FOSTA Compliance

Prime Time Loyalty, LLC
FOSTA COMPLIANCE POLICY
I. Policy Statement

Prime Time Loyalty, LLC (“Prime Time Loyalty” or the “Company”) is committed to compliance with the
Allow States and Victims to Fight Online Sex Trafficking Act (“FOSTA”) and other U.S. laws that may
apply. This commitment extends to promoting strict compliance on an on-going basis with Prime Time
Loyalty’s Terms and Conditions.

II. Reason for Policy/Purpose

This FOSTA Compliance Policy (this “Policy”) sets forth the Company’s policies and procedures to be
undertaken to further its compliance commitment. This document is a management system adopted to
provide overall structure and controls for complying with FOSTA.

The Company provides an online social network, the SwingLifeStyle website (the “Site”) which allows
users to connect with others who share similar interests. This social network allows users to create
profiles, contribute to forums, and engage in group messaging.
The Company will periodically review its compliance policies and procedures in the event of a material
change in the Company’s business or applicable law.

I. Allow States and Victims to Fight Online Sex Trafficking Act (FOSTA)

FOSTA amends the Communications Act of 1934 and clarifies that the Communications Act does not
prohibit the enforcement of Federal and State criminal and civil laws relating to sexual exploitation of
children or sex trafficking against providers and users of interactive computer services.

Therefore, the Company will take the measures outlined in this Policy to deter users of the Site (the
“User(s)”) from using the Site to engage in any activity that (i) promotes or facilitates prostitution, (ii)
facilitates traffickers in advertising the sale of unlawful sex acts with sex trafficking victims, or (iii) may
otherwise violate FOSTA.

III. Administration of this Policy

The Company’s Chief Compliance Officer (“CCO”) will oversee the administration of this Policy. The
CCO will establish and oversee the management of procedures to facilitate timely detection of violations
of FOSTA and coordinate the Company’s investigation of any reports of potential violations of FOSTA.

IV. Implement a Reporting System
The Company will set up an email account and identify a telephone number which the Users or any
employees of the Company can email or call to report events that the User or employee believes to be a
violation of FOSTA.

If employees have questions regarding FOSTA or reporting of FOSTA violations, he or she may contact
the CCO.

V. Audits & Investigations

The Company may audit the Site by reviewing the following: (i) the User’s profile, (ii) any of the User’s
communications made on the Site, and (iii) other content transmitted on the Site by the User (an “Audit”).

The Company may conduct an Audit for any reason, including if a User is reported per the reporting
system discussed in Section IV of this Policy. The Company may also conduct an Audit for no reason, in
its sole discretion. If the Company conducts an Audit which leads the Company to believe that any User
has violated or may have violated FOSTA, the Company may terminate or suspend the User’s account
or access to the Site.

If the Company terminates or suspends a User’s account based on the belief that the User is violating or
violated FOSTA and the Company later discovers that the User is not violating or did not violate FOSTA,
the Company may reinstate the User’s access to the Site.

The CCO shall make the ultimate decision regarding whether a violation of FOSTA is occurring or has
occurred.

VI. Reports to Law Enforcement

If the Company believes a violation of FOSTA is occurring or has occurred, it may report such violation to
law enforcement.

© 2017-2019 Prime Time Loyalty, LLC. All Rights Reserved

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