Rodsy, LLC
FOSTA Compliance Policy
I. Policy Statement
Rodsy, LLC (“Rodsy” or the “Company”) is dedicated to full compliance with the Allow States and Victims to Fight Online Sex Trafficking Act (“FOSTA”) and all other pertinent U.S. laws. This commitment encompasses ongoing adherence to Rodsy’s Terms and Conditions.
II. Purpose of Policy
This FOSTA Compliance Policy (“Policy”) delineates the Company’s protocols and measures to ensure compliance. This document serves as a comprehensive management system designed to provide a structured framework and controls necessary for adhering to FOSTA.
Rodsy operates the SwingLifeStyle website (“Site”), an online social network enabling users to connect with others of similar interests. The Site permits users to create profiles, engage in forums, and participate in group messaging.
The Company will periodically reassess its compliance protocols in response to significant changes in business operations or applicable laws.
III. Overview of FOSTA
FOSTA amends the Communications Act of 1934, affirming that the Act does not impede the enforcement of federal and state laws against sexual exploitation of children or sex trafficking by providers and users of interactive computer services.
Consequently, the Company will implement the measures detailed in this Policy to prevent users of the Site (“User(s)”) from engaging in activities that: (i) promote or facilitate prostitution, (ii) assist traffickers in advertising unlawful sex acts involving sex trafficking victims, or (iii) otherwise violate FOSTA.
IV. Reporting Mechanisms
The Company will establish a dedicated email account and telephone number for Users and employees to report any suspected FOSTA violations.
Employees with questions regarding FOSTA or the reporting of violations should contact the CCO.
V. Audits and Investigations
The Company reserves the right to audit the Site, which includes reviewing: (i) User profiles, (ii) User communications on the Site, and (iii) any other content transmitted by Users (an “Audit”).
Audits may be conducted for any reason, including but not limited to reports received through the established reporting system, or at the Company’s sole discretion. If an Audit suggests a User has violated or may be violating FOSTA, the Company may terminate or suspend the User’s account or access to the Site.
Should a subsequent review reveal that the User did not violate FOSTA, the Company may reinstate the User’s access.
The CCO will have the final authority in determining the occurrence of a FOSTA violation.
VI. Reporting to Law Enforcement
In the event the Company believes a FOSTA violation is occurring or has occurred, it may report the suspected violation to law enforcement authorities.
VII. Administration of the Policy
The Company’s Chief Compliance Officer (“CCO”) is tasked with administering this Policy. The CCO will develop and manage procedures to ensure prompt detection of FOSTA violations and will oversee the investigation of any reported potential violations.
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