Endorsers must clearly and conspicuously disclose and make readily apparent all “material connections” to Hizon in all advertising messages and promotional communications concerning Hizon and/or its products or services.
- A “material connection” is one that could influence the weight or credibility a reasonable consumer would give to the communications or messages made by the endorser. Such connections may be in the form of (a) consideration
(such as monetary compensation, including fees or commissions; gift cards; event access; prizes; or free or discounted products or services) provided by Hizon (or any of its agents acting on its behalf) to the
endorser, or (b) a relationship between Hizon and the endorser (such as employment or contractual relationships).
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Some examples of appropriate material connection disclosures are:
- I received [product] from Hizon as a gift;
- [thanks to] [courtesy of] Hizon, I was given this [product]
- Hizon sent me [product] to try;
- Some of the products reviewed in this blog post were sent to me by Hizon;
- This post is a paid advertisement for Hizon;
- I am an employee of Hizon.
These are simply examples of appropriate disclosures and variations on these examples may be appropriate based on the context. The key is to make it apparent to the reasonable consumer that Hizon provided the
subject product or service, as opposed to the endorser independently purchasing or obtaining the subject product or service.
- It is not sufficient to make a single disclosure on a home page or legal terms/disclaimer page that, for example, “many of the products I discuss on this site are provided to me free of charge by their manufacturers.”
Disclosures should be tied to the specific products at issue and readily apparent to readers of the particular blog post.
- When using a Twitter, Facebook, Instagram or similar platform, endorsers should endeavor to include a link on their main profile page directing followers to a comprehensive disclosure statement.
Endorsers who post their own opinions, comments, content or recommendations about Hizon, and/or its products or services, must disclose that their views do not necessarily represent those of Hizon.