RECORDS STATEMENT

Last Updated: June 7, 2026

Applicability

All photography published by Club Winkle consists exclusively of artistic nude and editorial imagery. While some works may include nudity, none depict actual or simulated sexually explicit conduct as defined under 18 U.S.C. § 2256.

Accordingly, the record-keeping and labeling requirements of 18 U.S.C. § 2257 and 18 U.S.C. § 2257A do not apply to content on this website.

Age verification

Notwithstanding the above, Club Winkle maintains on file valid identification and signed model releases confirming that every person portrayed in content produced under our direction was at least eighteen (18) years of age at the time of production.

Club Winkle Creators

Certain content published through Club Winkle Creators is produced and published independently by participating creators who have access to publish on their own profiles, feeds, and galleries on this website. Winkle Co. Pty Ltd (Club Winkle) is not the primary producer of those visual depictions within the meaning of 18 U.S.C. § 2257.

With respect to creator-published content, Club Winkle's role as operator is limited to providing the online service and performing activities of transmission, storage, retrieval, hosting, formatting, and distribution to subscribers. Such content appears on the website as a result of publishing actions taken by the relevant creator. Each creator retains control over the content published within their Club Winkle Creators profile.

To the extent 18 U.S.C. § 2257 were ever applicable, Club Winkle relies on the exemption in 18 U.S.C. § 2257(h)(2)(B)(v) for content produced and published by third-party creators. Participating creators are required to confirm that all persons depicted are at least eighteen (18) years of age and that appropriate model releases and identification records are held, where applicable, by the creator responsible for that content.

Club Winkle may remove or restrict creator-published content that violates our Safety & Content Policy, these record-keeping standards, or our Terms & Conditions.

Records custodian

Winkle Co. Pty Ltd
Club Winkle
Suite 2259 Shop 1, 5 Flynn Street
Churchlands, WA 6018
Australia

Enquiries regarding records may be directed to [email protected].