LifeLock 2015 Annual Report Download - page 147

 As noted, a required disclosure must be clear and conspicuous and is measured by the overall net impression of a reasonable consumer
in how it is perceived and understood within the context of the entire marketing material. This is especially important in the context of
Internet-based marketing and special care must be given in order to recognize and respond to any technological limitations or unique
characteristics of high tech methods of making disclosures, such as frames or pop-ups.
 Review the entire marketing materials to ensure that other elements-text, graphics, hyperlinks or sound-do not distract consumers’
attention from the disclosure.
 Repeat disclosures, as needed, on lengthy Web sites and in connection with repeated claims.
 Banner Ads.
 Banner Ads must link to a landing page so that full information can be provided to the customer.
 Free trial banner ads must include “with subscription to .”
 Banner ads referencing scores must include “Equifax Credit Score” in description. 
.
 Disclosures are not required if they cannot fit. However, creatively incorporate disclosures in banner ads if possible, or disclose them
clearly and conspicuously on the page directly linked to the banner ad which is always a landing page.
2. Social Media.
Social media marketing includes a brand page or profile on a social media site, conducting a promotion or contest using a social media
site, and blogs.
All disclosures must be in  For example, using a hashtag may not be readily understandable to all viewers.
When possible, avoid having to scroll to see the disclosure.
In space-constrained marketing materials, the disclosure must still be clear and conspicuous.
3. Paid Search.
a Each paid search must link to a landing page.
b Each paid search must clarify limited time period for discounts and use “Equifax” with score references.
4. Mobile/ Phone.
a Be sure to disclose how to avoid extra fees and costs in a clear and conspicuous manner. For products/features delivered by text, include “data
charges from your carrier may apply”.

 CROA Concerns. The following terms and phrases may not be used in any marketing materials:
 No reference to Equifax’s products “improving” or “protecting” a consumer’s credit.
 No references to "manage/managing your credit" or "credit management” as a description or feature of Equifax’s products.
 No description of any Equifax product as a “service”.
