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Infuse Requirements for Social Media Influencers

Last Updated March 22, 2022

If you are paid to endorse or promote an Infuse affiliated website (“Promoted Website”) or promote an Infuse promoted product or service (“Promoted Product”) through social media, you’re a paid influencer and your endorsement message must make it obvious that you have a relationship- “material connection” – with the Promoted Website or Product.  And your endorsement message must be truthful. Telling your followers about this relationship and being truthful about your experience with an Infuse affiliated website or a Promoted Product is important because it helps keep your recommendations honest and truthful, and it allows people to weigh the value of your endorsements.  And, most importantly, it is required by law and it is your responsibility to comply. 

Here are Infuse’s requirements for social media influencers:

1. What must be disclosed?

You must disclose any material connection to Infuse when endorsing Promoted Websites or Products.  In simple terms, you must disclose that we are paying you to promote the Promoted Websites or Products.  Keep in mind that tags, likes, pins and similar ways of showing you like a brand or product are endorsements. 

2. How must it be disclosed?

Make sure people see and understand the disclosure. 

  • Make the disclosure hard to miss and within the endorsement message itself (and not only in an ABOUT ME or profile page, or at the end of a post or video).
    • Don’t mix the disclosure into a group of hashtags or links.
  • If your endorsement is in a picture (like Snapchat or Instagram Stories), superimpose the disclosure over the picture and make sure viewers have adequate time to see it.
  • If your endorsement is in video, the disclosure should be in the video itself.
  • If your endorsement is in a live stream, the disclosure should be repeated periodically.

 

3. What should the disclosure say?

Use simple and clear language.

  • Use words like “advertisement,” “ad,” and “sponsored” (with or without a hashtag) in the endorsement message.
    • 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.]
  • Simple explanations like, “Thanks to [Infuse or the branded site] for paying me for this endorsement” are enough if placed in a way that is hard to miss. Be sure to use language like this when speaking in a video.
  • If space limited, use terms like “InfuseEndorsedPartner.”
 
4. What other things do I need to be aware of to ensure endorsements are truthful?
 

You can’t talk about your experience with a website or product you haven’t tried, so prior to endorsing a Promoted Website or a Promoted Product, you should visit the website or use the product.   Here’s some background on the websites:

  • Reward Vault and Flash Rewards programs offer consumers the opportunity to earn a gift card by entering some basic contact information, answering survey questions, and completing a certain number of deals. Some of the deals include free online games, monthly subscription boxes, some of the best entertainment services, and much, much more (purchases are generally required). The websites have given consumers over $15 million in Rewards (this is a fact you can mention in your endorsement). Here’s links to the websites: https://flashrewards.co; and https://rewardvault.co.
  • Here’s an example of an Instagram caption for our Rewards Program: “I earned my $750 gift card through Flash Rewards. I had to enter some information and shop for some deals that I already wanted to buy. #sponsoredbyFlash”


Like all advertisements, social media influencers must ensure that claims in ads must be truthful, not misleading and be capable of substantiation – in other words, they must be able to be supported with facts. You must also ensure that material terms of the Rewards Program are disclosed. A material term is a term that the average consumer would reasonably consider necessary to make an informed purchase decision.

  • You can’t make up claims about a product that would require proof the advertiser doesn’t have – such as saying the products are “free” or that someone can “win” a gift card (unless that is the case, such as on Fluent’s sweepstakes websites). For example, if your advertisement relates to Venmo or Cash App, do not imply that there is “free” cash available, or that cash is readily available without material additional steps. 
  • Claims for rewarded Promoted Websites should be accompanied by a ‘Paid Participation Required’ disclosure or other similar language (e.g., purchase required or payment required). For example, if you make a claim that a consumer can earn $750 to a cash app account, you must somehow indicate that there are costs associated with the offer.  Ways to do that would include saying that you “shopped around for some deals and which enabled you to earn the gift card” or you could discuss how much you spent to earn your reward (e.g., “I only spent $75 to earn my $750 gift card.”):
  • Do not state or imply that all consumers must do is “complete a survey,” “verify information,” “confirm shipping details,” or suggest a reward is ready to be “claimed.” Instead, you should use language that conveys there are certain multiple steps involved in earning a reward.
  • If you are endorsing a Promoted Product, be truthful in your claims.  If you haven’t used the Promoted Product, don’t imply that you have.
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