Compliance Levels and Privileges

Effective as of December 16, 2022.

Passes, Inc. (hereinafter, “our”, “we”, “us” or “Passes”) is committed to protecting the privacy and safety of all fans and creators on our platform. We take a number of steps to validate identities and ages of fans and creators on the platform, which correspond to different levels of privileges on Passes. Put simply, the more identification a fan or creator providers, the more tools and privileges they will enjoy.

Our detailed compliance levels and privileges are detailed below:

  1. Compliance Level
    • Users of Passes have different levels of access and privileges on the platform. Each user falls into one of these compliance levels:
      • Fan
      • Creator

    Compliance CriteriaFanCreator
    User agrees to Platform Terms of ServiceYesYes
    User confirms they are above the age of majority in their domicile (18+ or 21+, as applicable), but Passes has not verified the user’s government IDYesYes
    User passes KYC Government ID and selfie check (verifying user age and liveness)NoYes
    User agrees to the Creator Terms of ServiceNoYes

  2. User Privileges
    • Privileges on Passes correspond with the compliance level achieved by each user.

    User PrivilegesFanCreator
    Can send text-only Direct MessagesYesYes
    Can send Direct Messages with text and/or media (only depicting you and no other people)NoYes
    Can be identified in content upload by another CreatorNoYes
    Post and sell any type of their own content (on profile page and DMs)NoYes

  3. How do we verify identities?
    • Passes uses Persona for ID verification. Persona is an industry-learning identity verification platform that is safe for all users.
    • What is Persona?
      • When a user applies to become a Creator, they must upload government ID documentation proving their identity. This ID can be:
        • Driver License
        • State ID
        • Passport
        • Passport Card
        • Permanent Resident Card
        • Non-citizen Travel Document
        • Visa
        • Work Permit
      • Creators will then take a selfie on their device so that Persona can match your face to the provided ID. This selfie check helps Persona match faces to their provided ID and make sure that there is a real person making an account (and not a faceless bot).
      • After matching the face to the provided ID, Persona checks government databases to check for fraud. This helps Passes block criminals, sex offenders, duplicate users, and fraudsters from making accounts to harm our platform.
      • All web traffic through Persona is encrypted via HTTPS and TLS 1.2, and their database is encrypted with AES-256 encryption to ensure all users’ information remains private.