- 4/17/2025
Sensitive Categories
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FunTranscript
00:00Okay, guys, we're going to kick us off. Happy Tuesday, everyone. Welcome. Thanks for tuning
00:06in this week and welcome to today's Tuesday training session. Today, we're talking about
00:11advertising with sensitive categories and we're going to focus the conversation on our third
00:18party policies. Now, I'm personally happy we're talking about this today because it's something
00:23I get a lot of questions around and I rely on our teams who are always up to date on all of the
00:29policy information. Now, policies don't always stay the same. So, we're going to make sure that
00:35any policy changes moving forward, we're going to keep you guys in the loop. And so, we're going to
00:39update everyone quarterly on all of these policies. Today, we have with us Anna Pavone, Digital Ad
00:46Operations Coordinator, Sam Grandy, Digital Marketing Coordinator, Trevor Adams, Director of
00:52Creative Services, Jennifer Williams, VP of Digital Marketing. And we're going to start by talking
00:58about the importance of all these policies. Then we're going to jump into audience extension
01:03and the content and landing page policies. Then we're going to go through creative policies and
01:09then finish off with additional items to look out for. Next slide, Kim. So, kicking us off with the
01:16importance of all the policies that we're going to go through today. Now, in digital advertising,
01:21its important and crucial quality control step is to audit content and creative. All ads go through
01:28an approval process to make sure they are safe and appropriate, aka they are FTC compliant. Any new
01:35ads or changes to existing ads are automatically submitted for review to make sure they abide by all
01:41the policies. Ads that violate these policies are marked disapproved or suspended and will not be able
01:48to run. Furthermore, if we did not have quality control to audit the creative and content, number
01:55one, it opens ourselves up to a lawsuit, as in Beasley. And we could have complete shutdowns for
02:01our third-party vendors. And it can severely impact all aspects of the advertiser's marketing efforts.
02:08Now, that's why it's so important for our advertisers to understand how vital it is to have an advertising
02:14partner like us that knows what they're doing. So, they are safe, we're safe, and it protects them all
02:21the way through their advertising. So, now I'm going to hand it off to Anna to go through content and
02:29landing page policy. Hi, everyone. I'm Anna. For those of you who don't know me,
02:35I am part of POT2. I do Tampa, Augustine Fert-Meyers, and I sit in Tampa. And I'm just going
02:45to be discussing some policies and categories to be on the lookout for when you're talking to advertisers.
02:51So, next slide, please. Cosmetic surgery. We cannot have any nudity in ads whatsoever. This includes
03:00midges, cleavage, etc. This ad right here would be approved. It does not violate any of that. We
03:07also have to look out for their landing pages. If there's a section on the landing page that includes
03:14nudity, we need an age gate up there for it to be approved. Or we have to remove the content
03:20completely. And this is for real-life photos as well as cartoon imagery. Okay, next slide, please.
03:27Sexually suggestive in gentlemen's club. Same thing here. We cannot have any nudity,
03:34such as cleavage, women, models wearing lingerie. We also can't have images that look like sexual poses
03:42or facial expressions. This ad, this brown girdle ad, we would not be able to run that because it's
03:50showing cleavage. However, the ad right next to it, that would be approved to run. We would just need to
03:56check their landing page to make sure they abide by the policies. No exposed midriffs. This one is a
04:04case-by-case basis. I included some ads on the bottom of the slide here. These were approved because
04:11it's more sports bra workout attire. So if you ever have an ad where it's an exposed midriff and you're
04:19not sure whether it would be approved or not, please send it to your PAW team. We will make sure to let
04:26you know if it's approved before we go into the final execution process. And for gentlemen's club,
04:33same thing. No nudity. It cannot be overtly pornographic. And the same applies for all landing pages.
04:40For medical campaigns, we can run all general medical campaigns. All tactics are allowed without
04:50restriction. We just have to be on the lookout for sensitive medical campaigns. For these topics,
04:57we can only run general keywords, general geofence locations, and we cannot site retarget off of that
05:05site. So sensitive keywords are anything with cancer, mental health, abuse services, anything that really
05:12falls under that sensitive category. Again, if you're unsure, please check with your PAW team first.
05:18And we do allow geofencing for condition-specific locations. This would include dentist offices, eye
05:28doctors. But again, we have to look out for those sensitive categories. Example, cancer, dementia,
05:35etc. Next slide. Addiction is another thing that falls under a sensitive category. An example of
05:44this ad, this would be approved to run. We would just need to keep the keywords general around wellness
05:51and healing. We can have keywords that's like drug addiction, alcohol addiction, that would be
05:56considered sensitive. And for geofencing, we can only do general fences such as hospitals and wellness
06:03centers. But it cannot be drug and alcohol related. Next slide, please. Sexual performance is another
06:12one as well. This is just an example. A client wanted to market all offerings but only focus on ED specific.
06:20They asked what could we run. So in this case, we could not do site retargeting because we cannot collect
06:26data off of users who go to a sensitive website or that has sensitive information. Keywords would have
06:34to be general. They would have to be around men's health and wellness. They could not be around ED specific.
06:42And the ads are a big thing here too. We have to make sure the imagery and the text on the ad
06:49is not speaking directly to these patients. Great. Next slide. I already touched on some landing page
06:59policies. These are just additional ones. For Facebook, we are always allowed to run a Facebook
07:06page as a landing page. So say we have a campaign where the something got flagged on the landing page,
07:13but it has to go live right then and there. We always have the option to drive to their Facebook pages.
07:18And I know some people don't have a website either. So this would be a good exception.
07:25Landing pages cannot direct to PDFs, just images or downloadable content. And they cannot contain
07:34content and imagery targeting children under the age of 13. This is a COPA violation. We can also not
07:42knowingly market or advertise the products to their rights to users under the age of 18. This is pretty
07:51self-explanatory. Alcoholic beverages, tattooing, body piercings. We just have to make sure that
07:58there's either an age gate or we're not knowingly marketing to those users. And then firearms. If we
08:06have a landing page that includes firearms, they cannot be pointed at the user viewing the content.
08:14A minor cannot be holding a firearm. And it cannot look like a firearm is pointed
08:19at a user or a target that resembles a person.
08:23So again, if you have anything in these categories, please reach out to your power teams prior to it
08:31getting to execution. We just want to make sure everything's approved or we will find an additional
08:37method. And with that, I will hand it off to Trevor.
08:42Thank you very much. So let's talk about images and specifically images that are used for creative
08:52and editorial purposes on the Beasley platforms. As you may or may not know, we currently partner with
08:58two third-party vendors for image use. Those two vendors are Shutterstock and Getty. I'll be covering
09:05our licensing with Shutterstock and then passing it over to Jennifer for the Getty portion. With our
09:11current license with Shutterstock, it allows us to use their images for advertising, editorial,
09:17and content creation. Where our Getty license only covers editorial usage. Let me repeat that again.
09:24Our Getty license only covers editorial usage. As far as the Shutterstock license goes, the major
09:32points to take note are, and there are a lot of them here, but the images cannot be used in any way
09:38that a reasonable person would find offensive, including pornography, adult videos, adult
09:44entertainment venues, escort services, or similar advertisement or promotion of tobacco products,
09:51vape or e-cigarette products, endorsing a political party, candidate, elected official, or opinion,
09:59and suffering from or medicating for a physical or mental ailment, engaging in immoral or
10:06criminal activities. The Shutterstock images cannot be used in a way that may be perceived
10:13as deceptive advertising or unfair competition. Another big one is we cannot resell, redistribute,
10:22or sub-license the images in any way. So the next one on the list here has been brought to my attention
10:29a number of times lately. However, we cannot provide any image or any of the Shutterstock images to our
10:37clients to be used outside of the original scope of the agreed upon project. That goes for print and
10:44digital. And what that means is if our client and us have gone into an agreement to do a digital ad,
10:52we cannot provide that client with the Shutterstock image to be used outside of our platforms on,
10:58let's say, a print ad. It has to remain within the digital realm. So that being said, it can be used
11:05on different platforms in digital and the original ads that we created. They just cannot take that image
11:10and use it in a different way. So we can actually provide our digital images to that platform, but if
11:17they want to use that image outside, they're going to have to go and re-license it on their own.
11:22So the next one is also a big one and probably the toughest for designers within our company
11:29to digest, but we cannot use any part of an image back there or digital for from Shutterstock for a
11:38trademark service logo or service mark. I always say that creating logos is the toughest part of a
11:47designer's job. And this is exactly the reason why we cannot use the images off of Shutterstock to
11:53create the logos. So every time we're doing something, we're making an adjustment to a logo
11:57that's been asked to be created. We have to do that. It's an original design from our designers. So when
12:04you guys request logos on your end, keep that in mind that when we do those, they're completely original.
12:10So at this point, I would like to pass it over to Jennifer to review the Getty side or the Getty
12:17license. Thanks, Trevor. I think that at the end of the day, the most important thing you've already
12:24stated is that our Getty license is strictly for editorial use. Editorial use by your local digital
12:33program director to create editorial content, your local air staff to create the editorial content that
12:38they're creating. We have a specific license with Getty. And there are many other different licenses and
12:47additions that you can add to your license suite. Ours, again, only for editorial. The big thing,
12:53the big takeaway is that if the content that is being created is sponsored, we cannot use a Getty image for
13:00it. It's pretty much as simple as that. But the caveat is, there is a caveat. We can license image
13:09from Getty for your clients and for the ad campaigns. We would just need to purchase a specific license and
13:17go through clearances, rights and clearances to do that. There is a specific division that we have
13:24access to within Getty that sells those licenses. So we recently did a wonderful webinar from the two
13:32women who run their copyright infringement department and rights and clearances departments. We have access
13:42to that. Actually, we'll make that available on the Beasley Academy. The last section of that webinar
13:47speaks specifically to a potential use case that you all may have, which is, again, going through rights
13:53and clearances to purchase a Getty licensed image. The rate for those ranges. So we would have to take
14:00it on a case-by-case basis. The notes that you see in the slide that you'll get on the deck afterward
14:06really designed for the digital program directors to use when building editorial content. But again,
14:13you'll notice the third point. We don't have any access to utilize those images for commercial use.
14:21Trevor, any other questions on this? So let's just keep that in mind that Shutterstock is to be used for
14:29the ad creation, Getty, editorial only. And please note that we need to use attribution if using Getty.
14:40Can you go to the next slide, please? I just wanted to point out a couple of things when a client is
14:46providing an image to us. The number one thing to look at here is if there is a copyright notation on the
14:53image. I've asked my team to be extra vigilant to look for these things, but if we do notice that
15:01there's a copyright label or watermark on the image, we need to get in writing an indemnification note
15:09from the appropriate person on their side to give to our legal team. We have to be completely in the
15:15clear if we're using anything with a copyright image. The other thing to look at here is, and I've seen
15:20this a number of times, if there's any watermarking from any of the image subscribers such as Shutterstock,
15:28Getty, there is a new way within Photoshop to completely take that off. And what I wanted to
15:34show you here is, you know, this is pretty basic on one side where Shutterstock is pretty blatant in
15:40your face. On the next slide over here, Shutterstock, somebody has tried to take Shutterstock off.
15:47So there's just a little bit of remnants of the watermark there. But within the newest version of
15:54Photoshop, you can completely remove those. So we need to be extra vigilant with that. So on to the next
16:00slide, please. Speaking of being vigilant, there has been a number of lawsuits and infringements that have
16:12been happening lately with the radio companies and general media companies. And Jennifer, I want to just,
16:19I want to kick this to you for a minute. How many weekly infringement letters do you think you're seeing
16:26on the content side? So I will, thank you. And I will say that there are, we probably don't go a month without
16:32getting three to four copyright infringement notifications. So without getting too in the
16:40weeds, Trevor and I have talked about this, and I'm sure many of you have talked about this internally,
16:44there's metadata that's in every image. And that metadata is also indicates who owns the rights to the
16:53image or has information to that extent. There are bots and spiders that crawl the internet,
17:02looking to confirm and people will hire companies to, we've actually looked at contracting with one
17:07of these companies in the past, to literally crawl the internet and look for use cases of
17:12copywritten images. And then, as you'll see on the great slide here, that there are firms who are out
17:18there sending these letters out. In addition, there's also private photographers who make a living
17:23selling their photography, whose copyrights are potentially being infringed upon, who also reach out
17:28to us and many other companies and media companies. So we probably get, you know, again, I know we don't
17:35see all of them, Eric and I don't see all of them, but I'm going to say in a good month, we're probably
17:39getting, you know, three notices a month. And they can be from content that was produced yesterday.
17:50And here's the beautiful thing, they can also be from content, as Kimberly's on the call,
17:53she knows, that was produced five years ago, that just happens to get uncovered today.
17:59And then you're getting a letter, you're going to have to supply every page view that was associated
18:03with that image. And then that's with the font, the, um, either a lawsuit would be, uh, which is
18:09the worst case scenario, or you're just asked to pay, um, a substantially large amount of money
18:15for having that on your site or app or app. So, um, I think Trevor, the most important thing that we
18:22always talk about, and it's good to share this with you guys is that we, this, we get these invoices
18:27and fines and bills. We have to pay literally a couple of times a month across our company.
18:33It's not unusual. We're not being picked on. It happens every day. Um, it's a reality that you
18:39guys, and you guys have so many other things on your plate. You're not hearing about that all the
18:42time, but just know that it is happening. So there is revenue that is not budgeted for going that we
18:47are spending. There's money that we're spending. It's not budgeted for to pay for fines on a monthly
18:52basis. And those fines go to the local market, right? Jennifer, I mean, it's built back, right?
18:56It's built back to the local market. So it does hit the local markets, uh, budgets there.
19:02And in Kimberly, it's not just the fine when we have to contract with outside attorneys.
19:07Yes. That also gets built back.
19:09Yes. Most of this is done through contracting with outside. We have to negotiate through outside
19:13attorneys. So again, not ominous. This, this isn't meant to be like, Oh no, I can't do anything.
19:19You absolutely can. We just need to take that extra step. Again, with Getty, if it's Getty,
19:23we just need to get the, we have to get the right, the right license with the image and use it. And
19:28we'll use it in good health and coverage. And we've had instances, Trevor with you specifically,
19:31I know with Shutterstock where we used an image correctly. We had the right license. We were
19:37supposed to, we did everything right and Shutterstock covered us for it and took care of it. So again,
19:42this just kind of is those things as we rush and try to get stuff done. Sometimes we, um, we'll go,
19:48why I was probably just fine. Just always double check, make sure that the, you have the right
19:52license using the, you've covered up all of the exact things that, um, Anna went through that
19:58we're, uh, that we're not looking at anything that doesn't fit the ad descriptors or the denied or the
20:03wrong type of, uh, imaging for ads. And that we have license to use it in that manner.
20:08And please be aware, every, everything from as little as a logo download off the internet,
20:14we really need to pay attention to that stuff. So what I ask is that you do not download any images
20:21from the, from websites or online, and you ask the client to provide those. I think that will be the
20:27biggest saving factor for us and things like this. Okay. Uh, I think that's, that's it for our part.
20:37Anything else you want to add, Jennifer? Nope. Okay. Great. Thank you guys. Thank you guys.
20:44Now we're going to go and hear from Sam. Hello. Okay. So hi, I'm Sam Grandy. I'm, um,
20:53on the corporate digital team. I'm a part of pod one and kind of pod three now actually. Um, and I'm just
20:59going to go over a couple additional things to look out for when it comes to sensitive categories.
21:04Um, so COPA violation. So I know this was touched on a little bit earlier. Um, but a COPA stands for
21:13the Children's Online Privacy Protection Act. And it's intended to protect children under the age of
21:1913 from online data collection without parental consent. So most of you already know this already,
21:26but we don't allow any data collection or ads specifically targeted at children under the age of 13.
21:31Um, examples where this policy applies includes the ads, the keywords, landing page, and location
21:39eligible for geo-fencing. So that's going to be schools under the age of high school, public parks,
21:46toy stores, just really any place that has majority of children under the age of 13.
21:53Um, and so I wanted to show you guys a little example on the right, right here. So we run into
21:59this from time to time. Um, if a high school is connected to an elementary or middle school,
22:06like mine was growing up, um, we would not be able to geofence that high school because we can't
22:12determine what the shared space is. Um, but you'll see in this scenario, the high school and the middle
22:19school are not connected. One is across the street from the other one. Um, so we can just geofence
22:26that high school and that would be allowed. Next slide, please.
22:34Okay. Proper brand notification. So proper brand notification is required on all ads. Um, this is
22:41important because we need to let the user know where these ads are coming from. So you must state the
22:47advertiser's name or include the advertiser's logo to have that proper brand notification.
22:53So I wanted to show you a little example over here. So this first ad was disapproved because it did not
23:01state, um, where the ad was coming from. So it didn't have the Genesis name or the Genesis logo.
23:07Um, and this is how we fixed it. We literally just put the Genesis logo on the ad and it has proper
23:13brand notification now. Next slide, please. Okay. Political advertising. So political advertising,
23:24um, you know, includes any political organizations, parties, political issues, um, individual candidates
23:32or politicians. And we just want you guys to keep in mind a couple of things when you are pitching
23:38these types of clients. Um, so we can't do any attack ads directed at individual candidates. I'm
23:45sure you guys are seeing a lot of those now on your TV and we are not allowed to do that. Um,
23:51all ads must state a disclosure that identifies who is paid for the ad. So if you're wondering what
23:58that looks like, um, I added it on this or it's on this example right here where it says paid for by
24:03Lynn Gray. Um, and that would go, that would be the same if we were running a video ad as well.
24:10Um, campaigns related to ballot measures and candidates for state and local elections in
24:15the following states are prohibited. And that's going to be in Maryland, Nevada, New Jersey,
24:21and Washington. We cannot do any political advertising in Canada and state and local
24:28political advertising in California and New York requires approval, um, before we run those ads.
24:34So again, if you guys ever have any questions, just please send them to your designated pod so we
24:40can check it. Um, so we don't run into any delays when we're getting these campaigns live.
24:46And that is it. Great. Thank you, Sam. We want to make sure we touch on marijuana and CBD,
24:54especially CBD right now. There's a lot of buzz around advertising CBD currently any ads or campaigns
25:00need to be approved by the Beasley's legal team. Now we know this doesn't scale. So we are working
25:07currently with our legal team to define rules for advertising. So we all know what we can and cannot
25:12do. We just need to make sure that we are in compliance with our FTC license, even when it comes
25:17to our third party policies. So more to come on this, we will have, uh, all of the information
25:23for you guys to know what we can and can't do here. In conclusion, we just want to make sure
25:30you guys understand how crucial it is for an organization to keep this top of mind to protect
25:35ourselves and then also to protect our advertisers. And it's also so important for the advertisers to know
25:42that they need to work with a reputable company like us to be able to make sure that they stay
25:47compliant. We will update you guys quarterly on any new policy changes that come into effect. And if
25:53it's a big policy change, we'll get it to you guys right away. And when in doubt to just check with the
25:59pods and the creative teams, if you have any questions before the sale, just so you guys could stay on top
26:04of it. And that's what they're there for. So don't hesitate to do that. We did have a question that came
26:11in that I want to address real quick. Does geofencing hospitals violate any HIPAA or any state or federal
26:19laws? And so we had Luke and Anna share some insight here. The way our vendor puts it in is that there's
26:26no HIPAA violations around the way they geofence, but they are, they have restrictions based on not
26:30wanting to infringe on people's data, morality, and most, if not all companies follow these similar
26:36guidelines. We can geofence hospitals as long as it's not a diagnosis specific hospital that falls
26:43under a sensitive topic. So I hope that answers your question. If you have further questions here,
26:50don't hesitate to reach out or on anything else as well. Okay guys, no more questions. So that's all we
27:00have today. Look out for the email tomorrow with the link to the recording, as well as the Finish Strong
27:07Friday email that goes out Friday morning with the topic we'll have for the next session, which is in
27:13two weeks from today. And that's it. Thank you guys so much for joining and we'll talk to you guys soon.
27:19Take care. Bye-bye.
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