Anti–Human Trafficking Policy

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Effective date May 8, 2026

Our Position

Luvra Inc. has a zero-tolerance policy toward human trafficking in every form, including sex trafficking, labor trafficking, and any commercial sexual activity involving a minor. Any content, account, or activity on Luvra that depicts, promotes, facilitates, or otherwise involves human trafficking is strictly prohibited. We act swiftly and without warning to remove such content, terminate the accounts involved, preserve evidence, and cooperate with law-enforcement and regulatory authorities.

Definitions

For the purposes of this policy, "human trafficking" means the recruitment, transportation, transfer, harbouring or receipt of a person, by force, threat, fraud, deception, abuse of power, abuse of vulnerability, or the giving or receiving of payments or benefits, for the purpose of exploitation. This is consistent with the United Nations Trafficking in Persons Protocol (Palermo Protocol) and the United States Trafficking Victims Protection Act. Any commercial sexual activity involving a person under the age of eighteen is treated as trafficking regardless of consent or circumstance.

Prohibited Conduct

The following are absolutely prohibited on Luvra:

  • Posting, sharing, soliciting, or advertising content that depicts or facilitates trafficking, sexual servitude, or forced labour.
  • Any sexual content involving a minor, including content that sexualises a real, fictional, or apparent minor.
  • Recruiting, grooming, or coercing any person — particularly a minor — into producing content, performing services, or travelling for any commercial sexual purpose.
  • Posting content of an adult performer where consent was not freely given, was obtained through coercion or deception, or has been withdrawn.
  • Selling, renting, transferring, or otherwise commercialising any person, including by treating a person as property.
  • Facilitating or arranging the foregoing, including by providing payment infrastructure, communication channels, or travel coordination.

Our Safeguards

We operate the following safeguards to detect and prevent trafficking on Luvra:

  • Creator identity verification. Every creator must complete government-issued ID verification, including a liveness check, before they are allowed to publish content. We confirm the creator is at least eighteen years old and that the ID corresponds to the person on camera.
  • Consent records. Each creator agrees, by separate signed acknowledgement, that the people depicted in their content have given informed, specific, and revocable consent to be depicted and to have the content distributed on Luvra.
  • Content review. All uploaded content is subject to review. We reserve the right to review any content at any time, before or after publication, and to remove content that we believe violates this policy or applicable law.
  • Monitoring and reporting tools. Members can report content or accounts they believe are involved in trafficking via the in-app report flow or by emailing report@clubluvra.com.
  • Mandatory reporting. We report suspected child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC), and other suspected trafficking activity to the relevant national authority, in line with applicable law.
  • Record retention. We preserve content, identity records, and platform logs in accordance with 18 U.S.C. § 2257 and the law-enforcement preservation requirements applicable to this category of offence.
  • Staff training. Our trust-and-safety personnel are trained on the indicators of trafficking and on the appropriate response.

How to Report

If you believe a person depicted on Luvra is being trafficked, or that an account on Luvra is being used to facilitate trafficking, please report it immediately:

  • Luvra: report@clubluvra.com — please include the URL of the content or profile and any details that can help us locate the case.
  • In the United States: National Human Trafficking Hotline at 1-888-373-7888 or text "BeFree" (233733).
  • Suspected child sexual abuse material: NCMEC CyberTipline at report.cybertip.org.
  • If a person is in immediate danger, contact local law enforcement (in the US, dial 911).

Reports can be made anonymously. We treat all reports as confidential to the extent permitted by law.

Cooperation with Law Enforcement

When we have reason to believe content or activity on Luvra involves trafficking, we preserve all relevant records, report the matter to the appropriate authority, and respond fully to lawful requests for information. We do not require law enforcement to obtain a subpoena before we will preserve evidence in a trafficking matter — we preserve on credible report.

Consequences

Accounts found to be involved in trafficking, in any role, are terminated permanently and are not eligible for reinstatement. Any payouts pending to such an account may be withheld and forwarded to the appropriate authority pursuant to applicable law and the terms of our payment processor.

Contact

For questions about this policy, write to trust@clubluvra.com. For a content report, please use report@clubluvra.com so it lands directly in our compliance queue.

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