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Dot Com Disclosures

Dot Com Disclosures. Ensuring That Your Online Disclosures are “Clear and Conspicuous” Pablo M. Zylberglait Division of Enforcement Federal Trade Commission. Placement Hyperlinks Banners Design Technology. Placement of Online Disclosures.

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Dot Com Disclosures

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  1. Dot Com Disclosures Ensuring That Your Online Disclosures are “Clear and Conspicuous” Pablo M. Zylberglait Division of Enforcement Federal Trade Commission

  2. Placement • Hyperlinks • Banners • Design • Technology

  3. Placement of Online Disclosures • Place disclosure near or on same screen as triggering claim • Otherwise • Use text or visual cues to encourage scrolling • Avoid formats that discourage scrolling • Repetition • Repeated claims • Lengthy Web sites

  4. Placement Quiz Pizza Wizzard! Requires AC adapter available for $49.99 Requires AC adapter available for $49.99

  5. Placement Quiz Is the disclosure about the AC adapter adequately placed on this advertisement? • Probably yes • Probably not • Yes, as long as the adapter is really necessary • It doesn’t matter. I always get my pizza delivered Pizza Wizzard! Requires AC adapter available for $49.99

  6. Using Hyperlinks to Make Disclosures • Sometimes, full and complete disclosures are • Too lengthy to be placed near the claim, or • need to be repeated We the people of the United States, in order to form a more perfect union, establish justice, insure domestic tranquility, provide for the common defense, promote the general welfare, taxes and delivery fees not included, and secure the blessings of liberty to ourselves and our posterity, do ordain and establish this Constitution for the United States of America. We the people of the United States, in order to form a more perfect union, establish justice, insure domestic tranquility, provide for the common defense, promote the general welfare, taxes and delivery fees not included, and secure the blessings of liberty to ourselves and our posterity, do ordain and establish this Constitution for the United States of America. We the people of the United States, in order to form a more perfect union, establish justice, insure domestic tranquility, provide for the common defense, promote the general welfare, taxes and delivery fees not included, and secure the blessings of liberty to ourselves and our posterity, do ordain and establish this Constitution for the United States of America

  7. Using Hyperlinks to Make Disclosures • Place appropriately and prominently • Label to convey importance, nature, and relevance Hyperlinks

  8. Designing the Hyperlink • Make it Obvious • Don’t be coy • Don’t be subtle* • Use hyperlink styles consistently

  9. Hyperlinks Quiz 1 Is the hyperlink adequate if the disclosure states: “Requires AC adapter available for $49.99”? • Yes • Yes, as long as both prices are in U.S. Dollars • No Pizza Wizzard! accessories accessories

  10. Ensuring that the Disclosure is Prominent • Take consumers directly to the disclosure on the click-through page • Assess the effectiveness of hyperlinks

  11. When to Avoid Using Hyperlinks • Disclosure is integral to the meaning of the claim • Unexpected costs • Health warnings • Safety warnings • Disclosure easily fits next to the claim

  12. Hyperlinks Quiz 2 CD-Playing Capabilities by Sentrix CD-Playing Capabilities

  13. CD-Playing Capabilities The Sentrix DVD710ATcan play all music CDs except for: • Commercially recorded music CDs manufactured prior to the year 2000, or • CDs recorded through a personal computer

  14. Hyperlinks Quiz 2 Is the hyperlink about the CD-playing capabilities labeled adequately? • Yes • No • Only if you can play CDs without the need for an adapter by Sentrix CD-Playing Capabilities CD-Playing Capabilities

  15. Disclosures and • Disclosure within the banner? • does it fit? • is the claim deceptive without it? • If not within the banner, take consumers directly to the disclosure • Provide required disclosures in interactive banners

  16. Good Design : Greater Effectiveness • Sizematters • Formatting claims and disclosures consistently helps • Color counts

  17. Design • Don’t bury the disclosure We the people of the United States, in order to form a more perfect union, establish justice, insure domestic tranquility, provide for the common defense, promote the general welfare, taxes and delivery fees not included, and secure the blessings of liberty to ourselves and our posterity, do ordain and establish this Constitution for the United States of America • Review entire ad to avoid distractions • Use adequate audio disclosures • Use adequate video disclosures • Text is always a good bet

  18. Technology Variables • Hardware • Graphic cards • Monitor size and definition • Operating system display options • Browser capabilities and settings • Online software (plug-ins, Java, etc.) • Consider technological limitations • Design with default settings in mind

  19. Recap Dot Com Disclosures • Near triggering claim • Hyperlinks • place them near the claim • label them clearly • take consumers directly to the disclosure • Use design techniques to help consumers notice and understand disclosures and hyperlinks. • Try to accommodate prevalent default settings in consumers’ browsers

  20. Dot Com Disclosures Ensuring That Your Online Disclosures are “Clear and Conspicuous”

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