a. Disclose Your Connection to Groupon.  You must make your connection to Groupon clear to viewers, regardless of space limitations.  The disclosure must make clear the nature of the relationship (e.g., whether you were paid or received something for free) and must be prominent enough for consumers to view it easily when they are reading the Sponsored Content.  In more detail:

• Disclosures must be made in all Sponsored Content – it is not enough to have it on your “about” page.
• The disclosure must be visible to the consumer before they engage with your content and without the need to click “more,” scroll, navigate to another page, or otherwise hunt for it.  
• The disclosure must be able to travel with the post in case it is re-posted or shared, which means that the disclosure should be made first or with enough room that it is not cut off.  
• For video and photo posts, include written disclosures in the video or photo.  They must be placed where they will not be obscured by any ads or other content that the platform may place and remain long enough for viewers to read it.  
• For video posts, you must also include oral disclosures in the video.  They must be clearly spoken, reasonably paced, and use language understood by ordinary viewers.
• Examples of what to say are:  #sponsored, #ad, #paidinfluencer, or “Groupon gave me a free trip and…”  

b.  Give Your Honest and Truthful Opinions.  Your statements must always reflect your honest and truthful opinions and actual experiences.  If a statement is not your opinion, but rather something that Groupon has asked you to say, this fact must be made clear to readers.  

c. Only Make Factual Statements That Are Truthful and Can Be Verified.  Only make a factual statement about a product or program's characteristic or quality which you know for certain is true and can be verified.  Remember that even if you don't expressly state a fact, it may be implied, and these Guidelines apply to both express and implied messages.  Be especially careful about making any factual statement about Groupon’s competitors or their products and programs, as Groupon does not support any false or misleading statement or comparison.  

d. Get Permission for Promotions and Disclaim Groupon’s Affiliation. If you are conducting a promotion (sweepstakes, contest, free giveaway, etc.) using Groupon deals, services, products or site credit (i.e. Groupon Bucks) as prizes, please secure approval from Groupon before proceeding.  If Groupon approves, you must include the following statement in a prominent position that can be easily read by consumers: "This promotion is in no way sponsored, endorsed or administered by Groupon or [insert the merchant’s name].  By entering, you agree to look solely to [insert your name] for any claims in connection therewith, and not to Groupon or [insert the merchant’s name]." In addition, you must comply with all applicable laws and with any rules of the platform in conducting such promotions.

e. Do Not Send E-mail Messages on Groupon’s Behalf Unless Expressly Requested.  Unless expressly requested, Groupon does not want you to send any e-mails on its behalf, nor will it provide you any compensation if you do.  To the extent that you send your own e-mails, you must comply with all applicable laws.

a. Brief Overview

DO’s	DON’Ts
Create and use your own content Only use trademarks relating to the specific activity that you are promoting	Use unlicensed music Use content from other influencers or sources, without express authorization from the creator Use third-party trademarks or logos unrelated to the promotion  Reference third parties or celebrities

b.  Copyright.  Copyright protects original works of authorship such as videos, movies, TV shows and broadcasts, paintings, photographs and other visual artworks, video games, songs, books, plays, articles, and music scores.  Owners of copyrights can prevent others from using their work of authorship.

You must create your own content (e.g., take your own photos, create your own videos, and write your own blog posts), and you are prohibited from using any third-party content that you find on the Internet or elsewhere (e.g., images, written prose, or music) as part of any Sponsored Content.

Example 1:  If you go to a Broadway production to promote that particular show, you are not permitted to videotape the production or take a picture of the production as part of the Sponsored Content.  But you may take photographs (1) outside the theatre; (2) inside the theatre, either before the show starts, at intermission, or after the show ends; or (3) with any posters displayed for the show—or of their ticket, playbill, or Groupon voucher.  

Example 2:  You may take videos of yourself jumping at a trampoline park or eating dinner on a dinner cruise, if photography and videotaping is permitted by those businesses.  

Note, though, that you may not include other people or third-party trademarks in your photos except as described in the “Right of Publicity” and Trademark sections below.

c. Trademark.  Trademarks identify goods and services as being from a particular source.  Trademarks can be brand names, logos, slogans, and even product designs.  You may only use trademarks in the Sponsored Content if (i) the trademark has been cleared to use by Groupon; or (ii) promoting the trademark is the purpose of the Sponsored Content.

Example 1:  If you are hired by Groupon to promote purchasing a Los Angeles Rams ticket on Groupon, you may use the Los Angeles Rams’ name in the Sponsored Content, as well as photographs that you took while attending the game, which photos may include the Rams’ logo in the background. 

Example 2: If you are hired to promote a trampoline park for which deals can be purchased on Groupon, you may use the trampoline park’s brand name in the Sponsored Content.   

For example:

Purpose of Sponsorship	Acceptable Post	Unacceptable Post
Disney’s Aladdin Tix, purchased on Groupon	Having the best time at the Aladdin show, with the tickets I purchased on Groupon.	Wearing my favorite pair of Nikes at the Aladdin show.  Bought my tix on Groupon.
Los Angeles Rams Tix, purchased on Groupon	Gorgeous day watching the Los Angeles Rams.  I got my discounted tickets on Groupon.	Drinking an ice-cold Coca-Cola at the Rams game, with tickets I bought on Groupon.

Example 1:  If you take a photograph outside of a theatre to promote tickets to a Broadway show sold by Groupon, and if there is a McDonald’s next to the theatre, you should take caution not to include the McDonald’s brand name or logo in the background of the photograph.  You must ensure that any final Sponsored Content does not include the McDonald’s brand name or logo, as the existence of such matter in the background might cause consumers to believe that McDonald’s also sponsored the post.  

Example 2: If you make a video of your experience getting a facial at a Groupon spa merchant, and if you are wearing a shirt with the adidas logo on it, you should take caution not to include the adidas logo in the video.

d. Right of Publicity.  Right of publicity laws protect the unauthorized use of a person’s identifiable attributes, such as his or her name, voice, likeness (including celebrity images and names) or even distinctive gestures and phrases.  You may not refer to another person’s identifiable attributes in Sponsored Content without express authorization from that person.  For example, you may not post “Feeling like Beyoncé at this Lion King Broadway Show, with tickets purchased on Groupon.”  Additionally, you may not impersonate people or characters in the Sponsored Content.

a. You Are Personally Responsible For Your Actions.  You should know that you are personally liable under federal and state law for your actions with respect to your Sponsored Content, which makes following these Guidelines, as well as all applicable laws, regulations and other legal authority, your responsibility.    

b. Do Not Disclose Any Groupon Confidential Information.  If you are in a position whereby you have received information about Groupon, or its products or services, that is not known by the general public, do not include such information in your Sponsored Content.  To the extent you have any question whether information is confidential in nature, either contact Groupon directly before disclosing such information or otherwise err on the side of caution and do not disclose it.