Slickdeals Disclosure Policy

This policy applies to influencers, endorsers, ambassadors, publicists, spokespeople and anyone else who writes or speaks publicly, or creates other public content, about Slickdeals or its merchants (e.g. writing articles or blogs, giving interviews, posting on social media or creating videos) or who would otherwise need to make a disclosure under the Federal Trade Commission’s (“FTC”) requirements or other applicable law or regulation.

You are responsible for making these disclosures, and any content you create without these disclosures does not meet Slickdeals’ requirements.  In addition to any other applicable legal and regulatory requirements, you must comply with the requirements below, which are adapted from the FTC guide available at https://www.ftc.gov/tips-advice/business-center/guidance/disclosures-101-social-media-influencers and applicable to social media but also to other media and platforms.

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Your endorsement message should make it obvious when you have a relationship (“material connection”) with the brand. A “material connection” to the brand includes a personal, family, or employment relationship or a financial relationship—such as the brand paying you or giving you free or discounted products or services.

Telling your followers about these kinds of relationships is important because it helps keep your recommendations honest and truthful, and it allows people to weigh the value of your endorsements.

It’s your responsibility to make these disclosures, to be familiar with the FTC’s requirements, and to comply with laws against deceptive ads. Don’t rely on others to do it for you.

When to Disclose

• Disclose when you have any financial, employment, personal, or family relationship with a brand.
  • Financial relationships aren’t limited to money. Disclose the relationship if you got anything of value to mention a product.
  • If a brand gives you free or discounted products or other perks and then you mention one of its products, make a disclosure even if you weren’t asked to mention that product.
  • Don’t assume your followers already know about your brand relationships.
  • Make disclosures even if you think your evaluations are unbiased.
• Keep in mind that tags, likes, pins, and similar ways of showing you like a brand or product are endorsements.
• If posting from abroad, U.S. law applies if it’s reasonably foreseeable that the post will affect U.S. consumers. Foreign laws might also apply.
• If you have no brand relationship and are just telling people about a product you bought and happen to like, you don’t need to declare that you don’t have a brand relationship.

How to Disclose

Make sure people will see and understand the disclosure.

• Place it so it’s hard to miss.
  • The disclosure should be placed with the endorsement message itself.
  • Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, at the end of posts or videos, or anywhere that requires a person to click MORE.
  • Don’t mix your disclosure into a group of hashtags or links.
  • If your endorsement is in a picture on a platform like Snapchat and Instagram Stories, superimpose the disclosure over the picture and make sure viewers have enough time to notice and read it.
  • If making an endorsement in a video, the disclosure should be in the video and not just in the description uploaded with the video. Viewers are more likely to notice disclosures made in both audio and video. Some viewers may watch without sound and others may not notice superimposed words.
  • If making an endorsement in a live stream, the disclosure should be repeated periodically so viewers who only see part of the stream will get the disclosure.
• Use simple and clear language.
  • Simple explanations like “Thanks to Slickdeals for the great deal” are often enough if placed in a way that is hard to miss.
  • So are terms like “advertisement,” “ad,” and “sponsored.”
  • On a space-limited platform like Twitter, the terms “Slickdeals Partner” or “Slickdeals Ambassador” (where Slickdeals is the company name) are also options.
  • It’s fine (but not necessary) to include a hashtag with the disclosure, such as #ad or #sponsored.
  • Don’t use vague or confusing terms like “sp,” “spon,” or “collab,” or stand-alone terms like “thanks” or “ambassador,” and stay away from other abbreviations and shorthand when possible.
• The disclosure should be in the same language as the endorsement itself.
• Don’t assume that a platform’s disclosure tool is good enough, but consider using it in addition to your own, good disclosure.

What Else to Know

• You can’t talk about your experience with a product you haven’t tried.
• If you’re paid to talk about a product and thought it was terrible, you can’t say it’s terrific.
• You can’t make up claims about a product that would require proof the advertiser doesn’t have—such as scientific proof that a product can treat a health condition.

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For more information, please see the FTC’s .com Disclosures:  How to Make Effective Disclosures in Digital Advertising and Endorsement Guides.

If the requirements in this policy, in applicable law or regulation or from the FTC change, you must comply with those updated requirements.