18 U.S.C. § 2257 Compliance Statement

Effective: May 23, 2026

1. Statement of Compliance

All models, actors, actresses, performers and other persons who appear in any visual depiction of actual or simulated sexually explicit conduct appearing on or otherwise contained in the Zavrah platform were over the age of eighteen (18) years at the time of the creation of such depictions.

2. User-Generated Content Exemption

Zavrah is an interactive computer service and online platform that allows users to create, upload, share and exchange content. Visual content depicting sexually explicit conduct that is hosted on Zavrah is created and uploaded by independent third-party users (the "Content Producers"). Zavrah itself does not produce, create, or commission any such content.

Pursuant to 18 U.S.C. § 2257(h)(2)(B)(v) and the implementing regulations set forth at 28 C.F.R. § 75.1(c)(4), Zavrah qualifies as a service that solely transmits and stores user-generated content. Accordingly, the original record-keeping obligations under § 2257 and § 2257A rest with the Content Producers — the individual users who created and uploaded the material — and not with Zavrah.

3. Records Held by Content Producers

As a condition of uploading sexually explicit visual content to Zavrah, every Content Producer is required to:

  • Verify that every individual depicted in the content was at least eighteen (18) years of age at the time the content was produced.
  • Maintain, in compliance with 18 U.S.C. § 2257 and 28 C.F.R. § 75, the records required to establish the age and identity of each performer.
  • Provide the legal name and current address at which such records are maintained, available upon lawful request.
  • Indemnify Zavrah against any claim arising from a failure to maintain those records.

Inquiries regarding the records for specific user-generated content should be directed to the Content Producer who uploaded that content.

4. Custodian of Records — Platform-Operated Content

For any content that Zavrah itself directly produces (which is currently none), the designated Custodian of Records is:

Zavrah — Custodian of Records

Email: records@zavrah.com

Physical mailing address available upon written request to the above email.

5. Reporting Underage Content

Zavrah has a zero-tolerance policy toward content depicting minors. If you believe any content on the platform may depict an individual under the age of 18, please report it immediately to trust@zavrah.com with the URL and any supporting information. All reports are reviewed urgently and forwarded to the National Center for Missing & Exploited Children (NCMEC) where required by law.

6. Related Pages