This FTC Disclosure Policy (“Disclosure Policy”) explains what disclosures you must make when you participate in paid placements through commentfluencer.com (the “Platform”). It is incorporated into our Terms of Service. Capitalized terms have the meaning given there. The US Federal Trade Commission’s Endorsement Guides and applicable law govern; this Policy is a practical, plain-English guide to complying with them on Commentfluencer.
1. Why disclosure is required
When a Commenter is paid, given free product, or otherwise compensated to post a comment, place a link, share a promo code, or otherwise promote a Brand, there is a material connection between the Commenter and the Brand. Under the US Federal Trade Commission (FTC) Act and the FTC’s Endorsement Guides, that material connection must be disclosed clearly and conspicuously so the audience understands the content is sponsored. Similar rules apply in many other countries (e.g., the UK CMA/ASA, EU consumer-protection rules).
Because every paid placement on Commentfluencer involves compensation, disclosure is always required. This protects you, the Brand, and the platforms you post on.
2. Who is responsible
Both the Commenter and the Brand are responsible for compliant disclosure:
- Commenters must include a clear disclosure on each paid placement they post or publish.
- Brands must not instruct or pressure Commenters to omit, hide, or weaken disclosures, and should confirm their placements are disclosed.
- Commentfluencer provides guidance and a disclosure helper, but does not post on your behalf and is not your legal advisor. You remain solely responsible for legally adequate disclosure.
3. What a compliant disclosure looks like
A disclosure must be clear and conspicuous — easy to notice, read/hear, and understand. Make it:
- Unavoidable — placed where the audience will actually see it, not buried, hidden behind a “more” link, mixed into a string of unrelated hashtags, or placed only on a separate page;
- Up front — at the beginning of a comment or caption when practical, before any “read more” cut-off;
- In the same language as the rest of your content;
- In plain terms the audience understands.
3.1 Approved disclosure language
Use clear terms such as:
#ad#sponsored- “Paid partnership with [Brand]”
- “Thanks to [Brand] for sponsoring this” (paid placement)
- “[Brand] is paying me to share this”
#paid/ “Paid promotion”
When a platform offers a built-in “Paid partnership” / branded-content label or tool, use it in addition to a written disclosure.
3.2 Terms that are NOT sufficient
Do not rely on vague or ambiguous tags such as: #sp, #spon, #collab, #ambassador, “thanks [Brand]”, #partner, or simply tagging the Brand. These do not clearly convey a paid relationship.
4. Placement-specific guidance
- Comments (TikTok/Instagram/YouTube): Put the disclosure inside the comment itself, at or near the start (e.g., “#ad — check my bio link for ...”). Do not rely solely on a disclosure hidden in your bio while the comment drives the action.
- Bio links: If your bio is the paid placement, your bio should make clear the link is sponsored/affiliate where applicable. A bio disclosure alone does not cover a separate paid comment — the comment also needs its own disclosure.
- Promo codes: When you share a unique code as a paid placement, disclose that you’re paid (e.g., “Use my code SAVE10 — #ad”).
- Video/voice: If a placement includes spoken promotion, disclose audibly as well as in text; on-screen text disclosures should remain visible long enough to read.
5. Honesty rules
- Only endorse truthfully. Don’t make claims about a product you haven’t tried or don’t believe, and don’t make false, misleading, or unsubstantiated claims (including health, earnings, or performance claims).
- Don’t hide the relationship. Disclosure is required even if you genuinely like the product.
- Follow the Brand’s lawful, accurate claims only. If a Brand asks you to say something false or to omit disclosure, refuse and report it to trust@commentfluencer.com.
6. Platform rules also apply
Each social platform (YouTube, TikTok, Instagram/Meta, and others) has its own branded-content and disclosure rules and tools. You must comply with those in addition to this Policy and the FTC Guides. Some platforms require you to toggle a paid-partnership setting; some restrict certain links or promotions. Using a platform tool does not replace a clear written/spoken disclosure.
7. How Commentfluencer supports and enforces disclosure
- Disclosure helper: When you accept a Deal, the Platform surfaces reminders and ready-to-use disclosure snippets (e.g.,
#ad) you can copy into your placement. This is a convenience, not legal advice or a guarantee of compliance. - Acknowledgement: You may be asked to confirm that you will disclose paid placements before a Deal activates.
- Enforcement: Failure to disclose is a violation of our Terms of Service and Acceptable Use Policy. We may require correction, withhold or forfeit commissions, suspend, or terminate accounts for non-disclosure or for instructing others not to disclose. Repeated or deliberate non-disclosure may result in permanent removal.
8. Quick checklist
Before you post a paid placement, confirm:
- The disclosure is in the placement itself (not just your bio or a separate page).
- It uses clear language (
#ad/#sponsored/ “paid partnership”). - It’s up front and easy to notice, not buried in hashtags.
- You used any platform branded-content tool that applies.
- Your claims are truthful and you can stand behind them.
9. Changes and contact
We may update this Policy from time to time, with notice for material changes and an updated “Effective date.” Questions or reports: trust@commentfluencer.com or legal@commentfluencer.com.
This Policy is a practical guide, not legal advice. When in doubt, disclose more clearly, and consult the FTC’s Endorsement Guides or your own counsel.