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Thread: Ftc disclosure question

 
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  #1  
Old September 24th, 2012, 06:42 PM
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Ftc disclosure question

I recently got a request from a vendor to include the following in all my content pages that have links to the vendor. My site is a content/review site that promotes a few vendors. The site has generic ftc disclosure with a link in the footer of each page. But the vendor in question wants a little more than the generic disclosure. They want me explicitly name the vendor and the affiliate relationship on the content page.

My question is, does any one have similar vendor specific disclosure for their content pages with aff links.

The vendor wanted me have the following disclosure on each page that has a link to the vendor.

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Quote:

copy on the page "The Company receives a small commission for any XYZ sales generated by this site."

OR

"Click here for information regarding the site's relationship with XYZ." Then have the link that includes the disclosure language.
  #2  
Old September 24th, 2012, 07:46 PM
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Quote:
My question is, does any one have similar vendor specific disclosure for their content pages with aff links
Absolutely not.. and I would leave any program that tries to force links or text on my content pages..

However, the FTC has been pretty clear that the disclaimer shouldn't be buried - I certainly don't think it needs to be vendor specific on every content page, but perhaps your wording isn't clear enough. I have mine in the opening paragraph of the About Us page, which is linked in both the header and footer.

Have they asked other publishers, or just you..?
  #3  
Old September 24th, 2012, 07:48 PM
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Look up treadmill review and check out the Top 10. I worked with affiliates like that who had to disclose due to other reasons.
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  #4  
Old September 24th, 2012, 09:06 PM
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This may help...

While the FTC isn't explicitly requiring vendor-specific disclosures, they aren't confirming that a generic (one-for-all) disclosure is enough either. In fact, they do recommend to place the disclosure in as close of a proximity to the message as possible.

Here's an excerpt from their Q&A on the Endorsement Guides:

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Quote:
Would a single disclosure on my home page that “many of the products I discuss on this site are provided to me free by their manufacturer” be enough?

A single disclosure doesn’t really do it because people visiting your site might read individual reviews or watch individual videos without seeing the disclosure on your home page.

Would a button that says DISCLOSURE, LEGAL, or something like that be sufficient disclosure?

No. A button isn’t likely to be sufficient. How often do you click on those buttons when you visit someone else’s site? If you provide the information as part of your message, your audience is less likely to miss it.
...and a little further down on the same page addressing the affiliate marketing context specifically they said/wrote:

Quote:
As for where to place a disclosure, the guiding principle is that it has to be clear and conspicuous. Putting disclosures in obscure places – for example, buried on an ABOUT US or GENERAL INFO page, behind a poorly labeled hyperlink or in a terms of service agreement – isn’t good enough. The average person who visits your site must be able to notice your disclosure, read it and understand it.
Between the FTC's clear recommendation against generic website pages and that "provide the information as part of your message" wording, it, actually, isn't surprising that this merchant is requiring their affiliates to include a brief, yet clearly visible (aka "conspicuous") disclosure on all content pages that discuss their products and contain affiliate links to them.

Geno
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  #5  
Old September 24th, 2012, 09:16 PM
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Quote:
Originally Posted by teezone View Post
Absolutely not.. and I would leave any program that tries to force links or text on my content pages..
That's what I did. Left the program. But what if most of my vendors come back asking for a vendor specific disclosure. I can't leave em all.

Quote:
Originally Posted by teezone View Post
However, the FTC has been pretty clear that the disclaimer shouldn't be buried - I certainly don't think it needs to be vendor specific on every content page, but perhaps your wording isn't clear enough. I have mine in the opening paragraph of the About Us page, which is linked in both the header and footer.
No, mine is clear enough. Its based on what Shawn Collins of Affiliatetip had suggested in one of his posts. Neither did the aff manage say they had any issues with it. They just want a vendor specific disclosure. Period.

Quote:
Originally Posted by teezone View Post
Have they asked other publishers, or just you..?
It sounded like their legal dept is requesting this to be enforced by all affiliates. Though, I did a search on "XYZ reviews", and on the first two pages of the results, none of the affiliate content sites have a XYZ specific disclosure.
  #6  
Old September 24th, 2012, 11:10 PM
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Quote:
In fact, they do recommend to place the disclosure in as close of a proximity to the message as possible.
Yes, I read that too Geno.. my comments here are probably more applicable to a content site (like mine), and not review sites, which is a focus of the FTC. Plus, from what I gather, many sites write "reviews" that are really just sales pitches.

Products recommended on my site are not reviews - they match content. For example, if I were writing about an episode of a Jamie Oliver show, I would list a few of his cookbooks to supplement the story.

Having said that, we publishers can't lose site of this requirement (although I still wouldn't add a store disclaimer in the example above!).
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  #7  
Old September 24th, 2012, 11:27 PM
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This could be a case where the merchant has received a warning from the FTC and they're trying to cover their asses. I seem to remember a merchant that was fined by the FTC a couple of years ago (unfortunately I can't remember who) and they responded in a similar fashion with the additional requirement that all of their affiliates agree to new terms and a compliance agreement that explicitly spelled out that they would promote the merchants products in strict compliance to the FTC guidelines.

-rematt
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  #8  
Old September 25th, 2012, 07:54 AM
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May be we can start a thread with a list of vendors that require or has required in the past a vendor specific ftc disclosure. That will also give the respective aff managers to clarify the requirement.
  #9  
Old September 25th, 2012, 08:44 AM
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Quote:
Originally Posted by rematt View Post
I seem to remember a merchant that was fined by the FTC a couple of years ago...
Think: "learning"...
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