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Code of Conduct

Effective as of the date accepted on Credible’s marketing partner website located at www.crediblepartners.hasoffers.com/signup (the “Effective Date”), the party submitting an application to become a Credible partner (“Company”) agrees to follow this Credible Code of Conduct (“Code of Conduct”) when describing or promoting Credible’s products and services (“Advertising Services”) in any medium, including through Company’s website, via email and on social media sites such as YouTube, Facebook, Twitter and LinkedIn (each a “Media Outlet” and collectively “Media Outlets”). Any of Company’s employees, contractors, affiliates or any other person or entity associated with Company that Company has the ability to direct in furtherance of the Advertising Services, will be bound by this Code of Conduct.


 

Any violations of this Code of Conduct in Company’s performance of Advertising Services may result in the immediate suspension of Company as a Credible partner and the withholding of any ill-gotten gains, in addition to any other rights or remedies which Credible may have.


 

Pre-approval:

  • With the exception of editorial content, any content that refers to Credible or Credible products and services must be preapproved in writing by Credible.
  • Company may not engage or permit any sub-affiliates, resellers or advertising networks to promote or distribute any information about Credible, the products and services Credible offers, or any Credible Marks or logos unless Company has received prior written approval from Credible.


 

Notifications:

Company must contact Credible immediately:

  • Upon learning of any actual or alleged violations of this Code of Conduct; or
  • Unless otherwise prohibited by applicable laws, if Company is subject to litigation or regulatory investigation relating to the nature of the Advertising Services.


 

No Misleading Content or Actions:

  • Company may not direct traffic to Credible in any manner designed to generate fraudulent leads, including, but not limited to: mechanical means through deployment or use of Company’s employees, contractors, or third party vendors; automated generation through deployment or use of algorithms, “robots,” “bots” or other automated tools and/or computer-generated search requests, and/or the fraudulent use of software; and/or by any other means utilized for the purpose of fraudulently increasing the payment of fees for the Advertising Services.
  • Company may not represent any content referencing Credible, its products or its services in a deceptive, misleading or unfair manner. Company may not refer to the products or services available on Credible in any manner that suggests such products or services are capable of doing more than it promises, such as, for example, marketing a consumer loan product as capable of as improving a person’s credit score or eliminating debt.
  • Company may not violate the terms and conditions or guidelines of any third-party mail/communication service or system in the promotion of Credible. This includes the posting of advertisements within user generated content sites that may violate such services or system’s terms of use. 
  • Company may not use third-party trademarks to direct traffic to Credible in a manner that is confusing, tarnishes such trademark or implies an endorsement by, or association with, the third-party trademark owner without such trademark owner’s prior written consent.
  • Company may not use any third-party content (such as graphics, text, video and audio) without the prior written consent of such third party, except to the extent permitted by applicable laws.
  • Company must not charge consumers for providing information about Credible.
  • If Company collects consumers’ personal information and shares it with Credible, it must clearly and conspicuously disclose that fact to consumers prior to such collection. 


 

Disclosures:

  • Advertising disclosures must be clearly written and must employ language that is easily understandable by the average consumer. For any communication that includes a reference to Credible, including website pages and emails, Company must include a disclosure that states whether the Company receives compensation from the provider whose financial products or services appear on the website, email, or other communication. For the purposes of this required disclosure, it is insufficient to state that the site “may receive” compensation, or that the site receives compensation from “some” providers, if all of the products or services promoted result in compensation for the Company. For example, if Company receives compensation from “most” providers listed on a website or email, the advertising disclosure should use “most” rather than “some” or “certain.” Moreover, if the amount of compensation received by Company impacts the selection of, order of, or prominence with which partners are presented with Credible, that fact must be disclosed. 
  • If the Company is reviewing multiple products from a single or multiple lenders, the Company should disclose that it has not reviewed every product available, such as: “Not all available financial products and offers from all financial institutions have been reviewed by this website.” 
  • When providing editorial content, Company must disclose the fact that the author’s opinion, analysis or assessment is that of the author’s only and has not been provided or reviewed by Credible (an “Editorial Disclosure”), for example: “This content is not provided by Credible or any of the Providers on the Credible website. Any opinions, analyses, reviews or recommendations expressed here are those of the author’s alone, and have not been reviewed, approved or otherwise endorsed by Credible.” 
  • Advertising disclosures must be prominently displayed in a clear and conspicuous manner. This generally means:
  • The full text of the advertising disclosures appears in sufficient font, color, size and style to be clearly legible and easily distinguishable from other site content wherever it appears on the page. 
  • Use of bold or italicized text is recommended. 
  • Context is very important. For example, a disclosure on a page or email where there is little other text is likely to be far more conspicuous than it would be on a page that is very busy. For the latter, a larger, darker disclosure may be needed to be conspicuous. Thus, to ensure that the hyperlink is clear and conspicuous, attention should be paid not only to its placement, its color and size and the heaviness of its font, but how much other text surrounds it. 
  • Having only one advertising disclosure placed only in the footer of each page or email with no other visual or contextual cues is not acceptable. 
  • “Prominently displayed” means: 
  • Posting the full disclosure text in all caps, large font and/or bold letters in a text box labeled “Advertising Disclosure” near the financial product content; or 
  • Posting an “Advertising Disclosure” jump to the full disclosure elsewhere on the page, a prominent overlay or separate webpage.
  • If the advertising disclosure text is placed in a less prominent location on the page than near the financial product content (e.g., in a footer), then visual cues (e.g., asterisks, superscript or a symbol) must be used in the appropriate location (e.g., after the words “Advertiser Disclosure”) to bring the disclosure to the attention of consumers. 
  • Alternatively, the text could be hyperlinked to the disclosure text. If using a hyperlink labeled “Advertising Disclosure” (or something similar, such as “Advertiser Disclosure”), then the hyperlink itself must be clear and conspicuous, both in appearance and placement, and it must be obvious to readers that it is a hyperlink (e.g., the text of the hyperlink appears with an underline or in the same color as other hyperlinks on the site). The hyperlink can prompt an overlay, “jump” the reader to text that is in a footer or in another non-prominent spot on the page, or send the reader directly to a webpage in which the aggregator provides the advertising disclosure and other editorial policies.

Product/Service Assessments:

This section addresses language, visual cues and rankings that, directly or indirectly, appear to assess, compare and/or evaluate financial products. This can include: 

  • Language: “best,” “top,” “favorite,” “editors’ pick, etc.
  • Visual Cues: stars, badges, ribbons, highlighting, font size, etc. 
  • Rankings: express rankings (e.g., 1-10) and implicit rankings (e.g., “favorite” or “first”).

Any time Company uses such assessments, Company must provide supporting evidence that such assessments are based on the Company’s independent editorial judgment. The means of conducting the assessment should be consistent with the advertising disclosure. In addition, the following rules apply with respect to specific types of assessments: 

  • “Best,” “Top,” etc. Products or Services: Language indicating how such determinations were made must be disclosed with prominence and in close proximity to the content.
  • Visual Cues: Star ratings or other visual cues should explain the meaning of such ratings. 
  • Rankings and Lists: If a Company’s site includes Credible products in a ranking or other comparative valuation suggesting relative quality, value or desirability (e.g., best to worst, top 10), then that ranking cannot be based on whether those ranked products or services have compensated the Company specifically for inclusion in such a ranking. This does not preclude a Company from receiving compensation for other purposes (such as a commission for clicking on a particular provider’s advertised product or featuring a product with prominent “shelf space” on the site).

Reviews:

All reviews reflecting the Company opinion, analysis or recommendation of Credible products or services:

  • must reflect the author’s honest opinions, beliefs and experiences of Credible and its products or services; 
  • must not contain any statement or representation about Credible or its products or services that, to the best of the author’s and editors’ knowledge, is untrue, misleading or deceptive; and 
  • must contain an Editorial Disclosure to inform the reader that the review is that of the author and not provided or reviewed by Credible.

Fair Lending:

Consistent with federal and state laws, Credible policy prohibits discriminatory practices, which include advertising based on certain criteria, specifically: “Prohibited Bases.” Prohibited Bases include age (other than exclusion of prospects to those under 18 years of age); date of birth (other than exclusion of prospects to those under 18 years of age); gender; race; religion; marital status; national origin; receipt of income from public assistance programs; color; sexual orientation and identity; consumer exercise of his/her rights under Applicable Law; education level; language (including device and browser language); geography; and status as a service member of the United States armed forces (each a “Prohibited Basis” and, collectively, the “Prohibited Bases”).


 

If a Company selectively displays Credible to its users (whether through algorithm, product assessments, lead generation, the use of a product selection tool or calculator, etc.), the Company shall not do so on a Prohibited Basis, and shall, upon Credible’s request from time to time, certify to Credible’s satisfaction that it complies with the foregoing. This can include, for example, describing in detail its selection methodology (such as the factors, criteria or algorithms used) to ensure such methodology is applied in a non-discriminatory manner, or providing Credible with summary reports demonstrating that its selection methodology, even if facially non-discriminatory, does not have a resulting discriminatory impact or effect (i.e., disparate impact) on users.

Search Campaigns – Protected SEM Bidding Keywords:

To the extent applicable to the Advertising Services, Company: 

  • must use a broad negative match for Credible Marks in all paid search campaigns;  
  • is prohibited from the following:
  • Bidding on any search terms or phrases containing Credible trademarks, service marks, branded terms, and misspellings or confusingly similar terms (“Credible Marks”). 
  • Bidding on any Credible URLs or variations or misspellings (soft branded) thereof. 
  • Using any Credible Marks in Company’s paid search ad copy.