I. Definitions

Express Advocacy means paid-for communications that unmistakably urge the election or defeat of one or more clearly identified candidate(s) for federal or certain Statewide Election. For instance, advertisements that expressly state whether to vote for or against a candidate (e.g., “Vote for Joe Smith for Governor!”) are Express Advocacy. 

Personally Identifiable Information or PII means information about a specific individual including name, address, telephone number, and email address—when used to identify a particular individual.

Political Figure means current and former elected officials at any level of government, political appointees, members of their staffs, and any family members of the aforementioned.

Political Advertising means a Client’s use of the Services to engage in Express Advocacy.

State Authority means government bodies and institutions.

State-Owned Media means entities controlled and/or financed by government or State Authorities.

Statewide Election means state elections involving candidates for governor, lieutenant governor, secretary of state, treasurer, or state attorney general.

II. Political Advertising Requirements

Compliance with BroadProximity, LLC. Terms and Policies. Clients must comply with this Policy, the applicable terms and conditions between Client and BroadProximity, LLC. and other BroadProximity, LLC. policies, as applicable, when engaging in Political Advertising.

BroadProximity, LLC. reserves the right, in its sole discretion, to refuse to implement any campaign for any reason, including, but not limited to, the fact that the campaign is controversial, intimidating, or harassing; violates BroadProximity, LLC.’s policies; and/or may affect BroadProximity, LLC. or its affiliates’ brand(s). BroadProximity, LLC. also reserves the right, in its sole discretion, to review any campaign at any time and/or terminate it at any time.

Recordkeeping. Client must maintain the records and information described below for any Political Advertising campaign. BroadProximity, LLC. may request any of the information listed below before or after approving any Client for Political Advertising.

• Name of political advertiser (if different from client);
• Name of candidate referenced in Express Advocacy;
• Examples of creative messaging used in the advertisement(s) (or, upon BroadProximity, LLC.’s request, all of the creative messaging used in the advertisement(s));
• A telephone number, physical address, web address, or alternative reliable contact information for the political advertiser (if different from the client);
• The names of the Chief Executive Officer(s), member(s) of the Executive Committee, member(s) of the Board of Directors, and/or Treasurer of the political advertiser (if different from the client).

Consumer Permissions. For any Client campaign targeted based PII, Client must obtain all necessary permissions to use (and for BroadProximity, LLC. to use) the data for Political Advertising. Compliance with All Applicable Laws. When engaging in Political Advertising, Clients must use the Services in compliance with all applicable federal, state, and local laws.

• In the states of Maryland, Nevada, New Jersey, and Washington, advertisements related to ballot measures and candidates for state and local elections are not permitted. Beginning January 1, 2020, advertisements related to ballot measures and candidates for state and local elections in California are not permitted.
• In the state of New York, independent expenditure committees that wish to engage in advertising campaigns related to ballot measures and candidates for New York state and local elections must: (1) inform BroadProximity, LLC. that they are independent expenditure committees; and (2) submit a copy of the registration documents they have filed with the New York State Board of Elections to BroadProximity, LLC..

Disclosures and Disclaimers. Clients must comply with the all of the DAA Self-Regulatory Principles including the DAA’s Application of the Self-Regulatory Principles of Transparency & Accountability to Political Advertising (the “Political Advertising Principles”).

Client must make all disclosures and disclaimers as required by the DAA’s Political Advertising Principles. Client is required, to extent required by law, to include a “Paid for by” disclosure that appears directly in the advertisement and identifies who has paid for the advertisement. Such disclaimers must be included in all advertisements, including but not limited to those that use audio creatives and video creatives.

Disclosures and disclaimers made by Clients may not wrongfully imply that a foreign leader or entity has paid for the advertisement.

III. Political Advertising Restrictions

• U.S. Only. Clients may engage in Political Advertising in the U.S. only.
• Foreign Nationals. No foreign national may use the Services for Political Advertising. Clients must agree in writing that they will not use the Services for Political Advertising on behalf of a foreign national.
• State-Owned Media. No State-Owned Media organization or State Authority may engage in Political Advertising outside of the country in which they are located.
• Political Figures. Client’s ads may not imply knowledge of an individual’s status as a Political Figure nor of the status of any of an individual’s staff, employer, friends or family as a Political Figure. Clients may not engage in wholesale uploads of physical addresses for Political Figures.

Audience Size/Location Restrictions. Client’s engaged in Political Advertising remain subject to and must comply with applicable law, regulation and self-regulatory principles, as well as our other content and targeting guidelines with respect to such advertising.Examples of locations that may not be targeted for Political Advertising include, premises of federal agencies, polling places and the floor of federal and state senates and houses of representatives.

IV. Changes to this Policy BroadProximity, LLC. reserves the right to update or change this Policy at any time and in its sole discretion. For specific questions regarding this Policy or permissible Political Advertising activities, please contact BroadProximity, LLC. for guidance at broadproximity@gmail.com.

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