Summary of Affiliate Marketing Guidelines

About These Guidelines

Identity Guard® and its related trademarks, logos, tradenames, intellectual property (our “marks”) are valuable assets are proprietary to Identity Guard and Intersections Inc.(collectively “Identity Guard). Accordingly, Identity Guard requires all marketing partners, affiliates, and other licensees using our marks (each an “Affiliate”) to abide to our Affiliate Marketing Guidelines (the “Guidelines”). These Guidelines may be updated from time to time at Identity Guard’s sole discretion and are meant to provide guidance to Affiliates in their use of Identity Guard’s marks. These Guidelines do not in itself constitute Identity Guard’s express approval, license, or authorization of any Affiliate marketing.

All development and/or use of Affiliate marketing materials containing or referring to Identity Guard marks must be expressly approved in writing by Identity Guard. Please send all approval requests to affiliates@identityguard.com.

The below is a summary (and an abbreviated version) of the requirements relevant to our Affiliates. The full Affiliate Marketing Guidelines governing the Affiliate’s use of our marks can be found at:

https://www.identityguard.com/legal/advertising-and-marketing-guidelines

Summary of Guidelines

Marketing Channels: Affiliates may only market those product/services within the permitted marketing channels as expressly approved by Identity Guard in writing. Unless otherwise agreed to in writing by Identity Guard, the following marketing channels are prohibited and Affiliates may not (directly or indirectly) make use of:

  • Post Transaction Marketing
  • Incentive-Based Marketing
  • Paid Search Advertising
  • Telemarketing
  • Text messages
  • Personal web pages
  • Paid search marketing on Google, Bing or Yahoo
  • Pay per click email marketing.
  • Integration of Identity Guard API.
  • Co-registration path offers.

Prohibited Methods of Advertising/Marketing: Affiliates may not (directly or indirectly) make use of:

  • Auto-responder emails or for posting of any kind.
  • Any method to generate impressions, clicks, or transactions that are not initiated by the affirmative action of a consumer.
  • Incentivized offers including content unlocking.
  • Contingencies making the purchase of Identity Guard’s product or service a condition of obtaining any other product or service, or otherwise requiring as the last/final step in a cross-sell for a related product.
  • Requirements necessitating consumers to enter credit card information in order to proceed in a related offer;
  • Spoofs, redirects, or traffic to or from any adult-oriented web sites;
  • Deceptive offers for free products where customers are taken through the enrollment process to receive the product.

General Advertising/Marketing Rules. In addition to all other requirements of the Guidelines, all Affiliate content must: • Be truthful, accurate, and not drafted in a manner to create a false sense of urgency.

  • Comply with all advertising and marketing rules, regulations and laws.
  • Affiliates may not make or publish derogatory statements about Experian, Equifax or TransUnion and such conduct and/or content is strictly prohibited under this agreement. Content should not focus on mistakes or errors by the bureaus in reporting or maintaining credit data; issues, difficulties or concerns with the credit bureau dispute processes, or selling any consumer data. Derogatory statements about any specific financial institution are also strictly prohibited.
  • Affiliates must comply with U.S. Federal Trade Commission (“FTC”) Endorsement rules, regulations, and guidelines, including disclosure of the fact that they receive compensation for reviewing Identity Guard products and services. The “Affiliate Disclosure” link must be above the fold.
  • All claims related to Identity Guard products and/or services must be substantiated in fact.
  • Identity Guard services may never purport to help improve, repair, fix or otherwise affect an individual’s credit score.
  • Identity Guard is not a credit repair or counseling agency.

Prohibited Advertising/Marketing Content. All Affiliate offers, content, and/or marketing materials containing Identity Guard marks must be provided in English. Identity Guard products or services may not be associated with any of the following:

  • Unsolicited spam.
  • Advertisements on Craigslist.com (including job or home listings)
  • “Job Path” traffic
  • Offers for any government assistance, benefits, housing, other public assistance;
  • Content containing third-party trademarks (including logos) or other third party intellectual property or items requiring proprietary rights
  • Libelous, defamatory, disparaging, obscene, or offensive content
  • Content associated with lending, pay-day loans, private investigation, physical security services, the practice of law, credit “repair”, or credit “counseling” [or similar as defined by applicable law]
  • Content engaging in, promoting or reasonable interpreted to endorse fraudulent or unethical conduct, illegal activities, piracy, hacking, hatred, violence, sexually explicit material, and/or discrimination based on race, color, sex, religion, nationality, disability, sexual orientation, or age.
  • Pages or e-mails that contain content or creative that is deceptive or misleading, or otherwise fails to comply with all applicable federal and state consumer protection laws (including without limitation the federal CAN-SPAM Act and state anti-spam laws).
  • Specific Prohibitions:
  • The use or attempted use of any pay-per-click, contextual or any other marketing channel or format that includes the terms (or similar spellings/misspellings) is prohibited:
  • “Free Credit Report”
  • “Annual Credit Report”
  • “Annual Report”
  • “Annual Credit”
  • “FACT Act”
  • “FICO”
  • “Free Credit Score”
  • or any term that claims or infers, that our offer is associated with the annualcreditreport.com site.
  • The use of the following phrases (including derivatives or similar phrases having reasonably the same or similar meaning) is prohibited:
  • “Fix any credit issues”
  • “Set your credit straight”
  • “Improve” or “increase” your credit score
  • “Clean your credit”
  • “Repair your credit”
  • “Lower your monthly payments”
  • “Provide credit secrets”
  • The use the word(s) “Free” or “Annual” in the same sentence as the word “Report” “Security breach” or “account has been compromised”

Email Advertising/Marketing

All email marketing and/or Affiliate Content must contain the ability for user to remove from your mailing list any e- mail address associated with a wireless domain name, as listed on the current list of wireless domains maintained by the Federal Communications Commission (see, http://transition.fcc.gov/cgb/policy/DomainNameDownload.html).

Email marketing must include a functioning unsubscribe link; prominent opt out instructions, and a toll-free telephone number, physical address, or valid email address at which recipient may contact to file complaints and/or opt-out and must at all times comply with all applicable federal, state and local laws and regulations, including the CAN-SPAM Act.

Affiliates who use e-mail marketing may not use “ASAP” in any email creative or subject line or otherwise suggest a response is urgent if that is not the case; use the phrases “security breach” or “account has been compromised” in any e- mail; remove, alter, or tamper with the opt-out notice and the opt-out mechanism provided by Identity Guard; or market content via PPC networks (i.e. AdKnowlege and AdMarketplace).

Use of Use Experian®, Equifax® and/or TransUnion® within Affiliate Advertising/Marketing Materials. The use of the Experian®, Equifax® and/or TransUnion® trademarks, trade/brand name(s) is expressly forbidden without express consent of the respective company. Affiliates must have the express written permission of the credit bureaus to display their trademarks in conjunction with Identity Guard. In such a case, Affiliate shall notify Identity Guard, and Identity Guard will request approval by the credit bureaus on behalf of the Affiliate.

Contextual Advertising/Marketing. Identity Guard does not permit Affiliates to bid upon or use any contextual advertising including (without limitation) cost per view (CPV), pay per view (PPV), pop-up, and/or in-text advertising on the website of any financial institution, which includes banks, credit unions, credit card providers, and/or investment management websites.

Endorsements, Testimonials, and Awards. Identity Guard requires compliance with all FTC rules, regulations, and guidelines, including the revised FTC guidelines for use of Endorsements and Testimonials. Any consumer endorsement or testimonial must be submitted to Identity Guard in advance of use along with a disclosure concerning (i) when the endorsement was received; (ii) what product(s) the endorsement applies to; and (iii) whether the endorser received any compensation including money, free services, or other free or discounted items. A consumer endorsement or testimonial may not be posted if it incorporates a statement that Identity Guard would not or could not make on its own behalf without proper editing conventions. Seek approval from Identity Guard prior to including testimonials. Identity Guard Affiliates may include awards received by Identity Guard for its products and services. That said, the awards must be current and properly attributed based upon the product and/or entity receiving the award. Seek approval from Identity Guard before including any award or achievement.

Special Offers / Limited Time Offers. A “limited-time offer” must limited in time and must at all times comply with FTC rules, regulations, and guidelines regarding limited time offers. Please refer to the FTC for additional information. No additional disclosure language is required for limited time offers. Using the term “special offer” or similar must be substantiated by limited pricing, time limitation or exclusivity of the offer.

Use of Quotes, Statistics, and Factual Statements from Third-Party Sources. Any third-party content provided including quotes, statistics, and/or factual statements should be from trusted and reputable sources and should not be disseminated if there is any reason to believe the content is inaccurate or misleading. All statistics must be accurately cited.

  • Quotes or Facts from Publicly Available Sources - (e.g., newspapers, magazines, and other hard copy documents) may be used provided that (i) attribution is given, (ii) Identity Guard does not have an existing contract with the party from which the facts or quotes are being obtained that precludes Identity Guard from using the facts/quotes, and (iii) that a non- substantial portion of the article is used (i.e., one or two sentences).
  • Quotes or Facts from the Internet (e.g., FTC Web site, BBB Web site, etc.) may be used provided that (i) such use is in compliance with the terms of use of any information from the site from which the information has been obtained, (ii) give attribution, (iii) Identity Guard does not have an existing contract with the party from which the facts or quotes are being obtained that precludes Identity Guard from using the facts/quotes, and (iv) that a non-substantial portion of the article is used (i.e., one or two sentences).
  • Quotes or Facts from a Report that Identity Guard has Supported/Sponsored - provided that Identity Guard has obtained the proper permissions from the provider (i.e., Javelin, Gartner, etc.) and attribution is given in accordance with instructions from the provider.
  • Product and Cancellation Disclosures Identity Guard requires the following disclosures when marketing a credit score, insurance, or free trial:
  • *The score you receive with Identity Guard is provided for educational purposes to help you understand your credit. It is calculated using the information contained in your TransUnion credit file. Lenders use many different credit scoring systems, and the score you receive with Identity Guard is not the same score used by lenders to evaluate your credit.
  • ** Identity Theft Insurance underwritten by insurance company subsidiaries or affiliates of American International Group‚ Inc. The description herein is a summary and intended for informational purposes only and does not include all terms‚ conditions and exclusions of the policies described. Please refer to the actual policies for terms‚ conditions‚ and exclusions of coverage. Coverage may not be available in all jurisdictions.
  • ***Free for 30 days, then automatically renews at a monthly fee for each month thereafter unless cancelled. If you do not cancel your membership within the trial period, your card will be charged either a monthly or annual fee, depending on the membership plan you choose. You may cancel your membership anytime simply by contacting Identity Guard.
2. Use of Aura Content