01Purpose and Scope

This DSA Statement has been prepared, under the European Union's (EU) Digital Services Act No. 2022/2065 (DSA), for the websites and applications operated by Zynvora Tech LLC (hereinafter the "Company") (affiliated brands including fanzu.live primarily, and broadza.live and lovtube; collectively, the "Platform"). The purpose of the Statement is to set out transparently the Platform's obligations under the DSA as an intermediary service provider, the rights and obligations of users, the mechanisms applied against illegal content, and its transparency commitments.

This Statement is primarily addressed to recipients of the service (users, broadcasters, representatives, and visitors) located within the EU and the European Economic Area (EEA). Since the Platform provides a hosting and online platform service in which users can create content, message, make video calls, and participate in live broadcasts, it is regarded as an intermediary service and hosting service provider within the meaning of the DSA.

This Statement should be read as a whole together with the Platform's other contractual and informative texts. The processing of personal data is explained in detail in the "Privacy Policy" document, user conduct rules in the "Community Guidelines" document, and general service terms in the "Terms of Use" document. In the event of a conflict, on matters relating to the DSA this Statement is complementary and explanatory in nature.

• Scope: DSA compliance disclosures for recipients of the service in the EU/EEA.
• Nature: The Platform is an intermediary service and hosting service provider within the meaning of the DSA.
• Integrity: Read together with the "Privacy Policy", "Community Guidelines", and "Terms of Use".

02Service Provider Information

The Platform is operated by Zynvora Tech LLC, a limited liability company established in the State of Delaware, United States of America (USA), and subject to the laws of that state. The Company is the operator of all services offered through fanzu.live and its affiliated brands (broadza.live, lovtube).

Official and legal correspondence relating to the Company is conducted primarily by electronic mail. legal@fanzu.live may be used for legal notices and contact under the DSA, destek@fanzu.live for general support requests, privacy@fanzu.live for data protection and privacy requests, and dmca@fanzu.live for copyright and DMCA notices. Where communication by postal mail is required, [Company mailing address] is taken as the address for service.

The Platform is intended only for the use of persons aged 18 and over. Explicit sexual content, pornography, and obscene broadcasting are strictly prohibited on the Platform; although the Platform is a service requiring adult verification, it is not a pornographic platform.

• Operator: Zynvora Tech LLC (Delaware, USA).
• Brands: fanzu.live, broadza.live, lovtube.
• Legal/DSA contact: legal@fanzu.live.
• General support: destek@fanzu.live; Data requests: privacy@fanzu.live; Copyright/DMCA: dmca@fanzu.live.
• Mailing address: [Company mailing address].

03EU Point of Contact and Language of Communication

As required by the DSA, the Company has designated a single point of contact so that recipients of the service in the EU, the authorities of Member States, and the European Commission can communicate directly, electronically, and rapidly with the Platform. This point of contact can be reached via the electronic mail address legal@fanzu.live.

The point of contact is used for official correspondence under the DSA, illegal content notifications, competent authority requests, and regulatory communications. The Company undertakes to address valid notices reaching it within a reasonable time and, where necessary, to forward them to the relevant units.

The languages accepted for communication with the point of contact are English and Turkish. In official correspondence with competent authorities, cases in which the processing language of the relevant authority may be taken into account are reserved. Users are encouraged to submit their notices as clearly and completely as possible for the sake of clarity and prompt processing.

• Single point of contact: legal@fanzu.live.
• Field of use: illegal content notifications, competent authority requests, regulatory communication.
• Languages of communication: English and Turkish.

04Illegal Content Notification (Notice & Action)

In accordance with the "notice and action" principle envisaged by the DSA, the Platform provides a mechanism through which any person or organization can notify, easily, accessibly, and by electronic means, content on the Platform that they consider to be illegal. Notices may be made through the complaint and reporting tools within the Platform or to legal@fanzu.live.

For a notice to be processed effectively, the notifying person is expected to justify with sufficient clarity why the relevant content is considered illegal, to specify the exact and precise location of the content (for example, a link, username, broadcast, or message description), to provide their name and contact (email) information, and to make a statement that the notice is submitted in good faith and based on accurate information.

The Company reviews the notices reaching it in a timely, diligent, impartial, and non-arbitrary manner. If, as a result of the review, it is determined that the content is indeed illegal or breaches the Platform rules, proportionate measures may be applied, such as removal of the content, restriction of access, reduction of the content's visibility, warning of the relevant account, suspension, or banning. If the notifying person has provided contact information, they are informed of the decision taken regarding their notice and the available appeal avenues.

When content requiring urgent intervention, threatening persons' safety of life, or giving rise to suspicion of a serious crime is detected on the Platform, the Company may inform the competent authorities in accordance with applicable law.

• Notification channels: in-Platform complaint tools and legal@fanzu.live.
• Expected in a valid notice: justification of illegality, the exact location of the content, the notifier's name and email, a statement of good faith.
• Example complaint subjects: fake profile, fraudulent/commercial use, suspicion of a minor, hate speech.
• Possible measures: removal of content, restriction of access, reduction of visibility, warning/suspension/banning of the account.

05Content Moderation and Statement of Reasons

The Company oversees the content shared and the user conduct on the Platform through both user notices and administrator review and technical tools. Moderation measures include measures such as removal of content, restriction of access or visibility, intervention in rule breaches in private messages and broadcast chats, blocking a user, banning from broadcasting, and suspending an account.

As required by the DSA, when a restriction such as content removal, restriction of access, reduction of visibility, or suspension or termination of an account is applied in respect of a recipient of the service, the Company aims to provide the affected recipient with a clear and comprehensible statement of reasons. This statement includes the type and scope of the measure applied, the factual and legal basis on which the measure relies, information as to whether the decision was made by automated means or by human review, and the available appeal avenues, if any.

Moderation decisions are made, observing the balance between freedom of expression and other fundamental rights, in accordance with the principle of proportionality and in a non-arbitrary manner. The Company may additionally assess manifestly unfounded or abusive notices and repeat violations.

• Moderation tools: user notices, administrator review, blocking users, banning from broadcasting, suspending accounts.
• Content of the statement of reasons: the type and scope of the measure, the factual and legal basis, whether the decision relies on automated/human review, appeal avenues.
• Principle: proportionality, impartiality, and respect for fundamental rights.

06Internal Complaint and Appeal System

Recipients of the service against whom a moderation measure has been applied, and persons whose notices have been processed, may benefit from a free and accessible internal complaint mechanism through which they can appeal against the decision. Appeals may be submitted to legal@fanzu.live or to the appeal channels provided within the Platform.

An appeal must be made within a reasonable time from the notification of the decision. Appeals are assessed by adequately qualified staff, in an impartial manner, and not solely on the basis of automated tools. If, as a result of the review, it is determined that the initial decision was erroneous or disproportionate, the Company reverses, corrects, or updates the relevant measure.

The outcome of the appeal is notified to the applicant together with its reasons. Use of the internal complaint mechanism does not eliminate the user's right to resort to the out-of-court dispute resolution avenues explained below or to judicial recourse.

• Application channel: legal@fanzu.live and in-Platform appeal tools.
• Nature: free, impartial review not based solely on automated tools.
• Possible outcome: upholding, reversing, correcting, or updating the measure.
• The appeal does not prevent other legal recourse avenues.

07Out-of-Court Dispute Resolution

Recipients of the service in the EU/EEA who are dissatisfied with the outcome of the internal complaint and appeal mechanism have the right, under the DSA, to apply to an out-of-court dispute resolution body certified in the relevant Member State. This application may be used for the resolution of disputes arising from content moderation decisions.

The decision of a certified dispute resolution body may be binding within the framework envisaged by the DSA; however, these bodies are not a court and do not eliminate the parties' right to resort to judicial recourse. The Company participates in good faith in dispute resolution processes initiated before a certified body.

The fees and procedure relating to out-of-court dispute resolution are subject to the rules of the relevant body and the provisions of the DSA. Use of this avenue does not affect the consumer rights and other legal recourse possibilities in the user's country.

• Right of application: application to an out-of-court dispute resolution body certified in the relevant Member State.
• Scope: disputes arising from content moderation decisions.
• This avenue does not eliminate the right to resort to the judiciary.

08Statement of Average Monthly Active Recipients of the Service

The DSA requires online platforms to periodically make public the average number of monthly active recipients of the service in the EU. This number is important for determining the very large online platform (VLOP) threshold and the scope of the relevant obligations.

As of the date of this Statement, the average number of monthly active recipients of the service of the Platform in the EU is declared as [average number of monthly active recipients]. This figure is updated periodically in accordance with the calculation principles envisaged by the DSA and is published within this Statement or on the relevant pages of the Platform.

The number in question is an estimated value reflecting the active recipients in the EU and may vary depending on the measurement method and the period. Where the applicable thresholds are exceeded, the Company takes the necessary measures to comply with the additional obligations under the DSA.

• Declared value: average number of monthly active recipients of the service in the EU [average number of monthly active recipients].
• Purpose: determining the VLOP threshold and the scope of obligations.
• Update: periodic update in accordance with the DSA calculation principles.

09Cooperation with Competent Authorities

Under the DSA, the Company responds, in accordance with applicable law, to the duly issued requests of competent national authorities (including Digital Services Coordinators), judicial bodies, and the European Commission. These requests may seek action against specific illegal content or the provision of information regarding a specific recipient of the service.

The Company fulfills only requests that have a legal basis, are duly issued, and are drafted with sufficient clarity. The authority issuing the request and, where applicable, the affected recipient of the service are informed of the action taken to the extent permitted by applicable law. The scope of the request is assessed, observing the principles of proportionality and respect for fundamental rights.

The point of contact legal@fanzu.live is used for official correspondence relating to cooperation with competent authorities. In requests relating to the processing of personal data, the Company acts in accordance with the principles explained in the "Privacy Policy" document and the relevant data protection legislation.

• Counterparts: Digital Services Coordinators, judicial bodies, the European Commission.
• Condition: requests that have a legal basis, are duly issued, and are sufficiently clear.
• Contact: legal@fanzu.live.
• Principle: proportionality, respect for fundamental rights, and compliance with data protection legislation.

10EU Legal Representative

Intermediary service providers not established in the EU but providing services to recipients of the service in the EU are required, under the DSA, to appoint a legal representative authorized in writing in one of the EU Member States. This legal representative may be addressed by competent authorities, the Commission, and recipients of the service on matters of DSA compliance.

Information regarding the Platform's EU legal representative under the DSA is stated as [EU legal representative information]. As the identity, address, and contact information of the legal representative are updated, they are published within this Statement and on the relevant pages of the Platform.

The appointment of a legal representative does not eliminate the Company's responsibility under the DSA; the Company and the legal representative may be jointly addressed for the fulfillment of the relevant obligations. Valid notices made to the legal representative are deemed to have been made to the Company.

• Requirement: appointment of a legal representative authorized in the EU for a provider not established in the EU.
• Information: [EU legal representative information].
• Effect: the appointment of the representative does not remove the Company's responsibility; a valid notice made to the representative is deemed made to the Company.

11Transparency Reporting

As required by the DSA, the Company undertakes to publish periodic transparency reports on its content moderation activities. These reports aim to set out, in a comprehensible manner, the scope and results of the moderation processes carried out on the Platform.

Transparency reports may include headings such as the number and types of illegal content notices and competent authority requests received, the responses given to them and the average processing times, the moderation activities carried out on the Company's own initiative, the types of measures applied, the appeals made to the internal complaint mechanism and their outcomes, and information regarding the use of automated tools.

The information contained in the reports is presented while observing the obligations relating to the protection of personal data and the confidentiality of ongoing investigations. Transparency reports are made accessible on the relevant pages of the Platform or through this Statement.

• Content: number of notices and authority requests, responses given, and processing times.
• Content: own-initiative moderation, measures applied, appeals and their outcomes, use of automated tools.
• Constraint: respect for personal data protection and the confidentiality of investigations.

12Updates

This DSA Statement may be updated from time to time in line with changes in legislation, developments in the Platform's services and processes, or the guidance of competent authorities. The current text, together with its effective date, is published on the Platform.

In the event of significant changes, the Company may inform recipients of the service through the communication channels it deems appropriate. Continuing to use the Platform after the publication of updates means that the informative nature of the current Statement is accepted.

For questions and notices regarding this Statement, you may contact legal@fanzu.live. This Statement is a complementary document explaining the rights and obligations under the DSA for recipients of the service in the EU/EEA, without prejudice to the general contractual framework subject to the laws of the State of Delaware, USA. The last update date of this Statement is August 22, 2026.

• Reasons for update: legislative changes, service/process developments, authority guidance.
• Information: significant changes may be announced through appropriate channels.
• Contact: legal@fanzu.live.
• Last update: August 22, 2026.