Vinchella – FTC Endorsement & Testimonial Compliance Policy
Issued under 16 CFR Part 255
Applies to: Vinchella Inc. Fort Lauderdale, Florida, USA
Effective Date: January 2026
FTC Disclosure
1. Legal Basis
This policy implements the Federal Trade Commission’s Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 CFR Part 255).
These FTC Guides interpret Section 5 of the FTC Act (15 U.S.C. § 45), which prohibits unfair or deceptive acts or practices in commerce.
Accordingly:
All endorsements and testimonials must be truthful, Not misleading, Substantiated, and Accompanied by a clear and conspicuous disclosure of any material connection between the endorser and Vinchella Inc.
2. Definitions (16 CFR § 255.0–255.1)
Endorsement
Any advertising message consumers may believe reflects the opinions, findings, or experiences of someone other than Vinchella Inc.
Endorser
Any person, influencer, affiliate, or organization who makes an endorsement.
Material Connection
Any relationship that could affect the credibility of an endorsement, including:
Compensation or commissions
Free or discounted products
Travel, gifts, or event access
Employment or consulting relationship
Affiliate partnerships
Brand ambassadorship
Material connections must always be disclosed.
3. General Principles
Endorsements must reflect the honest opinions, findings, or experiences of the endorser.
Endorsers must have actually used the product if describing personal experience.
Endorsements cannot express or imply claims Vinchella could not legally make on its own.
Typical-results claims must reflect what users can generally expect. If atypical, a disclosure is required.
Material connections must be disclosed each time an endorsement appears.
Disclosures must be unavoidable, clear, and easy to understand.
4. Disclosure Standards
A. Clarity & Conspicuousness (FTC § 255.5)
Disclosures must: Use simple language such as “Ad,” “Sponsored,” “Paid Partnership with Vinchella,” or “Vinchella gifted this product.” Appear before or near the endorsement itself. Not be buried in a bio, profile, “About” section, or separate page. Be visible without needing to click “more.” Be spoken and shown on-screen in videos.
Hashtags must be unambiguous, e.g.:
#VinchellaPartner
#VinchellaAd
#VinchellaGifted
Weak or vague hashtags like #sp or #collab are not compliant.
B. Placement & Duration
Users must not have to scroll, click, or hover to find a disclosure.
In videos and livestreams, disclosures must appear early and remain long enough to read.
5. Typical Disclosure Examples
Acceptable (Compliant)
“Paid partnership with @Vinchella”
“Sponsored by Vinchella”
“Vinchella gifted this product for review”
“Affiliate link – I earn a commission if you buy through this link”
Not Acceptable
“Thanks @Vinchella!” (no disclosure)
“#sp” or “#collab” (ambiguous)
Disclosure only in the bio or at the bottom of long captions
6. Substantiation of Claims
All performance or anti-aging claims must be truthful, non-misleading, and supported by competent and reliable evidence (e.g., clinical testing, consumer perception studies).
Influencers may describe personal experiences but cannot claim results beyond what the product can achieve.
Vinchella reviews all influencer scripts, claims, and marketing assets for compliance with FTC, FDA cosmetic labeling, and international advertising standards.
7. Monitoring & Enforcement
Vinchella will:
Review influencer and affiliate content before or immediately after posting.
Request corrections to disclosures that do not comply with FTC rules.
Pause payments or terminate partnerships for repeated non-compliance.
Maintain endorsement documentation, contracts, communications, and screenshots for at least 24 months, as recommended by FTC guidance.
8. Penalties for Non-Compliance
Violations of 16 CFR Part 255 may result in:
FTC enforcement actions
Civil penalties under 15 U.S.C. § 45(m)(1)(A)
Liability for deceptive advertising
Termination of partnership agreements
Mandatory corrective disclosures
Influencers and affiliates working with Vinchella must comply fully with this policy.
9. Questions & Contact
:For compliance questions or clarification about endorsements
Vinchella Inc. – Legal & Compliance Department
Email: customer-service@vinchella.com
Phone: +1-866-201-5188
:Address
3301 SW 42nd St, Fort Lauderdale, Florida 33312-6828, USA