Important FTC Compliance Information for HostCentric Affiliates. | View in browser. |
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Dear Jack,
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As a reminder, the HostCentric Affiliate Agreement
requires you to disclose your affiliate relationship with HostCentric whenever you offer an endorsement or testimonial of HostCentric's services, including, in the form of publishing online rankings or reviews comparing service providers. Under the Federal Trade Commission (FTC) Guides Concerning the Use of Endorsements and Testimonials in Advertising ("Endorsement Guidelines"), and as updated in 2015, you are required to disclose any material connections. The FTC is especially concerned about any financial incentives that would be of interest to a consumer reading your endorsement or testimonial (including reviews and rankings).
If you are publishing reviews or rankings comparing brands, the consumer needs to understand the factors which weigh or drive the order of rankings or the substance of reviews. If, for example, commission or conversion rate are significantly determining the positioning or endorsement of a brand, then you must communicate this.
If you are making comparisons among brands on the basis of price or features, you are solely responsible for the accuracy of this content, and also for making sound and fair (“apples to apples”) comparisons among the various brands you are reviewing or endorsing.
View the FTC Endorsement Requirement in the Affiliate Agreement
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WHAT IT MEANS FOR YOU
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If you provide reviews, rankings, endorsements, testimonials, blogs or content of any kind about any HostCentric’s service for which you receive commissions, you must clearly disclose the fact that you receive such compensation in a clear and prominent place in close proximity to your endorsement. This disclosure must appear on every page that includes your endorsement and cannot require the consumer to scroll through multiple page-views, or click on secondary links behind vague words such as “Disclaimer”.
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The FTC takes the Endorsement Guidelines seriously and continues to bring enforcement actions against a wide range of companies, including marketers, advertisers, affiliates, PR agencies, web influencers and others.
HostCentric has an obligation to monitor our affiliate program and we take this obligation very seriously. HostCentric monitors affiliate sites to ensure that our services are represented appropriately and that they comply with the Endorsement Guidelines. As stated in our Affiliate Agreement, failure to comply with the Endorsement guidelines could result in your removal from the HostCentric affiliate program as well as the cancellation of all commissions due to you.
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TIPS FOR MAKING SURE YOUR SITE IS COMPLIANT
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Please note that although the HostCentric Affiliate Agreement specifically requires you to comply with all FTC regulations, you also have an independent obligation to comply with such regulations. It is your responsibility to ensure that your actions are always in compliance with all applicable law and regulations.
We have pulled together some examples (based on FTC advice or enforcement cases) to illustrate ways that you can disclose a material connection between you and your advertisers. Take a few minutes to review this summary:
HostCentric Affiliate Disclosure Requirements and Examples
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The FTC also offers a variety of resources to help make it easier for you to comply with the guidelines, including:
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Guides Concerning the Use of Endorsements and Testimonials in Advertising |
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The FTC's Revised Endorsement Guides: What People are Asking |
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Dot Com Disclosures: Information About Online Advertising |
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The FTC Native Advertising Guide |
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Please take steps immediately to make sure that your site is in compliance with these guidelines. Several of our leading affiliates have already posted their disclosures, and they continue to enjoy great success.
Note: These links are intended to provide guidance only. If you provide endorsements of some type, you should obtain legal advice on how the FTC rules apply to you.
Best wishes,
Your HostCentric Affiliate Team
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Quick Tips on How to disclose a "material connection" (i.e., that you receive commissions for internet sales)
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Disclosures must meet these four basic requirements:
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Frequent: Disclosures must be "clear and conspicuous" whether they are in video, print or audio content.
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Clear: Language must be specific and easy to understand. This means, for example, you should identify which brands featured on your page pay you commissions, not merely that “some” do.
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Conspicuous: The location of the disclosure should be place close to your endorsement or review. The font, color and size of the disclosure should be such that it is easily noticed and read. And don’t obscure the disclosure behind a vague, non-explanatory link such as “disclosure” or “disclaimer".
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Require no action: The user shouldn't need to click, hover, or scroll to locate or understand the nature of your disclosure.
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For more information, please review our
Affiliate Disclosure and Requirement Examples.
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