Advertising & Brand-Safety Policy

1Purpose and scope

1.1This Advertising & Brand-Safety Policy (the “Policy”) sets out the standards that Mine Marketing LTD, an Israeli company whose registered address is 28 HaArba'a St., Tel Aviv-Yafo 6473925, Israel (“Mine Marketing”), applies to the advertising it plans, creates, reviews, places and monetises.

1.2It applies to every campaign that Mine Marketing runs for a Client on any Platform; to every Owned Property, including search-arbitrage properties, and the campaigns that buy traffic for them; to every Ad and Landing Page that Mine Marketing creates, reviews or places, whoever supplied it; and to Mine Marketing’s employees and contractors, the Agents and every supplier or partner acting for Mine Marketing (each a “Representative”). It does not govern AdsBuzz at ads.buzz, which has its own policies.

1.3This Policy is read with the Responsible AI Policy and the Privacy Policy. Where a Platform or Partner policy, a Client’s rules or the law is stricter, the stricter standard applies. An Agreement may add to this Policy but does not relax it.

2Definitions

2.1In this Policy, “including” means “including without limitation”, and:

Account Lead

The named person at Mine Marketing who is accountable for a Client account and for every Agent action on it.

Ad

Any advertisement, including its text, images, video, audio, links and targeting, in any format.

Agents

The AI agents that Mine Marketing operates on one data layer: the Opportunities Researcher, Creative, Optimization and Scaling agents, and the ad-review agent (the “Ad-Review Agent”).

Client

A business that has signed a written agreement for services with Mine Marketing (an “Agreement”, which includes any document made under it).

Exclusion Lists

The sites, apps, channels, placements, keywords and content categories, maintained for each Client, on or next to which its Ads must not appear.

Invalid Traffic

Clicks, impressions, visits or conversions that do not come from a real person with genuine interest, including bot, synthetic, incentivised and fraudulent traffic.

Landing Page

Any web page or app destination to which an Ad leads, and the pages of the same journey.

Operating Mode

The mode agreed with a Client for its account (Supervised, Guardrailed or Fully autonomous) that determines which changes the Agents may apply without a person’s prior approval, as described in the Responsible AI Policy.

Owned Property

A website that Mine Marketing operates itself, including one monetised with licensed search and native feeds (search arbitrage).

Partner

A provider of licensed search or native feeds carried on an Owned Property, or another partner through which Mine Marketing monetises traffic.

Personal Data

Any information relating to an identified or identifiable individual, including “personal information” as defined in the data-protection laws that apply.

Platform

An advertising platform on which Mine Marketing buys media, such as Google Ads, Microsoft Advertising, Meta, TikTok, Snapchat, Pinterest, YouTube, X Ads, ChatGPT Ads, Reddit Ads, LinkedIn Ads, Amazon Ads, Apple Search Ads, Yahoo, Taboola and Outbrain.

Policy Checks

Platform and Partner policies, each Client’s brand-safety rules and each account’s hard limits, encoded as checks that run outside the models.

3Principles

3.1Mine Marketing’s advertising is lawful, complying with the law of each market and the policies of each Platform and Partner; honest, being truthful, substantiated and not misleading by statement, omission or design; transparent, identifying the advertiser and showing Platforms, Partners and reviewers exactly what users see; safe, neither harming, exploiting nor discriminating against people, nor appearing where a Client has excluded it; and accountable, with a named person responsible for every account and every change recorded.

4Compliance with Platform policies and the law

4.1Mine Marketing complies with the advertising policies, terms, community standards and editorial requirements of every Platform it uses and every Partner whose feed it carries, as updated from time to time, and updates the Policy Checks when they change.

4.2Mine Marketing complies with the advertising, consumer-protection, data-protection and sector law of each market in which an Ad runs, including, as they apply, Israel’s Consumer Protection Law, 5741-1981, the EU Unfair Commercial Practices Directive (Directive 2005/29/EC) as implemented in each Member State, the consumer-protection law of the United Kingdom and Switzerland, the advertising codes administered by the UK Advertising Standards Authority, the Federal Trade Commission Act and the consumer-protection and advertising laws of the states of the United States.

4.3The Agents act on Platforms only through official APIs. Mine Marketing does not scrape Platforms, use unofficial automation or work around Platform limits; where no API exists, a person makes the change. An Ad that a Platform rejects is corrected or appealed through the Platform’s official process, never resubmitted unchanged or disguised.

5Prohibited content and practices

5.1Mine Marketing does not create, place or monetise any Ad, Landing Page or Owned Property that contains or promotes:

1. products or services that are illegal in the market concerned, and dangerous products or services, such as weapons, explosives or recreational drugs, that the law or the Platform prohibits;
2. deceptive or misleading claims, including unsubstantiated results, fake reviews or testimonials, and get-rich-quick, pyramid or similar schemes;
3. false urgency or scarcity, such as fake countdown timers or stock levels;
4. impersonation of any person, brand or authority, or a false affiliation or endorsement;
5. counterfeit or infringing goods or content;
6. malware, phishing, unwanted software or code that harms users or collects data without their knowledge;
7. sexually explicit or adult content;
8. hate speech, harassment, threats, or shocking or graphic violence;
9. misinformation, including false claims about health, elections or public safety; or
10. content that exploits or endangers minors, exploits tragedy or vulnerability, or asserts knowledge of a person’s sensitive characteristics.

5.2Mine Marketing does not engage in, or permit any Representative to engage in, cloaking (showing a Platform, Partner or reviewer content different from what users see); circumvention of review, including post-approval changes, evasive redirects or hidden text; account farming, renting or borrowing, or opening accounts to evade a suspension; buying or generating fake followers, likes, reviews or other engagement; any other evasion of a policy or enforcement action; or the buying, selling or generating of Invalid Traffic.

6Restricted categories

6.1The following categories are advertised only where the Platform permits them, with every Platform authorisation or certification required, where the Client holds every licence required in the market, and in compliance with that market’s content, disclosure and targeting rules:

1. financial services and credit, with the cost, risk and regulatory disclosures that apply;
2. insurance, stating the insurer’s or intermediary’s identity and status where required;
3. health, with no claim that is unsubstantiated or, where approval is required, unapproved;
4. education, with no misleading claim about accreditation, outcomes or earnings;
5. alcohol and gambling, only to adults, only for licensed operators where a licence is required, and with the warnings the law requires;
6. political, electoral and social-issue advertising, only where the law and the Platform permit it, after the Platform’s authorisation process and with the required disclosures; and
7. any other category that a Platform or the law restricts, such as crypto-assets, prescription medicines, weight loss or dating, on the same conditions.

6.2Where a Platform designates special ad categories, such as Meta’s special ad categories for credit and financial products and services, employment and housing, Mine Marketing declares the category, accepts its targeting limits and does not use look-alike audiences, exclusions or proxy attributes to recreate the targeting those limits remove.

7Claims substantiation and disclosures

7.1Every objective claim, including claims about price, savings, results, ratings and comparisons, is substantiated before the Ad goes live. The Client supplies substantiation for claims about its own products, and Mine Marketing keeps it with the account records.

7.2Comparisons are like for like and state their basis. Testimonials reflect real customers’ genuine experience, and any material connection with the advertiser is disclosed. Prices and offers state their material conditions clearly and close to the claim; a third party’s reported result is attributed to its source.

7.3Every Ad identifies the advertiser and is recognisable as advertising; sponsored, native and affiliate content is labelled as the law, Platform or Partner requires.

8Landing-page standards

8.1Every Landing Page and Owned Property that Mine Marketing builds, places or monetises must:

1. work on desktop and mobile and deliver what the Ad promotes, on the terms the Ad states;
2. identify the business responsible and give a working means of contact;
3. publish a privacy policy and obtain consent for non-essential cookies where the law requires;
4. use no misleading interface, such as disguised ads, fake warnings or close buttons, or pre-ticked consent;
5. make no automatic redirect, pop-under or forced download;
6. contain no malicious or unauthorised code; and
7. load promptly over HTTPS and be kept secure and up to date.

8.2Mine Marketing checks each Landing Page against these standards before an Ad is directed to it and during the campaign, and does not direct, or continue to direct, an Ad to one that does not meet them. On the Owned Properties, consent for cookies and similar technologies is managed as the law of each visitor’s market requires.

9Creative review

9.1Every Ad and Landing Page passes the Policy Checks before it goes live. The checks sit outside the models the Agents use, so that no model can override or disable them.

9.2The Ad-Review Agent reviews every image and video Ad against Platform policy and the Client’s brand-safety rules before launch and throughout its rotation, and stops or flags any Ad that no longer passes.

9.3A person gives every new Ad and Landing Page a final review before it goes live. No Agent publishes a new Ad or Landing Page on its own authority, in any Operating Mode. Doubtful cases go to the Account Lead and do not go live until resolved. A Platform’s approval does not replace this review.

10AI-generated and altered content

10.1Content generated or materially altered by AI is disclosed, labelled and marked as each Platform’s rules and the law require, including, where it applies, the EU Artificial Intelligence Act (Regulation (EU) 2024/1689).

10.2Mine Marketing does not use synthetic media to deceive, such as to depict events that did not happen, fabricate testimonials or exaggerate results, and does not use a real person’s name, likeness or voice without that person’s documented permission.

10.3Before AI-generated content is used, the reviewer checks that it does not copy or imitate another’s protected work or trade mark and that all third-party elements are licensed for the use.

11Targeting and data

11.1Mine Marketing does not target or exclude people on the basis of a protected characteristic in a way that is unlawful, discriminatory or contrary to Platform rules.

11.2Ads for age-restricted products are not targeted at minors, use the Platform’s age controls and are not placed in content directed at minors. Mine Marketing does not knowingly use the Personal Data of children to target Ads, and applies each Platform’s restrictions on advertising to people under 18.

11.3Personal Data is used for targeting and measurement only through Platforms’ official tools, under each Client’s Agreement and instructions, and in accordance with the applicable data-protection laws and the notices and consents the Client provides. Sensitive data, such as health, financial hardship, religion, sexual orientation or political opinions, is not used to target individuals unless the law and the Platform expressly permit it and the required consent has been obtained.

11.4A Client’s customer list or other first-party data is uploaded to a Platform only where the Client confirms that it has the lawful basis, notices and consents the upload requires, only through the Platform’s official tools (with the hashing or matching protections they provide), and only for that Client’s campaigns.

12Brand safety and suitability for Clients

12.1For each Client, Mine Marketing agrees and maintains Exclusion Lists, excluded content categories, placement and keyword (including negative-keyword) exclusions, the Platform’s suitability settings, and any further rules in the Agreement. The Agents enforce them as Policy Checks across all of that Client’s campaigns, and they change only with the Client’s agreement, with each change logged.

12.2Mine Marketing monitors placements and search terms, removes any Ad found in an excluded or unsuitable placement and adds that placement or term to the Exclusion Lists. Neither Mine Marketing nor any Platform can guarantee that an Ad will never appear next to unsuitable content; Mine Marketing’s commitment is to apply the settings, monitor and act promptly.

13Traffic quality

13.1Mine Marketing runs one account per Client: each Client’s campaigns run in advertising accounts dedicated to that Client’s business alone, and Mine Marketing never mixes Clients’ campaigns, budgets or data in one account.

13.2Mine Marketing does not use cloaking, and does not buy, generate or send incentivised, synthetic or bot traffic or any other Invalid Traffic.

13.3Traffic is bought only through Platforms’ official channels, and its sources are disclosed to Partners. Mine Marketing monitors for Invalid Traffic, excludes sources that show it, reports confirmed Invalid Traffic to the affected Client, Platform or Partner, and cooperates in good faith with any Platform or Partner investigation, subject to its confidentiality obligations and the law.

14Search arbitrage

14.1Mine Marketing operates Owned Properties monetised with licensed search and native feeds, each carried under a valid agreement with the Partner or an authorised intermediary, and run to each Partner’s traffic-quality, placement, labelling and query-handling rules. In particular:

1. queries come from users, or from suggestions the user chooses as the Partner permits, and are never generated automatically;
2. paid results are clearly labelled and distinguishable from content;
3. Ads that lead to an Owned Property describe it accurately, and it provides genuine content;
4. traffic stays within the sources each Partner has approved;
5. no page, layout or prompt is designed to mislead users into clicking; and
6. no one acting for Mine Marketing clicks, or asks or rewards anyone to click, Partner ads, and Partner results are not altered, framed, obscured or reordered except as the Partner permits.

14.2Mine Marketing keeps records of the traffic sources for each Owned Property and provides them to a Partner as its agreement requires.

14.3Where a Partner raises a quality concern about a traffic source, Mine Marketing stops that source until the concern is resolved.

15Intellectual property and trade marks

15.1Mine Marketing uses only material that it or the Client owns or is licensed to use, and keeps a record of third-party licences. It does not use another’s trade mark in an Ad, keyword or Landing Page in a way likely to confuse or suggest a false affiliation, or contrary to Platform trade-mark policy. A competitor’s trade mark is bid on as a keyword only where the law and the Platform allow it and the Client has agreed.

15.2A rights holder may report an infringing Ad under Section 19; where the claim appears well founded, Mine Marketing pauses or changes the Ad.

16Clients’ responsibilities and Mine Marketing’s rights

16.1Each Client is responsible, as its Agreement sets out, for the lawfulness of its products and services; for holding every licence, registration and authorisation they require; for the accuracy of the information, claims and substantiation it supplies; for the Landing Pages and data it controls; and for the notices and consents that its own collection of Personal Data requires.

16.2Mine Marketing may decline, pause or remove any Ad, Landing Page, keyword, placement, product or campaign that it reasonably considers would breach this Policy, a Platform or Partner policy, the Client’s Agreement or Exclusion Lists or the law, and tells the Client promptly when it does so. It does not place an Ad that it knows or reasonably suspects to be unlawful. A Platform’s or Partner’s enforcement decision binds the account concerned, and Mine Marketing does not try to avoid it other than through the official appeal process.

17Suppliers and partners

17.1Every Representative that creates, reviews, places or sends traffic to Ads, Landing Pages or Owned Properties is bound by written terms to comply with this Policy. Mine Marketing assesses such suppliers before engaging them, monitors their work, and suspends or ends an engagement for breach.

18Monitoring, incidents and remediation

18.1Mine Marketing monitors live Ads, Landing Pages, placements, search terms and traffic through the Agents, Platform reporting and its staff. Where any of them is found or reasonably suspected to breach this Policy, a Platform or Partner policy, a Client’s rules or the law (an “Incident”), Mine Marketing will:

1. pause or remove it without undue delay;
2. correct the cause, with a person’s review, before anything is relaunched;
3. notify the affected Client within one business day of confirming the Incident, and the Platform or Partner where its policy or the law requires;
4. identify the root cause and update the Policy Checks, Exclusion Lists, procedures or training; and
5. record the Incident, the actions taken and the outcome.

18.2An Incident involving Personal Data is also handled under the breach procedure in the Privacy Policy and the Agreement.

19Reporting concerns

19.1Anyone may report an Ad, page or practice that they believe breaches this Policy to team@mine-marketing.com with “Brand safety” in the subject line, saying what was seen, where and when, with a link or screenshot where possible.

19.2Mine Marketing acknowledges each report within five business days, investigates it and acts under Section 18 where it is confirmed. It does not retaliate against anyone who reports a concern in good faith.

20Accountability and records

20.1The Account Lead is accountable for applying this Policy to each Client account and gives sign-off where the Operating Mode requires it.

20.2Every change to an account, by a person or an Agent, is logged with its reason, the limit checked, the approver and the previous value, so that it can be reviewed and, where the Platform allows, rolled back. Each Platform’s own change history is a further, independent record.

20.3Change logs, review records, substantiation and Incident records are kept for the duration of the Agreement and 24 months after it ends, unless the Agreement or the law requires otherwise. Staff who work on advertising are trained on this Policy and the relevant Platform policies on joining and at least annually.

21Review and contact

21.1Mine Marketing reviews this Policy at least every 12 months and whenever a material change in the law, a Platform or Partner policy or its services requires, and publishes the current version on this page with its last-updated date.

21.2Questions about this Policy should be sent to team@mine-marketing.com with “Brand safety” in the subject line, or by post to Mine Marketing LTD, 28 HaArba'a St., Tel Aviv-Yafo 6473925, Israel.