The clock starts when a valid request arrives: a signature, enough to find the image, a good-faith statement that it was shared without consent, and a way to reach the person. From then, 48 hours to take it down and look for identical copies. Sandglass never holds the image itself - only where it was and when it came down.
What the FTC would ask to see: when each request came in, when the image came down, the copies found and removed, and when the requester was told.