcement.

Depending on the relevant systems and incident, these may include:

Account and authentication records;
Age confirmation or verification-related information;
Relevant consent or terms acceptance records, where captured;
Moderation decisions and safety flags;
Reports, complaints, and investigation outcomes;
Relevant enforcement and escalation records.

This section describes categories of records that may be maintained; it does not assert that every listed record is currently collected or retained in a dedicated audit system.

Access must be limited to authorized purposes and personnel, and retention must follow the Privacy Policy and applicable legal requirements.

Sensitive identity information should not be collected or retained beyond what is reasonably necessary.

Third-Party Service Providers

Hayati may rely on third-party providers for authentication, hosting, AI processing, payments, fraud prevention, and, if introduced, identity or age verification.

Where such providers process personal information, Hayati will address applicable contractual, confidentiality, security, and data protection requirements.

The use of a third-party provider does not remove Hayati's responsibility to assess whether the relevant controls are appropriate for its Services.

Governance and Periodic Review

Hayati Labs Limited is responsible for maintaining these Procedures and reviewing them when material changes occur.

Relevant review triggers include:

Changes in age verification laws;
New acquiring bank or payment processor requirements;
Introduction of user media uploads or real-person content;
Significant changes to authentication or AI content generation;
Serious safety or consent-related incidents;
Changes to applicable privacy or recordkeeping obligations.

Operational implementation should be checked against these Procedures before they are represented as fully implemented to payment partners or regulators.

Limitations and Jurisdictional Compliance

Hayati recognizes that adult-oriented digital services may be subject to different requirements across jurisdictions.

Where a jurisdiction requires identity-based age verification, performer documentation, or other controls not currently available, Hayati must implement compliant measures or restrict the relevant service.

Nothing in these Procedures overrides mandatory legal requirements or applicable payment partner obligations.

Contact Information

Hayati Labs Limited Registered in the State of New York, United States Office: 2004 Brockwell Ave, Monterey Park, CA 91754, United States

Email: info@hayati.ai Website: https://hayati.ai

Document status: Compliance procedures for payment processor and acquiring bank review.

حياتي AI — Hayati Labs Limited

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Identity Verification (ID&V) and Consent Procedures