Compliance
Compliance overview
Written for payment providers, platform partners and legal counsel. Where something is undecided, it says so.
Current status. The service has not launched and takes no payments today. A company is being incorporated. Pricing and payment methods are undecided — this page describes the intended design so that it can be reviewed before it is built.
01
Service definition
- What it is
- A conversational service with a fictional adult AI character, for adult users. Session-based text roleplay, in Japanese, for the Japanese-speaking market.
- What it is not
- It is not a service that connects users with real people. There is no video call, no live performer, no camming, no user-to-user contact and no marketplace.
- Characters
- All characters are fictional and are depicted as adults. There is one curated character; users cannot create or upload their own.
- On-screen depiction
- Character artwork contains no nudity and no depiction of sexual acts. The conversation is adult in nature; the imagery is not.
02
Content policy
Enforcement is in two layers: an input filter that runs before the model is called, and an output filter that runs on the generated text before it reaches the user.
The following are refused. This list is a product constraint, not a moderation target we hope to reach:
- Minors, or any character or scenario suggesting a minor
- Real, identifiable people
- Content that presents non-consent as desirable
- Incest
- Bestiality
- Sexual violence, serious physical harm, or content encouraging self-harm
- Prostitution, trafficking, or the arrangement of real-world meetings
- Illegal drugs and weapons
03
Age assurance
- Access
- The service is for adults aged 18 and over, and is restricted to access from within Japan. The site carries an R-18 notice and RTA labelling.
- Method
- Self-declaration at entry, plus card payment for all paid use — a payment method minors do not hold. We do not distribute images of undressed persons: character artwork is clothed only, and the conversation itself is text. On that basis the service does not fall under the Japanese statutory category that requires document-based age proof.
- Jurisdiction
- Geo-restriction to Japan is deliberate. It keeps the service out of jurisdictions whose law requires document-based age assurance — the UK, France, Germany, Italy and a number of US states — rather than serving them without the controls their law expects.
- Persons depicted
- No real person is depicted. The character is generated, and the system prompt states explicitly that both the character and the user are adults, with expressions that frame the user as young or underage prohibited by rule. Every response passes an automated filter before it reaches the screen, and turn-level logs are retained.
- Free trial
- The free 10 turns sit behind the same self-declaration. Paid use is gated by card payment.
04
Data handling
A permanent policy, not a current limitation: user photos and video are never sent to our servers. Audio is handled differently, and we state that separately rather than blurring the two.
- Zero upload (photos, video)
- No upload path is implemented. The camera feature planned for the face-to-face plan analyses posture inside the browser, so there is no network path to us at all.
- Audio: no third party
- Speech recognition does not run on the device. We run our own self-hosted Whisper, so audio reaches our servers but never passes through Apple, Google, OpenAI or any other speech service. Audio itself is not stored — it is discarded as soon as it has been transcribed — and the transcript is kept only for the duration of the session.
- Verifiable
- The content security policy restricts connect-src to our own API domain, so a reviewer can confirm from the browser’s network log that nothing reaches a third party rather than taking our word for it.
- Conversation data
- Retention rules are being decided with counsel and will be published in the privacy policy before launch.
05
Payments
Please read this section before quoting: the card-on-file requirement is the part most likely to affect a decision.
- Model
- Pay-per-use only. No subscription, no recurring billing, no auto-renewal. Basic mode is billed per turn; face-to-face mode is billed per 15-minute session.
- Card-on-file
- Extending a session is a one-tap additional purchase, which requires storing the payment credential and charging it again without re-entry. This is user-initiated each time, but it is card-on-file and we understand it is reviewed separately from one-off payments for adult merchants.
- If card-on-file is declined
- We would rather know early. The extension flow for the voice and face-to-face plans is built on it, and we would redesign that flow rather than misrepresent it.
- Currency and market
- JPY, Japanese-speaking customers.
- Refunds
- Digital content, delivered immediately; refunds are not generally offered once a purchase completes. The treatment of undelivered service time will be set out in the terms.
06
Distribution and territory
- Distribution
- Progressive Web App only. We do not distribute through the Apple App Store or Google Play, and we are not seeking to.
- Acquisition
- Organic reach on X (Twitter) in Japan is the primary channel. No affiliate network.
- Territory
- Japanese-language service. Access from some jurisdictions will be restricted; the block list will be finalised with counsel before launch.
Questions, or a request for the full documentation pack: business@amaikey.com