Your company is ultimately responsible for what others do on your behalf. You should make sure your public relations firm has an appropriate program in place to train and monitor members of its social media network. Ask for regular reports confirming that the program is operating properly and monitor the network periodically. Delegating part of your promotional program to an outside entity doesn’t relieve you of responsibility under the FTC Act.
19.4 Affiliate agrees not to use any technique or marketing program that might reasonably be considered "predatory" or manipulative. GenealogyBank.com reserves the right to determine whether a technique or program is unreasonable. In the event of a breach of this Agreement by Affiliate and/or a third party or licensee, GenealogyBank.com shall immediately terminate this agreement, and, in addition to all other remedies available to it, GenealogyBank.com shall have the right to refuse to make payments to an Affiliate as a result of the Affiliate's efforts promoting GenealogyBank.com in such a manner.
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