VanceAd

Data Collection

-Affiliates may not mask fields without consumer disclosure.

masking fields is the collection of personal information obtained by the publisher and then transmitting that data to the advertiser without notifying the consumer which parts of the data will be shared. Personally identifiable information that is entered on the publisher’s website prior to the consumer’s interaction with an advertiser may be pre-populated in an offer form, but cannot be passed without providing the opportunity for the consumer to review that information.

Example: A consumer’s email address is known from the affiliate’s registration page. Pre-population of the data in any field is not allowed. We want the user to be aware and make an informed decision on deciding to share that data with the advertiser or not.

-Affiliates and advertisers must disclose if the data collected will be shared with third parties.

-Publishers cannot sell data that the consumer has provided during registration or on/in an advertiser offer form to other companies to use to market itself to the consumer without the consumer’s knowledge or choice.

-Publishers who host lead generation offers within another publisher’s registration process may use the collected data for improved optimization and targeting of subsequent offers. If the data is used for this purpose, the publisher must disclose usage of that data in their terms and conditions.

-No sharing of personally identifiable information with 3rd party marketers for the purpose of sending email, without consent

Web sites that capture Personally identifiable information should not engage in sharing or sale of such data with any 3rd party marketers for the purpose of sending email, unless the consumer has consented to share their email address with 3rd parties. Web sites that do share Personally identifiable information with 3rd party marketers, as outlined herein, must disclose to consumers that this will occur. Disclosure should be clear and conspicuous, and must be included at the point of signup and/or on the offer page, in addition to the privacy policy.

-Publishers and advertisers using third parties to manage their email list must have a formal data licensing agreement.

-If more than one list management partner is used, the publisher or advertiser must maintain opt-out procedures for each partner. In addition, establish a mechanism to quickly and efficiently remove these users from all list management partners.

-Publishers and Advertisers must make sure the “skip” option is CLEAR AND APPARENT and is not hidden or difficult to locate on the offer. In addition, the skip function should be displayed in equal prominence to the submit function.

-If multiple pages are used with various offer requirements, it is recommended that consumers be able to navigate freely between the offer pages to better understand the scope of the incentive requirements.

-The publisher should disclose directly on the registration page exactly what the consumer needs to do in order to receive the reward.

-A summary of key requirements of the consumer must be disclosed on the first registration page.

-If the consumer must sign up for various offers to qualify for the reward, the publisher must disclose to the consumer the cost associated with each offer presented.

– If there is some form of monetary obligation needed to qualify for a gift, the publisher must provide the consumer with a representative estimate of such costs.

– When using the term “free” or “complimentary” or other similar terms, advertisers should ensure proper disclosures are made within close proximity of the claim, if some form of obligation must be incurred by the consumer to receive the offer.

-The disclosures concerning the term “free” must be displayed based on any existing statutes, regulations, or guidance in a publishers’ area of operations. The disclosures must also be displayed in the same font color and type.

-The term “free” (or similar terms) and related disclosures must be highlighted on the registration page by a unique color and font that stands out from the other text on the creative material.

-If a purchase will be required by the consumer to receive the reward item, then the disclosure within close proximity of the word “free” (or similar terms) must be in the same color, font, and size of the word “free” (or similar terms) and it must educate the consumer about the purchase requirement(s).

-A summary of the requirements must be listed on the registration page. In addition, the verbiage qualifying the word “free” (or similar terms) must reference the summary terms and conditions listed on the registration page.

-If the offer requires the consumer to fulfill various requirements to receive a free gift, the consumer must always be required to certify he/she agrees to the terms and conditions.