Advertising Guidelines for IDENTITY GUARD® Related Services Affiliates & Partners
About these Guidelines The Identity Guard® related trademarks and logos (“our marks”) are valuable and important assets of Intersections Inc. As such, it is important that you protect the value of our marks by using them properly. In addition to protecting our marks, Intersections is vigilant about compliance with the plethora of rules, regulations and laws related to identity theft services and fair marketing practices. These guidelines, which may be updated from time to time, set forth our policies regarding use of our marks and advertising or marketing Identity Guard services. These guidelines are for Identity Guard partners, affiliates or other licensees and must be strictly followed. These guidelines are meant to provide guidance and do not constitute Intersections’ legal approval or legal advice and may not be deemed a license to use or market Identity Guard services. Identity Guard related marketing collateral must be approved prior to use by Intersections’ business and legal departments. Failure to obtain such approval prior to use may result in termination of your rights to market Identity Guard products and services. Your rights and restrictions related to use of our marks and marketing methods and channels are proscribed in a written agreement between you and Intersections. Nothing herein shall, nor is it intended to, expand upon those agreed upon rights.
Published April 2013; Revised March 2014 Version 1.1
Table of Contents I. General Affiliate Requirements ............................................................................................. 3 A. Introduction ........................................................................................................................ 3 B. Prohibited Content and Offers.......................................................................................... 3 C. Contextual Advertising ..................................................................................................... 5 II. Creative Requirements .......................................................................................................... 6 A. Trademarks ......................................................................................................................... 6 1. Using Trademarks in Text ............................................................................................. 6 2. Use of Third Party Trademarks .................................................................................... 7 3. Do Not Use Inappropriate Descriptors ........................................................................ 7 4. Set Intersections Marks apart from Other Words or Nouns..................................... 7 5. Use Trademark Notices .................................................................................................. 8 B. Logo Usage Guidelines ...................................................................................................... 8 C. Copyright Notices .............................................................................................................. 8 IV. Advertisements and Offers ................................................................................................. 9 A. Basic Advertising Rules .................................................................................................... 9 B. Common Mistakes ............................................................................................................ 10 C. Endorsements and Awards............................................................................................. 11 D. Free Trial / Terms of Offer .............................................................................................. 12 E. Credit Scores ...................................................................................................................... 13 F. Credit Reports................................................................................................................... 13 G. Special Offers / Limited Time Offers ............................................................................. 14 H. Using Quotes, Statistics, and Facts from Third-Party Sources .................................. 14 V. Products, Features & Approved Copy.............................................................................. 15 A. IdentityGuard.com Products .......................................................................................... 15 B. Sample Copy for IdentityGuard.com Products............................................................ 16 VI. Marketing of Identity Theft Insurance ............................................................................. 18
Published April 2013; Revised March 2014 Version 1.1
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I.
General Affiliate Requirements A.
Introduction
These guidelines and requirements are designed to assist affiliates in the marketing of Intersections Inc. services. These guidelines and requirements provide criteria for acceptable and unacceptable marketing. The services and products which you are permitted to market are expressly granted in your agreement with Intersections. You should only market those services and products expressly agreed to in your agreement. Marketing in channels not expressly agreed to in your agreement should not be used. Such impermissible marketing channels include: • • • •
Post Transaction Marketing Incentive-Based Marketing Paid Search Advertising Telemarketing
Please send all approval requests to your Affiliate Managers
B.
Prohibited Content and Offers
Offers for Intersections services must not be associated with any of the following offers or content: • Advertisements, including job or home listings on Craigslist.com; • “Job Path” traffic is also prohibited regardless of the traffic source including search; • Pages or e-mails offering any government assistance including unemployment benefits, Social Security benefits, disability benefits, Section VIII housing, or other public assistance; • • •
•
Pages or e-mails not in English; Pages or e-mails containing third-party trademarks (including logos) or other intellectual property; Pages or e-mails engaging in lending, pay-day loans, private investigation, physical security services, the practice of law, fraudulent or unethical conduct, or “credit repair” or “credit counseling” as defined by applicable law. Pages or e-mails that promote illegal activities such as gambling, illegal substances, software piracy, or hacking.
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• •
Pages or e-mails that contain content or promote violence or hatred, criminal or illegal activities, sexually explicit material, discrimination based on race, color, sex, religion, nationality, disability, sexual orientation, or age. Pages or e-mails that contain or promote libelous, defamatory, disparaging, obscene or offensive content. 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.
Offers must not be promoted using any of the following mechanisms: • • • • • • • •
Using auto-responder emails to a posting of any kind. Employing incentivized offers including content unlocking. Making the purchase of our product a condition of obtaining any other product or service. Serving as the last step or final step in a cross-sell for a related product. Requiring consumers to enter credit information in order to proceed in a related offer. Using any method to generate impressions, clicks, or transactions that are not initiated by the affirmative action of a consumer. Using spoofs, redirects, or traffic to or from any adult-oriented web sites. Using deceptive offers for free products where customers are taken through the enrollment process to receive the product.
The following types of marketing aren’t allowed: • • • •
Text messaging, personal web pages. Paid search marketing on Google, Bing or Yahoo. Pay per click email marketing. Co-registration path offers.
You may not use, acquire, or attempt to use any pay-per-click, contextual or any other marketing channel or format that includes the terms “Free Credit Report,” “Annual Credit Report,” “annual report,” “annual credit,” “FACT Act,” “FICO,” or any other terms or Published April 2013; Revised March 2014 Version 1.1
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[Type here] misspellings of these, or any term that claims or infers, that our offer is associated with the annualcreditreport.com site. Do not use the word “Free” or “Annual” in the same sentence as the word “Report.” You may not use the names or trademarks of any credit reporting or rating agency. You must at all times comply with all applicable federal, state and local laws and regulations, including the CAN-SPAM Act. You may not send unsolicited spam. If we waive these requirements by act of omission then it should not be deemed a waiver of any of your preceding or subsequent activity.
C.
Contextual Advertising
Contextual advertising includes cost per view (CPV), pay per view (PPV), pop-up, and in-text advertising. The Advertiser does not permit affiliates to bid on or use any contextual advertising on the website of any financial institution, which includes banks, credit unions, credit card providers and investment management websites, and any others we may add to this list from time to time. Intersections also does not allow affiliates to use any of the following on any landing pages or marketing materials: • • • • •
“Security Breach” or “account has been compromised’ Language. Source URL or Website Name of the placement being bid on (example, “ABC.COM Visitor”). Address the consumer as if landing page is associated with the website (example, “Dear Visitor”). Source company’s name, trademarks or logos, or color or design scheme. Indications that the product being offered is a promotion or endorsement from source URL.
Bidding on or optimizing your site pages for the following terms/keywords (or any variations and misspellings) is prohibited: o
IdentityGuard.com
o TransUnion.com
o
CreditReport123.com o FreeCreditReport.com o Identity Guard CreditReport.com o Credit Protect
o Creditscore.com o ID Guard
CreditCheckTotal.com o Lifelock.com Published April 2013; Revised March 2014 Version 1.1
o o
o Privacy Guard Page 5 of 19
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o o Privacy Protect o ID Checkup
Lifelock
o Life lock Experian.com
Equifax.com
We suggest that you use negative phrase matching to avoid having your paid ads appear on these search terms.
II.
Creative Requirements A.
Trademarks 1.
Using Trademarks in Text
Properly Identify Identity Guard Brand Services – When referring to Identity Guard product names, use the proper service level name with the appropriate service descriptions in accordance with the list of current Identity Guard Marks provided below: •
Identity Guard® Essentials - Note: “Identity Guard” is a registered trademark, but “Essentials” is not. Therefore, “Essentials” should not be used with any trademark indicator, but “Identity Guard” should be followed by the registered trademark symbol.
• • • • •
Good Start® Watchful Eye® PrivacyProtect® - Note: PrivacyProtect does not have any spaces. Total Protection® SafeConnex™ - Note: Intersections is applying for a trademark for the term “SafeConnex,” but the mark has not yet registered. Until the mark registers, the “™” symbol should be used after the word. Once the mark registers, we can begin using “®”.
Properly Identify Partner Trademarks – Our partner trademarks are presented as illustrated below: • •
ZoneAlarm® Note: ZoneAlarm is one word. ID Vault®
These lists will change over time. Intersections will provide periodic updates when new trademarks are added. Do Not Use Our Marks in Possessive or Plural Form – Our marks should never be used in the possessive or plural form – however, note that Identity Guard is a registered company name Published April 2013; Revised March 2014 Version 1.1
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[Type here] and may be used in a possessive form with Advertiser approval. They should be used as a proper adjective followed by a proper generic descriptor.
Wrong
Right
Total Protection’s features will help keep you protected. The Identity Guard® Total Protection service will help keep you protected.
Do Not Shorten, Abbreviate or Create Acronyms for Our Marks
Wrong Right 2.
IDG will help keep you protected. Identity Guard® will help keep protected. Use of Third Party Trademarks
Use of any third party trademarks without their express consent may constitute trademark infringement. Use of Experian®, Equifax® and/or TransUnion® trademarks is expressly forbidden without respective express consent. Affiliates MUST have the expressed permission of the credit bureaus to display their trademarks in conjunction with Identity Guard. Intersections will request approval by the credit bureaus on behalf of the affiliate upon the affiliate’s request.
3.
Do Not Use Inappropriate Descriptors
Our marks identify specific products and services. Do not refer to the various levels of service incorrectly. For example, do not state that Identity Guard Good Start offers a suite of identity theft protection software tools.
4.
Set Intersections’ Marks apart from Other Words or Nouns
It is common to set apart trademarks from other words or nouns. This can be accomplished in a number of ways, including by displaying our marks in initial caps online and in e-mail.
Example
The Identity Guard® Total Protection® service.
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5.
Use Trademark Notices
Trademark Notices - Any trademark notice (®, SM, or TM) must appear in superscript and be used in accordance with the following rules: • In headlines and subheads (display) — each occurrence • In copy — first mention on each page Trademark Disclosure - Any Intersections’ trademarks that appear on any Web pages must be included in the disclosure in the order in which they appear on the page. • There is no comma between “Intersections” and “Inc.” • Only include trademarks of services that appear on the page.
Intersections, Identity Guard and Total Protection are Sample trademarks or federally registered trademarks of Intersections Disclosure Inc.
B.
Logo Usage Guidelines
The Identity Guard logo consists of black, grays and red with a metallic shield next to black type. Both the shield and the type contain a unique registration mark. The shield may be used as an isolated graphic. Please refer to the Identity Guard Brand Guidelines for Partners for proper logo presentation.
C.
Copyright Notices
Each page where Identity Guard is presented (even in conjunction with other offers) requires the following notice. The copyright notice precedes the trademark disclaimer.
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© 2014 Intersections Inc. All Rights Reserved. Sample Disclosure
or © Intersections Inc. All Rights Reserved.
The trademark notice and the copyright notice may be combined into a single text unit.
© 2014 Intersections Inc. All Rights Reserved. Intersections, Identity Guard, Total Protection, Monitor, Protect and Recover and associated designs are trademarks or federally registered Sample trademarks of Intersections Inc. Equifax is a registered Disclosure trademark of Equifax Inc., and other trademarks are trademarks of their respective owners.
IV.
Advertisements and Offers A.
Basic Advertising Rules
All content must comply with all advertising and marketing rules, regulations and laws. In addition or in duplication of these rules, we also require the following: •
•
•
All claims related to Identity Guard services must be truthful and substantiated in fact.
Compliance with the Consumer Federation of America’s ID Theft Best Practices document.
Information should be provided to explain the features of any advertised products and services directly on the page. This can be accomplished in one of the following ways: (i) including the information directly on the page; (ii) including the information on the page via dropdown boxes; (iii) including a link to a lightbox that will appear on the page with the additional information; or (iv) including a “Learn More” link that directs consumers to another page containing the information. This information should be provided wherever the product or service offerings are not self-explanatory or do not already have a required disclosure (e.g., “3 credit scores”).
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•
Identity Guard services may never purport to help improve, repair, fix or otherwise affect an individual’s credit score. Intersections is not a credit repair or counseling agency. Therefore, use of the following phrases (or similar phrases) is prohibited: o Fix any credit issues. o Set your credit straight.
•
o
Improve or increase your credit score. o Clean your credit. o Repair your credit.
o
Lower your monthly payments.
o
Provide credit secrets.
Derogatory statements about Experian, Equifax or TransUnion are strictly prohibited. In addition, 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 particular financial institution are strictly prohibited.
B.
Common Mistakes
Do not use the words “safeguard” or “guard” to describe identity theft protection or the Identity Guard services. Use the word “protect” or other words that do not include “guard.” Do not describe any Identity Guard services or features in absolute terms. For example:
Wrong
The Identity Guard® Platinum service will always notify you immediately if any of your information is exposed online.
Right
The Identity Guard® Platinum service will notify you promptly if your registered information is exposed online. The service will stop identity theft.
Wrong The service will prevent identity theft. Right
The service will help you protect your identity from identity thieves.
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[Type here] Intersections obtains credit data from the three major credit bureaus in order to provide certain services. Such collection should be referred to as “obtaining” credit information or data and not “pulling” credit information or data. The service will notify you of certain changes in your credit file. Not ALL changes. We can help a subscriber to protect their identity; help a subscriber to recover from identity theft. The inclusion of the word “help” is key. Never imply we can completely protect a subscriber or help a subscriber to completely recover, nor that we “stop” or “prevent” identity theft from occurring. While a comprehensive service, do not claim Total Protection or Platinum are the most comprehensive service available today, nor that it provides “total” or “complete” protection from identity theft. We can state that Identity Guard Platinum is Intersections’ most comprehensive solution. Do not use “Total Protection” as a way of describing the product or service. For example, it is not permissible to state: “Total Protection from Identity Theft. Buy Identity Guard.”
C.
Endorsements and Awards
The Advertiser requires compliance with all FTC Guidelines, including the revised FTC Guidelines for use of Endorsements and Testimonials. The Advertiser may provide a list of approved testimonials for inclusion in creative. •
•
Any consumer endorsement or testimonial must be submitted to Intersections Inc. 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 The Advertiser would not or could not make on its own behalf without proper editing conventions. Seek approval from The advertiser prior to including testimonials.
The advertiser affiliates may include awards received by him for its products and services. That said, the awards must be current. Seek approval from The Advertiser before including any award or achievement. Common attributions used in Identity Guard marketing include the following:
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[Type here] •
• •
IDENTITY GUARD® PLATINUM – Rated Best in Class, Javelin Strategy and Research 2012. IDENTITY GUARD® TOTAL PROTECTION® — Best in Class, Javelin Strategy and Research 2011. Intersections Inc. — Better Business Bureau A+ Rating.
In the statement: “Join the more than 36 million people who have already been protected by the world leader in privacy and identity theft protection. IDENTITY GUARD from Intersections Inc.”, the phrase “more than 36 million” must always be attributed to Intersections Inc.
D.
Free Trial / Terms of Offer
The material terms of the free trial, including the fact that enrollment in the Identity Guard service is required, must be disclosed in close proximity to the free trial offer. There are three options for displaying the disclosures: Option 1 • Disclose Terms in Main Offer Copy: o Offer – e.g., FREE for x Days. o Follow-up Price – Then pay only $x.xx per month thereafter. o
The follow-up price must appear with the offer copy.
Disclosure at bottom of page: You may cancel your membership anytime simply by contacting us. {“contacting us” links to Contact Us page}.
Option 2 •
•
Disclose Terms in Box in Close Proximity to First Call to Action Button and Above Fold o Offer. o Disclosures below.
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NOTE: It is not necessary to include “You may cancel your membership” copy in the disclosures at the bottom of the page. It is included in the box copy.
Option 3 •
When follow-up price is included smaller, below CTA, the disclosure must state: o “Free for <
> per month thereafter+. o The dagger must lead to the offer terms at the bottom of the page:
E.
+
Optional: You may include “Cancel Anytime” in the main offer copy.
When you order <>, you will begin your <>trial period, you will be billed <<$17.99>> for each month that you continue your membership. You may cancel your membership at any time simply by contacting us.
Credit Scores
The inclusion of marketing credit scores is not allowed.
F.
Credit Reports
The inclusion of marketing credit Reports is not allowed.
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G. Special Offers / Limited Time Offers
Limited-Time Offers - A limited-time offer must be just that — LIMITED IN TIME. The SAME offer cannot be extended for long periods of time; it would be misleading because the offer wouldn’t truly be “limited in time.” These offers also must comply with FTC guidelines regarding limited time offers. Please refer to FTC guidelines for additional information. No additional disclosure language is required for limited time offers. Special Offers - Using the term “special offer” or similar must be substantiated by limited pricing, time limitation or exclusivity of the offer.
H.
Using Quotes, Statistics, and Facts from Third-Party Sources
Be careful with statistics so as to not misrepresent the facts. All statistics must be accurately cited within compliance of our process. 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) Intersections does not have an existing contract with the party from which the facts or quotes are being obtained that precludes The Advertiser 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) The advertiser does not have an existing contract with the party from which the facts or quotes are being obtained that precludes The Advertiser 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 Intersections Paid for - provided that The Advertiser has obtained the proper permissions from the provider (i.e., Javelin, Gartner, etc.) and attribution is given in accordance with instructions from the provider.
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V.
Products, Features & Approved Copy A.
IdentityGuard.com Products IDENTITY
Feature
GUARD® FOR KIDS
Product ID
IDENTITY GUARD® ESSENTIALS
IDENTITY GUARD® GOLD
IDENTITY GUARD® TOTAL PROTECTION®
IDENTITY GUARD® PLATINUM
MM00
DTC1
DTCG
D4CR
DTCP
Child Identity Theft Protection & Child ID Footprint Report
Optional Addon
Optional Add-on
Optional Addon
Optional Add-on
Social Security Number Monitoring
Bank Account Number Monitoring
Account Access via Mobile App (iOS, Android, Blackberry)
Identity Theft Recovery Assistance
Unlimited Toll-Free Customer Service
Online Tools and Resources
1 score monthly (based on Experian data)
All 3 scores Quarterly (based on data from the credit bureaus)
All 3 scores monthly (based on data from the credit bureaus)
Ongoing for all 3 bureaus
Ongoing for all 3 bureaus
Ongoing for all 3 bureaus
1 Report Based on Experian Data
All 3 bureaus quarterly
All 3 bureaus monthly
Credit Scores
Credit Monitoring & Alerts
Credit Report Updates
Lost Wallet Protection
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[Type here] Identity Threat Detection and Alerts
Address Monitoring (Note: per U.S.P.S. guidelines, this service cannot be promoted.)
Antivirus Software
Public Record Report & Monitoring
$1 Million
$1 Million
PC Keyboard Encryption Software Registered Credit Card Number Monitoring
ID Vault® Password Protection Software
Identity Theft Insurance
$1 Million
$1 Million
B. Sample Copy for IdentityGuard.com Products Feature
Sample Copy for IdentityGuard.com Products
3 Credit Scores
Get an up-to-date view of your credit scores based on data from Equifax®, Experian® and TransUnion®. NOTE: Use of credit score language requires additional compliance with Intersections’ Credit Score Disclosure Guidelines.
Credit Monitoring & Alerts
We continuously monitor your credit file every day and alert you if there are certain changes. or We continuously monitor your credit file everyday and alert you if there are certain changes, such as: new credit applications, cell phone accounts, mortgages, and loans.
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[Type here] Credit Report Updates
You’ll stay informed with quarterly (or monthly, depending on the product) credit report updates with updated credit scores plus changes to your credit file.
Public Record Report & Monitoring
We carefully monitor your publicly available information and alert you to certain changes, such as name and aliases, address history, license and registrations, criminal and civil court records, and bankruptcy filings.
Internet Surveillance
If we see that your personal information — Social Security number, registered credit card or bank account numbers — is exposed online, we’ll alert you.
Lost Wallet Protection
We’ll help you cancel your credit cards and access up to $2,000 from your account.
Identity Threat Detection and Alerts
We proactively monitor your name, address and Social Security number for certain activity, such as new applications for credit, a cell phone, auto or home loans, cable, Internet, utility accounts and more, so we can alert you to certain activities.
ID Vault® Password Protector
Protect your online finances from online phishing, pharming and keystroke logging activities. ID Vault® securely encrypts and stores your usernames, passwords and credit card information, then conveniently signs you into your accounts so they stay protected.
PRIVACYPROTECT® AntiKeylogger Software
Encrypting your keystrokes makes them unintelligible to keyloggers so you can stay safe online while you browse the Internet, or connect securely to Wi-Fi hotspots through your laptop.
ZoneAlarm® Internet SecuritySuite
This all-inclusive package contains anti-virus, antispyware and firewall software — free for the life of your membership, saving you hundreds of dollars off the price of standalone security products.
Online Financial Tools
Use our interactive tools such as Credit Analyzer or Buy vs. Rent Calculator to create custom scenarios to find out how certain financial decisions could affect your credit.
Credit Education Specialists
Unlimited toll-free access to Credit Education Specialists to answer your questions.
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[Type here] Identity Theft Recovery Assistance
If you do become a victim of identity theft, the experts on the ITAC Victim Assistance® team will guide you through the recovery process and help you every step of the way to regain your financial identity.
Identity Theft Insurance
See Section IV: Identity Theft Insurance
Identity Theft Insurance
VI.
$2,500
$20,000
Marketing of Identity Theft Insurance
$1 Million Identity Theft Insurance IDENTITY GUARD® $1 million loss reimbursement insurance* with no deductible. Our simple promise to our customers: If identity thieves steal your money, we will help you get it back. Period! o
Never refer to the $1 Million Identity Theft Insurance as a guarantee. o Cannot send customers to a page solely promoting insurance. o Cannot call the insurance documents a “certificate” or “policy.”
o
Required disclosure (see below) must be on landing page or page before customer enrolls. If they enroll straight from a banner, the banner must contain the required disclosure.
Required Footnote Disclosure
*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.
$2,500 and $20,000 Identity Theft Insurance o Up to $2,500 identity theft insurance* (after $250 deductible), for certain expenses associated with identity theft. OR o
Up to $20,000 identity theft insurance* (after $250 deductible), for certain expenses associated with identity theft.
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Required Footnote Disclosure
*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.
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