Advertising Content Policy

This Advertising Content Policy defines the rules applicable to the creation, submission, promotion, distribution, and moderation of advertising content through the Pharoll platform, including the website, web application, mobile application, and any other related digital interfaces. Compliance with this Policy is mandatory for all users of the platform and forms an integral part of Pharoll’s Terms and Conditions.

1. Scope of Application

This Policy applies to all content, campaigns, promotional materials, messages, links, creative assets, texts, images, videos, commercial claims, and any other advertising elements promoted through the Pharoll platform.

It applies in particular to:

Business users, as advertisers, promoters, or parties responsible for campaigns;
Agent users, as promoters, distributors, or disseminators of advertising content;
campaigns distributed on the website, web application, mobile application, and other channels or interfaces linked to the platform; and
content distributed in domestic and international markets, without prejudice to the laws applicable in each relevant jurisdiction.

2. General Principles

All advertising content promoted through Pharoll must:

be lawful, truthful, verifiable, and presented fairly;
not mislead by deception, omission, or confusion;
respect the rights of third parties;
comply with applicable law, including advertising, consumer protection, intellectual property, competition, data protection, image rights, and sector-specific rules; and
comply with the requirements of the country or market in which the campaign is distributed, targeted, or made available.

Any form of misleading, aggressive, covert, manipulative, or otherwise unlawful advertising is prohibited.

3. User Responsibilities

3.1. Responsibility of Business Users

Business users are responsible, in particular, for:

ensuring the lawfulness, accuracy, and legal compliance of advertising content;
ensuring they hold the rights, authorizations, licenses, and consents needed to use texts, images, videos, trademarks, names, testimonials, and other materials included in campaigns;
ensuring the legal compliance of the promoted products, services, or offers;
ensuring that advertised claims, promises, comparisons, prices, discounts, results, or benefits are truthful, current, and substantiated; and
providing, whenever requested, reasonable supporting documentation for campaign validation.

3.2. Responsibility of Agent Users

Agent users are responsible, in particular, for:

promoting content transparently, ethically, and in accordance with this Policy;
complying with advertising identification rules applicable to the channel used;
not altering the meaning, context, or nature of the content in a misleading way;
not resorting to abusive, artificial, fraudulent, or manipulative disclosure practices; and
using only channels, accounts, audiences, and promotional means whose use is legitimate and allowed.

3.3. Shared Responsibility

Without prejudice to the distinction between Business and Agent roles, both may be held responsible, within their respective scope, for violations of this Policy, including where they contribute, by action or omission, to the distribution of unlawful, misleading, abusive, or non-compliant content.

4. Advertising Transparency

All content promoted through the platform must be clearly identifiable as advertising, sponsored content, commercial partnership, or communication of a promotional nature whenever required by law, applicable regulation, channel rules, or relevant market requirements. Business users are responsible for ensuring that advertising content, campaign instructions, creative materials, and promotional messages are designed and made available in a way that allows their commercial nature to be clearly identified.

Business users must, in particular:

structure campaigns in a way that is compatible with advertising transparency rules;
avoid messages, formats, or instructions that promote covert or disguised advertising; and
provide Agents with guidance that is compatible with legally required advertising identification where applicable.

Agent users, or any other users involved in dissemination, must promote content transparently and may not conceal, remove, alter, or distort its commercial nature.

Agent users must, in particular:

comply with transparency indications applicable to the campaign and the channel used;
use labels, notices, or formats that are appropriate to the relevant channel, platform, or market; and
avoid practices that disguise, conceal, or minimize the advertising nature of the communication.

The use of examples such as #ad, #pub, #sponsored, paid partnership, or equivalent terms does not dispense with compliance with the specific rules applicable to the channel, sector, and relevant jurisdiction.

Violation of advertising transparency rules may result in measures such as:

removal of content;
suspension of campaigns;
limitation of platform features;
loss of associated remuneration; and
suspension or closure of the account.

5. Prohibited Content and Practices

It is expressly prohibited to create, promote, or distribute content that includes, promotes, facilitates, or conceals:

5.1. Illegal or Fraudulent Activities

sale of illegal products or services;
fraudulent schemes;
pyramid schemes;
phishing, malware, computer fraud, or unlawful collection of data; and
money laundering, tax fraud, or other unlawful activities.

5.2. Misleading or Deceptive Content

false promises of income;
false, inaccurate, or manipulated claims;
omission of relevant information likely to mislead;
misleading use of testimonials, reviews, metrics, or results; and
content that simulates impartiality while serving a commercial purpose.

5.3. Regulated Products, Services, or Sectors in Breach

unlicensed financial services or services promoted in breach of applicable rules;
unauthorized or unregulated investments;
medical products, health services, supplements, or devices not approved where required;
illegal gambling; and
cryptoassets, betting, alcohol, tobacco, nicotine products, political content, or other sectors subject to legal or regulatory restrictions, when promoted without compliance with applicable rules.

This list is illustrative and does not limit the application of the Policy to other sectors subject to specific regulation.

5.4. Abusive, Offensive, or Harmful Content

hate speech;
violence or incitement to violence;
discrimination;
harassment;
exploitation of economic, social, psychological, or age-related vulnerabilities;
unlawful or inappropriate sexual content; and
promotion of self-harm, physical danger, or harmful conduct.

5.5. Abusive or Manipulative Marketing Practices

spam;
misleading clickbait;
hidden redirects;
artificial or manipulative incentives;
purchase or artificial generation of clicks, views, interactions, or traffic;
use of bots, scripts, fake accounts, or coordinated networks for misleading promotion;
distribution schemes intended to manipulate metrics, reach, engagement, conversions, or remuneration; and
deceptive means used to induce sharing, dissemination, or interaction.

5.6. Infringement of Third-Party Rights

unauthorized use of trademarks, logos, names, images, videos, or other protected materials;
misuse of the image, voice, identity, or reputation of third parties; and
infringement of copyright, industrial property, trade secrets, or other legally protected rights.

5.7. Abusive Collection or Use of Data

campaigns aimed at collecting personal data in a misleading, excessive, or unlawful manner;
use of forms, links, or destinations that breach data protection or security rules; and
use of campaigns to improperly obtain credentials, financial information, or sensitive data.

6. Advertising Directed at Minors

It is prohibited, in particular, to:

exploit the inexperience or vulnerability of minors;
directly encourage purchases by minors;
pressure minors to convince adults to acquire products or services;
use manipulative techniques aimed at minors; or
promote content that is inappropriate for vulnerable age groups.

Pharoll may restrict, reject, limit, suspend, or remove campaigns that, because of their nature, format, message, target, sector, or context, present an increased risk to minors or are incompatible with legal rules applicable in a given jurisdiction.

7. Evidence, Documentation, and Verification

Pharoll may, at any time and before or after publication of a campaign, request information or documentation reasonably necessary to assess content compliance, including, without limitation:

proof of licensing or legal authorization;
substantiation of claims, prices, results, or advertised benefits;
proof of ownership or authorization to use trademarks, images, videos, or other materials;
clarifications about the product, service, advertiser, target audience, or distribution channel; and
documents relevant for compliance, security, or fraud prevention purposes.

Failure to provide sufficient information may justify limiting, suspending, refusing publication of, or removing the campaign.

8. Control, Review, and Moderation

Pharoll does not carry out mandatory prior validation of all content, but reserves the right at any time to:

review campaigns before or after publication;
request changes or clarifications;
require additional documentary evidence;
limit the reach or distribution of a campaign;
suspend campaigns or accounts preventively;
remove content; and
block or close accounts.

Pharoll may act:

on its own initiative;
on the basis of internal security, risk, compliance, or fraud-detection systems;
following reports from users, third parties, or partner entities;
due to legal, regulatory, or judicial requirements; or
in light of rules applicable to the relevant sector, channel, product, or jurisdiction.

9. Notice and Action System

Any user or entity may report content that is potentially unlawful, abusive, misleading, or contrary to this Policy through the means made available by Pharoll, including platform mechanisms and appropriate contact channels.

Where possible, the notice should contain sufficient information for review, including:

identification of the content or campaign;
the reason for the report;
relevant contextual elements; and
available documentation or evidence, where applicable.

Pharoll may:

review the notice diligently;
request additional information;
adopt provisional or final measures; and
record moderation decisions for internal control, compliance, and defense of rights.

10. Consequences of Non-Compliance

Non-compliance with this Policy may result, individually or cumulatively and depending on the seriousness, recurrence, risk, and impact of the infringement, in:

a request to correct or amend the content;
rejection of the campaign;
removal of content;
limitation of platform features;
suspension of campaigns;
retention or loss of associated remuneration;
temporary account blocking;
permanent account closure;
communication to relevant partners; and
communication to competent authorities where applicable.

11. Cooperation with Authorities and International Compliance

Pharoll may remove content, restrict campaigns, provide legally required information, and cooperate with competent authorities whenever permitted or required by applicable law. Given the potentially international nature of the platform, users must ensure compliance with the law applicable in the relevant jurisdiction, including, in particular, the country or market in which:

the campaign is distributed;
the audience is targeted;
the product or service is made available; or
the promotional activity is carried out.

Pharoll may adopt moderation, restriction, or removal measures based on legal, regulatory, or sector-specific requirements applicable to the relevant country or market, even where those requirements differ across jurisdictions.

12. Limitation of Pharoll’s Liability

Pharoll acts as a technological intermediary and does not automatically edit, review, or approve all content submitted or distributed by users.

Users remain responsible for the content they create, submit, promote, or distribute, as well as for the legal compliance of their activities.

Without prejudice to Pharoll’s applicable legal obligations, Pharoll does not guarantee the lawfulness, accuracy, or compliance of third-party content, nor does it assume responsibility for acts carried out by users outside the platform.

13. Interaction with Other Policies and Terms

This Policy must be read together with:

Pharoll’s Terms and Conditions;
the Privacy Policy;
the Cookie Policy;
the Anti-Fraud / Invalid Traffic Policy, where applicable; and
any sector, campaign, channel, or product rules that may be adopted by Pharoll.

In the event of conflict between this Policy and specific campaign rules, the stricter rule shall prevail unless expressly stated otherwise.

14. Policy Updates

Pharoll may update this Advertising Content Policy at any time to reflect legal, regulatory, operational, technical, or commercial changes. The latest version will be made available on the platform and will take effect upon publication or on the stated effective date.

15. Contact

For questions relating to this Policy, users may contact Pharoll through:

Email: [email]
Address: [address]