Clearenta Publisher Advertising Policy

DRAFT — PENDING LEGAL REVIEW Clearenta Publisher Advertising Policy Version: publisher-advertising-policy-draft-2026-10-11-v1 Draft date: October 11, 2026 This draft policy describes advertising standards for approved Clearenta affiliates. It is not effective and must not be used for live recruitment until approved by Clearenta and legal counsel. 1. Approval is required All channels and material creative require Clearenta approval before use. Paid advertisements, landing pages, advertorials, and materially revised creatives require specific preapproval. Approval may be limited by channel, campaign, audience, geography, dates, or creative version. 2. Potentially permitted channels Subject to written or recorded approval, Clearenta may permit: - Content websites and editorial placements - Organic search and SEO - Organic social media - Approved paid search - Approved paid social - Other channels explicitly approved by Clearenta 3. Truthful claims Advertising must be accurate, substantiated, clear, and consistent with Clearenta's current public disclosures. Affiliates must not make misleading savings or debt-elimination claims; promise approval, qualification, settlement, savings, timing, or results; imply government affiliation; disguise advertising as independent editorial content; or omit material limitations. 4. Identity and brand Affiliate must accurately identify its role and may not impersonate or misrepresent Clearenta, CuraDebt, another provider, a lender, a law firm, a government program, or a nonprofit. Unauthorized trademark bidding, confusing domains, altered brand assets, third-party logos, endorsements, or implied partnerships are prohibited. 5. Email, SMS, and telemarketing Email and SMS promotion is prohibited unless Clearenta gives channel-specific written approval after reviewing consent, suppression, identification, opt-out, and recordkeeping controls. Purchased lists without adequate authorization, robocalls, prerecorded solicitations, unlawful automated messaging, and unlawful telemarketing are prohibited. Clearenta's transactional OTP consent is not affiliate marketing consent. 6. Traffic integrity Bots, click fraud, fabricated information, cookie stuffing, forced clicks, misleading redirects, unauthorized incentives, self-referrals, duplicate manipulation, and concealment of traffic sources are prohibited. Affiliate must disclose material sub-publishers and may not broker or resell access without approval. 7. Testimonials and endorsements Testimonials and endorsements must be genuine, authorized, representative or appropriately qualified, and accompanied by clear disclosures of material connections. Affiliates must comply with current FTC endorsement guidance and must not use fabricated reviews or atypical results without clear context. 8. Privacy and consent Affiliate must publish accurate privacy disclosures, minimize data collection, secure information, honor applicable privacy rights, and obtain channel-specific consent where required. Consumer personal information must not be placed in Clearenta tracking URLs. Affiliate may direct consumers only to approved Clearenta pages and may not collect information on Clearenta's behalf unless separately authorized and reviewed. 9. Debt-relief advertising Advertising must not imply that Clearenta provides debt-relief services, guarantees a provider connection, or determines qualification. Debt amount is only one factor. Affiliates must use required disclosures and comply with applicable federal and state advertising, telemarketing, and debt-relief requirements. 10. Transparency and monitoring Affiliate must disclose traffic sources, placement URLs, targeting, material edits, and requested performance records. Clearenta may investigate complaints and suspicious traffic, require correction or removal, disable a campaign, or suspend Affiliate. Approval evidence and the exact reviewed creative should be retained according to the approved retention policy.