Offerpal Media Mobile Advertising Policies

Offerpal Media's top priority is to ensure a safe, credible and trustworthy end-user experience. We therefore hold ourselves and our advertising partners accountable to the highest standard of ethics and corporate responsibility. The following set of guidelines and policies are intended to protect our users from advertising offers that are unclear, misleading, age-inappropriate or otherwise objectionable.

Offerpal Media will conduct a thorough internal review of all offers before they go live on our platform. We will regularly and proactively audit the offers on our platform and will ban any advertisers that knowingly violate the following policies. Offerpal reserves the right to reject or remove offers that do not comply with these policies.

The following policies describe Offerpal Media’s minimum standards for the advertising offers we run on mobile platforms and devices.

Compliance with Governing Bodies

• All mobile offers must abide by the rules and regulations of the wireless carriers, device manufacturers and platform operators, as well as the Federal Trade Commission.

Privacy Policy Disclosures

• All offers that collect Personally Identifiable Information (PII) such as name, date of birth, phone number, social security number, physical addresses, or email addresses must include a link to the advertiser’s privacy policy on every page of the offer.
• The privacy policy should disclose the practice of data collection, usage and sharing.
• The privacy policy should be easy to find and easy to read.
• Consumers must be given notice of any changes to the privacy policy.
• Advertisers must have controls in place to comply with their privacy policies.

Use of Data

• If consent to share PII information is given, it must be opt-in and clearly explained. The check-box must not be pre-checked.
• If PII is granted for the purposes of sending email communications, all CAN-SPAM and privacy laws must apply.
• Advertisers must not share PII with 3rd party marketers without the user’s explicit consent.

Terms and Conditions Disclosures

• Prior to accepting any consumer information, the terms and conditions must be clearly and conspicuously disclosed so that consumers understand the essence of the proposed exchange.
• Due to the limited screen size of mobile devices, the terms and conditions must appear in sufficient font size to be easily readable and obvious to the user.
• The terms and conditions should be accessible and prominent during the registration or offer participation process.
• When using the terms “free,” “complimentary” or similar terms, if some form of obligation is needed by the consumer to receive the offer, advertisers must ensure proper disclosures are made in proximity to the term. (See Use of the Word “Free” or Similar Terms Disclosures section below.)
• Advertisers should include a summary of consumer obligations and requirements on the offer creative. The summary of obligations and requirements is used to additionally educate consumers and not to replace the detailed terms and conditions link that should be prominently displayed for consumers.
• Advertisers may not make any changes to the terms and conditions without providing prior notice to Offerpal Media.

Use of the Word “Free” or Similar Terms Disclosures

• 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 should educate the consumer about the purchase requirement(s).
• 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.
• When developing a proper disclosure strategy for the use of the word “free” it is essential to reference the FTC guidance on the use of the word “free” and obtain legal counsel involvement as needed.

Accuracy of Information

• Ads must comply with all applicable FTC guidelines and other applicable laws, rules and regulations regarding accuracy of information (including without limitation industry-endorsed, self-regulatory principles or guidelines).
• Ads must not be deceptive, misleading, unfair or promote false or misleading claims or include any information that is false or misleading. For example, no deceptive pricing, no "bait and switch" advertising, no claim that "everyone wins" and no implication that the mere act of clicking a button is sufficient to win or suggests the user was specially selected to receive a prize.
• If "Free" is used in the ad, but the product requires Shipping & Handling fees, the ad must state it. For example: "plus Shipping and Handling fees."
• Ads must not make any claim about a product or service (e.g., "guaranteed" results for wrinkle remover) unless it has been substantiated through research or surveys, and that support is made publicly available online.
• Ads must not use superlatives relating to products or services that may be misleading, confusing or unsubstantiated.
• Ads must not inaccurately state or imply approval or endorsement by any government or quasi-government entity.

Landing Pages

• Due to the limited screen size of mobile devices, all landing pages must render with sufficient resolution and font size so that key elements are large enough to be reasonably apparent to the user.
• Advertisers must not redirect users to a different landing page than the one specifically related to the offer as it was approved by Offerpal Media. Advertisers caught redirecting users to unapproved landing pages will be permanently banned by Offerpal Media.
• Landing pages cannot generate a pop-up (including "pop-overs" and "pop-unders") when a user enters or leaves the page.
• Landing pages cannot use "fake" close behavior (ie. when a user clicks the 'close' icon on the page, the page should close down and no other behavior should result).
• Landing pages cannot utilize "mouse trapping" whereby the advertiser does not allow users to use their browser "back button" and traps them on their site and/or present any other unexpected behavior (for example: navigation to another ad or page).

Prohibited Content

• Offensive, profane, vulgar, obscene or inappropriate language;
• Obscene, defamatory, libelous, slanderous and/or unlawful content;
• Tobacco products;
• Ammunition, firearms, paintball guns, bb guns, or weapons of any kind;
• Scams, illegal activity, pyramid schemes, or chain letters;
• Get rich quick and other money making opportunities that offer compensation for little or no investment, including money making schemes positioned as alternatives to part-time or full-time employment;
• Adult content, including nudity, sexual terms and/or images of people in positions or activities that are excessively suggestive or sexual, or provocative images in violation of community standards;
• Adult toys, videos, or other adult products;
• Adult friend finders or dating sites with a sexual emphasis, except where explicitly allowed by governing agencies and approved by the publisher as well as the developer of the content where the offer will be displayed;
• Uncertified pharmaceutical products;
• Spy cams or illegal surveillance equipment;
• Web-based non-accredited colleges that offer degrees;
• Inflammatory religious content;
• Politically religious agendas and/or any known associations with hate, criminal and/or terrorist activities;
• Content that exploits political agendas or uses "hot button" issues for commercial use regardless of whether the advertiser has a political agenda;
• Hate speech, whether directed at an individual or a group, and whether based upon the race, sex, creed, national origin, religious affiliation, marital status, sexual orientation, gender identity, or language of such individual or group;
• Content that advocates against any organization, person, or group of people, with the exception of candidates running for public office;
• Content that depicts a health condition in a derogatory or inflammatory way or misrepresents a health condition in any way.
• Investment advice or opportunities not permitted by applicable law
• Software piracy, hacking or illegal downloads of any kind, including spyware and malware
• Gambling, including any online casino, sports books, bingo, or poker, except where specifically allowed by governing agencies and approved by the publisher