Affiliate Compliance Policy

1. Purpose

This policy ensures that all third-party promotion of AvataCore (avatacore.com) complies with U.S. federal advertising law (FTC Act §5, FDA promotional standards, FDCA), state telehealth marketing rules, the LegitScript Healthcare Merchant Certification Standards, and applicable healthcare advertising codes. Violation may result in termination of the affiliate relationship, clawback of unpaid commissions, and where applicable, regulatory referral.

This policy is a binding term of every AvataCore affiliate agreement. By promoting AvataCore in any form, you agree to it.

2. Approved Claim Language

• “Compounded GLP-1 medication using the same active ingredients (semaglutide / tirzepatide) studied in major clinical trials”
• “Prescribed by U.S.-licensed providers”
• “Dispensed by a U.S.-based pharmacy”
• “Free 1-2 day shipping”
• “No insurance required”
• “Cancel anytime”
• “Starting at $149” for the first month (sema-inj/sema-oral); “Starting at $199” first month (tirz-inj). Subscription auto-renews monthly at the standard plan rate ($299 sema, $399 tirz) until cancelled. Cancel-anytime + first-month vs ongoing rate disclosure required on every landing page per FTC ROSCA / Click-to-Cancel Rule.

Statistical claims must cite the source and include the disclaimer in §4. Approved citations:

• “Up to 14.9% average body weight loss in the STEP-1 trial (Wilding et al., NEJM 2021)”
• “Up to 20.9% average body weight loss in the SURMOUNT-1 trial (Jastreboff et al., NEJM 2022)”

3. Prohibited Claims and Creative

3.1 Medical / Efficacy Claims

• “FDA-approved” applied to compounded medications. Compounded preparations are not FDA-approved — only the branded reference products are.
• Any “guaranteed weight loss” or “lose X pounds in Y days” promise.
• Any disease cure, prevention, or treatment claim beyond weight management.
• Any comparison to Wegovy^® or Zepbound^® implying equivalence beyond shared active ingredient.
• “Doctor approved” without naming a specific licensed provider, or misrepresenting AvataCore as employing the providers (we work with a licensed clinical partner network).

3.2 Imagery

• Before/after photos of real people unless backed by signed releases and documented patient outcomes.
• Stock medical imagery suggesting the affiliate or model is a licensed provider.
• Hospital, clinical, or surgical imagery suggesting AvataCore is a hospital, clinic, or surgical service.
• Imagery of branded pens (Wegovy^®, Zepbound^®, Ozempic^®, Mounjaro^®) unless making a clearly-labeled comparative reference.

3.3 Pricing & Urgency

• “Limited time” / “ends today” claims unless tied to a published, dated promotion approved in advance by AvataCore.
• Price claims that omit the rebill / subscription cadence.
• “Free trial” language — AvataCore does not offer free trials of medication.
• Insurance-coverage promises (“insurance covers it,” “no copay”).

3.4 Audience & Targeting

• Promotion to anyone under 18.
• Promotion to states where AvataCore is not licensed (current state list available on request — affiliate is responsible for geo-fencing).
• Promotion to pregnant or breastfeeding individuals.
• Promotion to individuals with a personal or family history of medullary thyroid carcinoma (MTC) or MEN-2.

3.5 Channel-Specific

• Paid search bidding on AvataCore branded terms by affiliates without written approval.
• Cookie-stuffing, forced clicks, iframe injection, or any technique that registers an affiliate click without genuine user intent.
• Email send to lists not opted in for healthcare promotions (TCPA / CAN-SPAM compliance is the affiliate’s responsibility).
• SMS without prior express written consent under TCPA.
• Influencer endorsements that omit material connection disclosure.

4. Mandatory Disclaimers

Any affiliate creative that makes a weight-loss outcome claim, references trial data, or shows a numerical statistic must include the following disclaimer, prominently and legibly:

Individual results vary. Compounded medications are not FDA-approved and have not been evaluated for safety, efficacy, or quality by the FDA. Statistical outcomes referenced reflect FDA-approved branded medications studied in published peer-reviewed clinical trials; compounded formulations contain the same active ingredients but outcomes may differ. Weight loss is not guaranteed.

For paid media subject to character limits, the abbreviated form is acceptable:

Compounded GLP-1, not FDA-approved. Individual results vary.

For influencer / video content, the disclaimer must be (a) spoken aloud at least once, and (b) displayed on-screen during the segment containing the claim.

5. Material Connection Disclosure (FTC §255)

Any individual or entity receiving compensation, free product, commission, or any other consideration from AvataCore in exchange for promotion must disclose that material connection clearly and conspicuously, at the start of the post or video, using one of:

• #ad
• #sponsored
• Paid partnership with AvataCore
• AvataCore affiliate

The disclosure must be visible without clicking “more” / “see more.” On video, the disclosure must appear in the first 3 seconds and remain readable.

6. Review and Approval Workflow

1. Pre-launch creative review. All affiliate creative (ad copy, landing pages, video scripts, email templates, influencer posts) must be submitted to compliance@avatacore.com at least 3 business days before launch.
2. Approval window. AvataCore will respond within 3 business days with: approved, approved-with-edits, or rejected with reasoning.
3. Material changes. Any material change to approved creative requires re-submission.
4. Live monitoring. AvataCore reserves the right to monitor affiliate-driven traffic and creative at any time. Spot audits are conducted monthly.

7. Takedown Process

1. First notice (T+0): Email to affiliate’s primary contact identifying the violation. Affiliate has 24 hours to take down or edit the offending material.
2. Confirmation (T+24h): Affiliate must email confirmation of takedown/edit, with screenshot or URL evidence.
3. Failure to comply (T+48h): Affiliate account is suspended pending review. All earned but unpaid commissions are held.
4. Repeat violation: Termination, clawback of commissions earned during the violation window, and possible referral to relevant regulator.

8. Penalties

9. Indemnification

Affiliates indemnify AvataCore from any claim, regulatory action, lawsuit, or fine arising from the affiliate’s non-compliant promotional activity. AvataCore is not responsible for representations made by an affiliate that are not pre-approved in writing.

10. Reporting Violations

Anyone who identifies non-compliant affiliate activity may report it confidentially to compliance@avatacore.comwith subject “Affiliate Compliance Report.” Reports may be submitted anonymously. We will investigate within 5 business days.

11. Updates

This policy may be updated at any time. Affiliates will be notified via email at least 7 days before any material change takes effect. Continued promotion of AvataCore after the effective date constitutes acceptance.