Cyan Banister founded Zivity, a site dedicated to R-rated photos of mostly young, photogenic women, in 2007. She uploaded her own safe-for-work photos to prime the pump.

After launching the company onstage at the first TechCrunch40 conference in 2007, she garnered $8 million in investments, most of it from BlueRun Ventures and Founders Fund in March 2008.

Of course, Banister also oversaw the obligatory layoff of one-third of her staff later that year, and a restructuring of her business in which BlueRun and Founders Fund divested their stakes in favor of a more G-rated spinoff site.

Zivity’s value proposition works like this: For free, you can browse a catalog of sort-of-safe-for-work photos. For $10 a month, you can see fully nude photos of the models.

Banister herself, though, has never bared it. That seemed wise given her CEO role. Keep ’em guessing, right?

But a few weeks ago, Banister added nude photos of herself to Zivity’s premium section. Today, Banister let Los Angeles blog Sex and the 405 publicly publish photos from a nude set she shot back when she was starting Zivity.

Honestly, these photos won’t shock anyone who’s used the Internet for more than an hour. They’re less Penthouse and more Suicide Girls, cheesecake rather than porn. According to 405 blogger AV Flox, “Banister’s first shoot never made it into the site because the images didn’t meet the site’s quality guidelines.”

Somehow, Banister’s move seems smart, given her site’s mission. It doesn’t at all resemble the 1998 scandal around Crossworlds CEO Katrina Garnett, who wore a revealing black dress in a full-color, full-page ad in The New York Times Sunday Magazine. Not just because Banister is only participating in her own business model, but because in the intervening 12 years, Paris Hilton has raised the bar for scandal well past Zivity’s picture sets.