A commercial enterprise, doing business on the world wide web, with a universal resource locator address of https://auto-essentials.com, alternatively identified by the Internet Protocol routing address of 192.48.40.3, hereafter referred to as “The Company”, in adherence to Federal Trade Commission 16 CFR Part 225, “Guides Concerning the Use of Endorsements and Testimonials in Advertising”, does hereby make the following public disclosure on the use of endorsements and testimonials:
In concordance with § 255.1, subsection (a), The Company hereby publicly discloses that all endorsements displayed by The Company reflected the honest opinions, findings, beliefs, or experience of the endorser. No endorsement displayed by The Company conveyed any expressed or implied representation that would be deceptive if made directly by The Company.
In concordance with § 255.1, subsection (b), The Company hereby publicly discloses that advertisements displayed by The Company may have used an endorsement of an expert or celebrity only so long as The Company had good reason to believe that the endorser continued to subscribe to the views presented. The Company satisfied this obligation by securing the endorser’s views at reasonable intervals where reasonableness was determined by such factors as new information on the performance or effectiveness of the product, a material alteration in the product, changes in the performance of competitors’ products, and The Company’s contract commitments.
In concordance with § 255.2, subsection (b), The Company hereby publicly discloses that advertisements displayed by The Company may have contained an endorsement relating the experience of one or more consumers on a central or key attribute of the product or service that also will likely be interpreted as representing that the endorser’s experience is representative of what consumers will generally achieve with the advertised product or service in actual, albeit variable, conditions of use. The Company possessed and relied upon adequate substantiation for this representation.
In concordance with § 255.2, subsection (c), The Company hereby publicly discloses that any video or audio advertisements displayed by The Company presenting endorsements by what are represented, directly or by implication, to be “actual consumers” utilized actual consumers in both the audio and video, or clearly and conspicuously disclosed that the persons in such advertisements were not actual consumers of the advertised product.
In concordance with § 255.3, subsection (a), The Company hereby publicly discloses that whenever an advertisement displayed by The Company represented, directly or by implication, that the endorser was an expert with respect to the endorsement message, then the endorser’s qualifications gave the endorser the expertise that he or she is represented as possessing with respect to the endorsement.
In concordance with § 255.3, subsection (b), The Company hereby publicly discloses that advertisements displayed by The Company representing expert testimonial, the expert may, in endorsing a product, have taken into account factors not within his or her expertise (e.g., matters of taste or price), the endorsement was supported by an actual exercise of that expertise in evaluating product features or characteristics with respect to which he or she is expert and which are relevant to an ordinary consumer’s use of or experience with the product and are available to the ordinary consumer. This evaluation included an examination or testing of the product at least as extensive as someone with the same degree of expertise would normally need to conduct in order to support the conclusions presented in the endorsement. To the extent that any advertisements displayed by The Company implied that the endorsement was based upon a comparison, such comparison was included in the expert’s evaluation; and as a result of such comparison, the expert concluded that, with respect to those features on which he or she is expert and which are relevant and available to an ordinary consumer, the endorsed product was at least equal overall to the competitors’ products. Moreover, where the net impression created by the endorsement was that the advertised product was superior to other products with respect to any such feature or features, the expert found such superiority.
In concordance with § 255.4, The Company hereby publicly discloses that any advertising displayed by The Company featuring endorsements by organizations, especially expert ones, were viewed as representing the judgment of a group whose collective experience exceeds that of any individual member, and whose judgments were generally free of the sort of subjective factors that vary from individual to individual. The organization’s endorsement was reached by a process sufficient to ensure that the endorsement fairly reflected the collective judgment of the organization. When an organization was represented as being expert, then, in conjunction with a proper exercise of its expertise in evaluating the product, it utilized an expert or experts recognized as such by the organization or standards previously adopted by the organization and suitable for judging the relevant merits of such products.
In concordance with § 255.5, The Company hereby publicly discloses that when there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement (i.e., the connection is not reasonably expected by the audience), such connection is fully disclosed.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, there is no material connection between The Company and the brand, products or services that were mentioned.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, some links displayed by The Company are “affiliate links”. When users click on the link and purchase an item, The Company may receive an affiliate commission. The Company only recommends or endorses products, brands and services that The Company believes will add value to its readers.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, The Company may have received a review or sample copy of a product or service mentioned by The Company. The Company only recommends or endorses products, brands and services that The Company believes will add value to its readers.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, sponsored posts may have been displayed by The Company. Sponsored posts may be compensated to The Company by a cash payment, gift, or some other item of value. The Company only recommends or endorses products, brands and services that The Company believes will add value to its readers.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, there may have existed a personal relationship between one or more employees of The Company and advertisers displayed by The Company. The Company only recommends or endorses products, brands and services that The Company believes will add value to its readers.
In concordance with § 255.5, The Company hereby publicly discloses that, in some instances, other forms of unspecified compensation in the form of gifts or services may have been given to The Company for advertisements that were displayed by The Company or for services, products, brands or other information mentioned by The Company. The Company only recommends or endorses products, brands and services that The Company believes will add value to its readers.
In compliance with Federal Trade Commission 16 CFR Part 225, “Guides Concerning the Use of Endorsements and Testimonials in Advertising”, The Company hereby makes the above disclosure, effective for the calendar year of 2016.
