1. Purpose and Scope
This Advertising, Sponsored Content and Merchant Rewards Policy (“Policy”) explains the standards governing advertisements, sponsored posts, promotional campaigns, merchant offers and advertising-related rewards on PalKeeper services operated by PalKeeper Inc. (“PalKeeper”). It applies to advertisers, merchants, creators, agencies, users and others who publish, fund, distribute or interact with promotions through PalKeeper. It supplements the Terms of Service, Community Standards, Acceptable Use Policy, Privacy Policy, Cookie and Tracking Technologies Policy and applicable campaign terms.
2. Advertising Models and Availability
PalKeeper may display advertisements through third-party advertising networks, directly arranged merchant campaigns, sponsored content, promotional placements and other formats made available from time to time. The availability, placement, eligibility, pricing and features of each format may vary by region, account, device, campaign or applicable law. A feature described here is not a representation that it is currently offered.
3. User-Directed Advertising Preferences
Where available, users may select preferred advertising categories, brands or topics. Preferences help inform eligible advertising experiences but do not guarantee that a particular advertiser, offer or number of ads will appear, or that every unrelated ad will be excluded. Advertising preferences are distinct from consent to cookies, mobile identifiers, personalized tracking or third-party data sharing. Those activities are governed by applicable privacy notices and controls.
4. Advertising Identification and Transparency
Paid placements, sponsored content, material endorsements and other commercial relationships must be disclosed clearly and conspicuously as required by law and platform rules. Advertisers and creators must not disguise promotional material as independent reporting, an emergency notice, a personal recommendation without a relevant disclosure, or an ordinary user interaction where the commercial relationship would be misleading.
5. Advertiser Eligibility and Verification
Advertisers must have authority to act for the business, product or service promoted and must supply accurate business, billing, contact and substantiation information when requested. PalKeeper may require additional verification, approvals, licenses or documentation before or during a campaign. Verification or acceptance does not constitute endorsement or a guarantee of legality, quality or results.
6. Truthful Claims and Landing Pages
Advertisements must accurately represent products, prices, availability, material conditions, delivery, risks and expected outcomes. Material claims must be substantiated before publication. Landing pages and linked destinations must be functional, relevant, safe and consistent with the ad; they must not use deceptive redirects, hidden charges, impersonation, malware or misleading consent prompts.
7. Restricted and Prohibited Advertising
PalKeeper may reject or restrict ads involving fraud, unlawful products or services, sexual exploitation, child exploitation, credible threats, hate or harassment, dangerous instructions, illegal drugs, weapons, deceptive financial claims, counterfeit goods, unauthorized gambling, misleading health claims, privacy-invasive surveillance or other prohibited material. Additional restrictions may apply to alcohol, age-restricted products, political or issue advertising, financial products, health products and other regulated categories. Advertising that is lawful in one jurisdiction may still be restricted by PalKeeper or an advertising partner.
8. Safety, Emergencies and Sensitive Contexts
Advertisers must not exploit an emergency, fabricate SOS footage or safety incidents, impersonate emergency responders, or imply that purchasing an advertised product is necessary to obtain emergency help. Advertisements must not interfere with the operation or visibility of safety-critical features, including SOS, Watch My Back, Pal Tap and Route Alert. PalKeeper may restrict advertising near sensitive emergency content or in other high-risk contexts.
9. Supervised Minors and Age-Appropriate Advertising
Advertising shown to supervised minors must comply with applicable child and teen privacy, consumer-protection and advertising rules, including restrictions on behavioral targeting and age-inappropriate products. Guardian permission to use PalKeeper or participate in legally eligible marketplace activity does not by itself authorize advertising tracking. Where an ad network or app-store policy requires additional child-directed safeguards, those requirements must be satisfied before the relevant advertising is served.
10. Sponsored Posts, Influencers and Endorsements
Creators, influencers, affiliates and businesses must disclose material connections such as payments, free products, commissions or other benefits when promoting a product or service. Testimonials must reflect genuine experiences and must not fabricate customers, outcomes or independent reviews. Advertisers remain responsible for claims made by representatives and agencies acting on their behalf.
11. AI-Generated Advertising and Automated Activity
Realistic synthetic media or materially manipulated promotional content must be disclosed when omission could mislead people about an actual person, event, endorsement or product. AI may not be used to impersonate individuals without authorization, fabricate testimonials, generate deceptive emergency media or simulate authentic user engagement. Automated posting, campaign operations or agents are permitted only where authorized and must comply with platform rules.
12. Merchant Promotions and Reward Offers
PalKeeper may facilitate merchant-sponsored offers under which eligible users receive promotional value for qualifying actions. Each offer may specify its own reward type, value, conditions, availability, limits, redemption location, expiration and fulfillment rules. Merchant-specific rewards are not automatically cash, Pal Vault earnings, transferable balances or general-purpose payment instruments. Unless an offer expressly states otherwise, a reward is redeemable only under the sponsoring merchant’s stated conditions.
13. Reward Qualification, Changes and Abuse
A reward is earned only after the stated qualifying conditions have been met and any applicable verification is completed. PalKeeper or the sponsoring merchant may set campaign-specific limits and may suspend or modify future offers, subject to applicable law and commitments already made. Fraudulent impressions, invalid traffic, self-referrals, bot activity, manipulated completions, duplicate accounts and other reward abuse are prohibited. Legitimately earned rewards will not be arbitrarily cancelled merely because a later offer changes.
14. Third-Party Advertising Networks and Rewarded Formats
Advertisements served by third-party networks, including any integrated mobile advertising SDKs, are subject to applicable network policies and technical restrictions. PalKeeper does not authorize users or advertisers to artificially generate ad views, clicks, installs or conversions. Incentives for watching or interacting with ads may be offered only through formats and mechanisms expressly permitted by the relevant network and applicable law. Merchant promotional rewards must not be represented as incentives to click ordinary network ads where prohibited.
15. Privacy, Consent and Tracking
Collection or use of advertising identifiers, cookies, pixels, SDK data, attribution signals or other personal information must comply with applicable privacy law and PalKeeper’s published privacy notices. Advertisers must not obtain, infer or disclose sensitive personal information unlawfully, use unauthorized tracking, scrape private user data or attempt to bypass consent choices. PalKeeper’s advertising preferences do not replace legally required consent or opt-out mechanisms.
16. Advertising Data and Reporting
Campaign dashboards, impression counts, click counts, conversions, reach and other measurements may be estimates and may be adjusted for invalid traffic, delayed reporting, technical issues or provider corrections. Unless expressly agreed in writing, PalKeeper does not guarantee impressions, clicks, conversions, revenue or campaign outcomes. Access to campaign data is limited by applicable agreements, privacy rules and technical availability.
17. Campaign Orders, Pricing and Payment
Direct advertising campaigns may be governed by an insertion order, campaign confirmation, rate card or separate agreement identifying the advertiser, creative, placements, budget, currency, payment schedule and delivery conditions. No price, credit term, minimum spend or billing method is established by this Policy alone. Taxes, payment processing, refunds and adjustments will follow the applicable written campaign terms and mandatory law.
18. Campaign Review, Changes and Cancellation
PalKeeper may review, request changes to, reject, pause or remove advertising that violates law, this Policy, network requirements or platform safety standards. Advertiser-initiated changes, cancellations, unused budgets, credits and refunds are governed by the applicable campaign agreement and non-waivable legal rights. Where feasible, PalKeeper may communicate material campaign decisions and provide a route for review; urgent risks may require immediate action.
19. Merchant Responsibilities and Fulfillment
Merchants are responsible for accurate offers, inventory, pricing, redemption terms, customer support and lawful delivery of the goods, services or promotional benefits they promise, except to the extent PalKeeper expressly assumes a responsibility in writing. Advertisements must not misstate PalKeeper’s role as seller, guarantor, payment provider or sponsor. Consumer complaints and statutory remedies remain available as required by law.
20. Complaints, Enforcement and Appeals
Users may report deceptive, inappropriate or harmful advertising through available reporting channels. PalKeeper may request corrections, restrict distribution, disable campaigns, withhold disputed promotional benefits pending review, suspend advertising privileges or take other proportionate action. Serious fraud, exploitation or safety threats may warrant immediate removal. Where available and appropriate, affected parties may seek reconsideration using PalKeeper’s published support or appeal process.
21. No Endorsement; Legal Rights
The appearance of an advertisement does not mean PalKeeper endorses the advertiser, product, claims or external destination. Nothing in this Policy excludes liability or consumer rights that cannot lawfully be excluded, or alters obligations expressly accepted by PalKeeper in a separate binding agreement. Users should assess third-party offers carefully and report suspected fraud.
22. Policy Updates and Contact
PalKeeper may update this Policy as advertising services, law and platform practices evolve. Changes will be communicated as required by applicable law and will not automatically override rights already accrued under a binding campaign or offer. For questions or reports, use the official contact or support channels identified on palkeeper.com. The controlling version is the version published by PalKeeper at the time applicable to the relevant activity.
23. Spark Merchant-Sponsored Campaigns and Promotional Settlement
23.1 Spark scope and campaign controls
Spark is a merchant-sponsored promotional advertising feature. Available campaign controls may include ad format, placement, categories, audience targeting, geographic region, budget, Spark promotional amount, promo code, destination URL, minimum and maximum expected footprint, and campaign expiration. Availability and eligibility depend on the actual configuration shown before activation. Targeting selections are preferences, not guarantees of delivery or conversion.
23.2 Defined amounts
The total Spark Amount is the merchant-funded promotional amount designated for the Spark campaign, separate from any disclosed advertising placement charges, taxes or payment processing charges. PalKeeper retains 10% of the total Spark Amount as its Spark platform allocation. The remaining 90% is the promotional allocation available to fund valid rewards and, where applicable, advertising credits. A reward value offered to an individual user is distinct from the total Spark Amount.
23.3 Footprint definition and measurement
Spark Footprint is the percentage of measured campaign reach that results in qualifying impacted customers, calculated as (qualifying impacted customers ÷ measured campaign reach) × 100. Campaign reach, unique customers, qualifying actions, attribution windows and exclusions must be defined in the campaign configuration or applicable campaign terms. Repeat impressions, invalid traffic, fraudulent activity and duplicate qualifying actions may be excluded under a consistently applied methodology. Where reach is zero, the footprint is treated as zero for settlement purposes.
23.4 Expected minimum and maximum footprint
Before activating a Spark campaign, the merchant or advertiser must set both a minimum and maximum expected Spark Footprint percentage. The minimum must not exceed the maximum; values must satisfy PalKeeper’s displayed configuration limits. These percentages are advertiser-selected performance expectations, not a promise or guarantee by PalKeeper of reach, customers, sales, revenue or redemptions.
23.5 Campaign duration and expiration
The merchant must select a campaign start date and Spark campaign expiration date. The campaign expiration must be at least 30 calendar days after the initial campaign start date. A campaign may have a longer period where supported. Campaign expiration is distinct from the redemption deadline for rewards already issued; valid user rewards remain subject to their separately disclosed terms and applicable law. Campaign changes may not retroactively impair validly earned rewards.
23.6 User reward eligibility and redemption
Eligible users may receive merchant-sponsored promotional value only after satisfying the disclosed conditions. Spark rewards are not automatically cash, withdrawable Pal Vault earnings, transferable balances or general-purpose payment instruments. Unless expressly stated otherwise, rewards are redeemable only at the sponsoring merchant’s PalKeeper Storefront. If the campaign expressly permits it and the merchant supports it, redemption may also occur at that merchant’s external online storefront or physical location. The merchant must disclose eligibility, eligible goods/services, any minimum spend, redemption instructions, exclusions, deadlines and applicable restrictions.
23.7 Settlement when footprint is zero
After campaign completion and validation, if the measured qualifying footprint is zero, PalKeeper retains its 10% Spark allocation and credits the remaining 90% of the Spark Amount, less any valid reward commitments or other disclosed adjustments, to the merchant’s or advertiser’s restricted Pal Vault advertising-credit balance for future eligible ad spending. This credit is not automatically cash-refundable, withdrawable or transferable.
23.8 Settlement when footprint is positive but below minimum
If actual qualifying footprint is greater than zero but below the merchant’s minimum expected footprint, the promotional allocation remains enforceable: valid rewards earned or committed under the campaign are honored and deducted from the 90% promotional allocation. After validation and settlement, the unused, uncommitted balance is credited to the merchant’s or advertiser’s restricted Pal Vault advertising-credit balance for future eligible ad spending. PalKeeper retains its 10% Spark allocation. A below-minimum result does not cancel legitimate user rewards.
23.9 Settlement when footprint meets or exceeds minimum
If actual qualifying footprint meets or exceeds the minimum expected footprint, valid rewards are honored under the approved offer. Any unused and uncommitted promotional allocation is credited to the merchant’s or advertiser’s restricted Pal Vault advertising-credit balance for future eligible advertising, unless a different lawful disposition was expressly disclosed and accepted before activation. Performance above the stated maximum does not create additional reward obligations beyond the funded allocation and disclosed campaign terms.
23.10 Allocation cap and reconciliation
Spark rewards and valid promotional commitments must not exceed the available 90% promotional allocation unless the merchant expressly authorizes and funds an additional amount. Settlement credit is calculated as: 90% of the Spark Amount minus valid rewards and commitments and any separately disclosed, lawful adjustments, with a minimum of zero. No amount already validly earned by a user may be double-counted as merchant advertising credit. Refunds, reversals, disputes and fraud investigations may require subsequent corrections with an auditable transaction history.
23.11 Advertising credit in Pal Vault
Unused Spark allocations credited to the merchant’s or advertiser’s Pal Vault are restricted advertising credits, recorded separately from ordinary cash, cashout balances, marketplace earnings, and consumer rewards. They may be applied to future eligible PalKeeper advertising expenditure. Any credit expiration, transferability, account closure treatment, or other restrictions must be disclosed before funding and comply with applicable law. Credit is not automatically withdrawable as cash.
23.12 Reporting, integrity and disputes
Following completion and reasonable validation, PalKeeper will make available a campaign settlement summary identifying the Spark Amount, 10% platform allocation, 90% promotional allocation, selected footprint range, measured reach and footprint, valid promotional obligations, adjustments and credited advertising balance, as applicable. PalKeeper may review suspicious traffic or reward claims and correct material measurement errors. Advertisers may dispute material settlement discrepancies through the available support process. This section does not limit non-waivable rights.