QUALITY CONTROL GUIDELINES

LAST REVISED: July 26th , 2018

LEAD EMBLEM is serious about maintaining the highest quality leads in the industry. Therefore, LEAD EMBLEM will only pay a fee for leads that comply with applicable international, federal, state or local laws, these Quality Control Guidelines, and that are not generated by fraudulent practices.

A valid lead (aka “action” or “user action”) is a lead with accurate and complete information (i.e., all necessary fields have been completed by the consumer). Valid leads must be from real people (consumers) who express a genuine interest in the offer. LEAD EMBLEM will only pay for valid leads. The following Quality Control Guidelines must be met to generate a valid lead:

For all lead generation activity:

  1. Leads must not come from computer-generated sources such as robots, spiders, computer scripts or from other automated, artificial or fraudulent methods, including without limitation any methods designed to appear like an individual, real live person.
  2. Leads must not be processed or entered by anyone other than the consumer named in the lead. Call center operations may be exempt from this requirement with LEAD EMBLEM’s prior consent and written approval.
  3. Leads must not contain false, incomplete or inaccurate information.
  4. Leads must not be from persons never interested in receiving information in the offer, or from persons misled into submitting their information.
  5. Leads must not be duplicate leads, defined as the same contact information (same or similar name with the same phone number or email address) sent to LEAD EMBLEM in the last 30 days. For “payday loan” leads, new consumer-generated requests within 30 days may be accepted if they are not duplicative of prior requests.
  6. Leads must not be incentivized (including without limitation leads generated by offering incentives, payments, rebates or other things of value intended to increase conversion rates).
  7. Leads must not be obtained using misleading or confusing language encouraging persons to submit their contact information.
  8. Leads must not be generated with any websites or offers that are oriented toward, show or promote pornographic or sexually explicit content, gambling, racist or hate speech or other offensive material as determined solely by LEAD EMBLEM.
  9. Leads sent to LEAD EMBLEM must not be sold to other lead buyers, lead aggregators, vendors, wholesale or retailer buyers (i.e., only EXCLUSIVE leads are acceptable).
  10. Leads must not be misclassified (for example, a payday loan lead is not valid if the consumer was seeking information on debt relief programs).
  11. The consumer completing the request form must be 18 years of age or older.
  12. Lead generation methods must comply with the terms of use and privacy policy of the website or internet service provider utilized.
  13. Leads must not be generated through advertisements that are misleading, untrue and/or infringing on any trademark, copyright or other third party intellectual property rights. This is particularly important for leads obtained through Craigslist or other similar online classified ad websites, including without limitation any strategies that redirect persons to landing pages for purposes not clearly referenced or explained in the original ad.
  14. Leads must be delivered to LEAD EMBLEM in real-time.
  15. Leads must not be obtained using any other fraudulent or illegal practices.
  16. Leads sold via Ping Tree must be sold on an exclusive basis.
  17. Leads must be generated in accordance with State and Federal laws, acts and guidelines, including without limitation the Telephone Consumer Protection Act of 1991, the CAN-SPAM Act of 2003, and the Dodd-Frank Act of 2010, among others.
  18. Leads related to consumer finance (including without limitation payday loan leads) must be generated using creative, website copy, or other marketing creative that meets at a minimum the best-practices published by the Online Lenders Alliance (OLA).
  19. Leads related to consumer finance (including without limitation payday loan leads) must meet a redirect rate of no less than 85%.