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Guidelines for Marketing partners  

Zmarta AB and Freedom Rahoitus Oy, hereafter jointly referred to as ”Zmarta”, “we”, “us”  (or similar), provide consumer credit intermediation services and it is crucial for us that all  marketing of Zmarta’s services is conducted in a legally compliant manner and in  consistency with good marketing practice.  

These guidelines aim to clarify and ensure that all marketing of Zmarta’s services by a  Marketing partner (“Marketing partner” or “you”) is handled in a correct manner. However,  please note that these guidelines should not be viewed as legal advice from Zmarta, the  Marketing partner itself is obliged to ensure compliance with applicable laws and  regulations for marketing of consumer credits.  

We believe that these guidelines will bring value to both Zmarta and our Marketing partners  by enabling us to present the intermediation service to customers in a compliant way. 

When referring to the “Service” we mean Zmarta’s credit intermediary service. 

1. General marketing rules  

• Marketing must be carried out in accordance with good marketing practice and  cannot be aggressive, misleading or untrue. This must be taken into account when  creating content and also in connection with e-mail/SMS send-outs, both in terms of  content and frequency. 

• Marketing must comply with consumer protection, marketing regulations, and other  applicable laws and it may not include any unfair business practices. The Marketing  partner is responsible for the content he publishes, for personal data that he collects  and compliance with applicable data protection laws. 

• The Marketing partner may not encourage the customer to take quick decisions  regarding the credit or indicate that the customer will receive any benefit if he/she  applies quickly. In other words, no aggressive, misleading or untrue marketing. 

• A customer’s decision to not sign-up for a loan must be respected and the Marketing  partner cannot contact such customer to try to persuade him/her into taking the  offered loan if the customer has stated that it is not interested. 

• The Marketing partner must collect its own consent to direct marketing.  

• Direct marketing of consumer loans (via e-mail/SMS) must be moderate in terms of  how often it is sent to a consumer, it is unlawful to send direct marketing too often  and too frequently. For the Swedish market, guidance regarding frequency (as well  as content) of send-outs can be found in the Swedish court case PMT 7180-22 (the  Consumer Ombudsman vs. Qliro). 

• The Marketing partner may not use the logos of Zmarta’s cooperation banks/lenders  without prior written consent from the bank/lender in question. 

• Competitions, contests, sweepstakes, raffles and similar may not be used as a  marketing method. 

• The Marketing partner may not direct any marketing towards persons younger than  18 years. 

• The Marketing partner is fully responsible that third parties (which the marketing  partner has engaged) follow these guidelines as well as obligations and restrictions  stated in our agreement. If you, or a third party that you have engaged, want to create  own content or modify the content Zmarta has provided, it needs to be sent to Zmarta 

for pre-approval. 

2. Creating content  

Things to consider by the Marketing partner when reviewing/creating content:  

• It must be clear that: 

o Zmarta is the provider of the Service and that the Marketing partner’s role is  limited to marketing the Service. 

o The Marketing partner does not claim to provide intermediation services or other  licensable business unless the Marketing partner has a license to do so.  

o In other words, it must be clear to the customer that Zmarta provides the Service,  not the Marketing partner.  

3. When describing the Service, you may not:  

• Refer to a specific number of “banks”, i.e. “over X banks”. We collaborate with other  partners than banks, such as credit institutions. You may say “several banks” or “over  X banks and lenders”.  

• Market the Service in a way which gives the customers the impression that they will  receive a specific number of offers, e.g. “you get offers from over X lenders”. Customers will never get the same number of offers as we have lenders since the  offers will be limited depending on internal rules. Rather say that “you can get several  offers”.  

• Use phrases such as “Lending money fast”, “Lending money in only a couple of  seconds” or use any wording which refers to SMS/quick/instant loans. 

• Use superlatives or comparatives in your marketing (such as “You will get the best  offer” or “You will get cheaper interest”). 

• Use inappropriate or ungrounded promises (such as “You will save money”, “You will  get a loan”, “You will lower your monthly cost”, “Say goodbye to expensive loans” or  “Consolidate your loans and you will have more money to spend”). 

We need to present a reliable and balanced picture of the loan. These types of  statements might mislead the consumer about the financial consequences of taking a loan by presenting the loan as a worry-free solution to the consumer’s  potential problems. 

• Use statements regarding how many customers that have previously used the loan  application service (such as ”More than 100 000 customers have already applied” or  “Do as thousands of others, apply and find out what we can do for you”). 

These types of statements downplay the seriousness of the decision to enter  into a credit agreement by affecting the average consumer's ability to decide  to what extent the credit is favourable for him or her and risks luring the  consumer into an unconsidered decision. 

• Imply that loans are preapproved in any way. We do a credit check for all applications and it is the lender’s decision to approve a loan or not.  

• Use phrases such as “…just click on the link below to get money directly to your  account” (or similar). 

• Market the Service in a way which gives the customer the impression that an application has already been made or that loan offers have already been provided and may therefore not refer to “Regarding your application…” in any e-mail/SMS text  or subject line before an application process has been started by the customer.  

4. Specific rules for direct marketing (i.e. e-mail and SMS)  

• National legislation regarding unsolicited/unwanted communication must be strictly  obeyed by the Marketing partner.  

• Consent to digital marketing must be obtained from the customer and documentation  is required for such explicit permission from subscribers to receive the specific e mail/SMS. Opt-in details as date and source/purpose for opt-in should be possible to  share if asked by Zmarta.  

• Unsubscribe link needs to be included in all electronic marketing and should always  work properly. Possible errors must be corrected immediately. 

• Unsubscribe link should be marked in the language used in the direct marketing (not  enough with only English “Unsubscribe” if other language has been used in the  marketing). 

• An unsubscribe-request needs to be processed as soon as possible.  

• Sender name (identification) shall be correct, not misleading and may not vary from  time to time. Contact information to the Marketing partner must also be visible in the  send out/newsletter.  

• The sender must disclose the source of the consumer’s contact data and the reason  why the consumer is receiving the send out should be visible in the send out, e.g. “You receive this e-mail since you signed up for newsletter “Economy”.

• Blacklist tool must be established, used and updated at all times before each  individual send out.  

• If Zmarta is mentioned in direct marketing this sentence must be added in all e mail/SMS marketing (smaller font in bottom of text, only in Finnish/Swedish):  

SE: Det här e-postmeddelandet skickas inte från Zmarta, men från en  kommersiell marknadsföringspartner. 

(Translation for ease of reference: This e-mail is not sent from Zmarta, but from  a commercial marketing partner) 

FI: “Tämän sähköpostin lähettäjä ei ole Freedom Rahoitus, vaan lähettäjänä  toimii mainontaa tekevä kolmas osapuoli."  

(Translation for ease of reference: This e-mail is not sent from Freedom  Rahoitus, but from a commercial marketing partner)  

5. Calculation example  

• Information about the representative effective interest rate (Swe: representativt  ränteexempel) must always be shown when marketing a credit if the marketing  portrays any detail describing the terms of the credit, e.g. if the marketing contains  information about monthly cost, interest rates or similar. Such calculation example: 

o Must be provided clearly, highly visible and in near connection to the  presentation of monthly cost/payment. Meaning that it must be easily readable  and accessible (may not be presented behind link or at the bottom of the page).  

o Shall refer to the most common credit situation that is applied or can be  foreseen.  

o Shall be updated frequently by the Marketing partner. 

• Marketing partners that present Zmarta’s offer must always use the current  calculation example displayed on Zmarta’s website.  

• Marketing partners that provide comparison services in their own name (so called  white labels) are recommended to use the current calculation example displayed on  Zmarta’s website. If not using Zmarta’s example, the example used shall always  contain at least the variables included in Zmarta’s example. 

• If the Marketing partner wants to market that our lenders have rates “from” e.g. 3%  (Swe: frånräntesats), the entire interest range (lowest-highest) must be added in  connection to the information.  

6. Search Engine Marketing, sponsored links and Search Engine Optimization  

• Zmarta maintains a closed paid search policy. The Marketing partner may not purchase Zmarta's brand keywords, including “Zmarta”, “Freedom Finance”, “Freedom Rahoitus”, special spellings or misspellings of Zmarta’s brands or variations of these  words.  

• The Marketing partner is not permitted to direct traffic directly to Zmarta’s websites  including Zmarta, Freedom Finance and Freedom Rahoitusthrough the purchase of  sponsored links, irrespective of the keyword used. It is mandatory to include  Zmarta’s trademark, as well as variations and misspellings, as negative keywords. 

• The Marketing partner may not register domains or otherwise work with Search  Engine Optimization (“SEO”) to achieve rankings related to Zmarta’s brands, or  misspellings and variations of Zmarta’s brands. 

• Failure to adhere to these rules releases Zmarta from any obligation to compensate  the Marketing partner. 

APPENDICES:  

1. Specific requirements for White Labels  

2. Specific requirements for Affiliate Networks

APPENDIX 1 – SPECIFIC REQUIREMENTS FOR WHITE LABELS  

Information on application page  

The following information should be included on the application page to clarify the fact  that Zmarta provides the Service:  

1: Above the fold 

SE: I samarbete med {logo Zmarta}  

{Siten} marknadsför Zmarta AB:s tillståndspliktiga låneförmedlingstjänst.  

FI: Yhteistyössä {logo Zmarta}  

{Sivusto} markkinoi Freedom Rahoitus Oy:n lainanvälityspalveluja.  

2: In near connection to the “Send – Application” button:  

SE: Ansökan lämnas till {Siten AB}. Ansökan kommer att handläggas av Zmarta AB.  

FI: Hakemus jätetään {AB-sivustolle}. Hakemuksen käsittelee Freedom Rahoitus  Oy.  

If the Marketing partner collaborates with several intermediaries, Zmarta should be  named as one of the intermediaries that may process the application. 

Credit check  

In the application form (early in the application process), the Marketing partner must inform  the customer that a credit check will be made.  

Terms & Conditions  

• The Marketing partner shall ensure that a customer prior to or in connection with  completion of a loan application is clearly informed of the Marketing partner’s and  Zmarta’s processing of personal data,  

• The customer must actively consent to Zmarta’s terms and conditions by checking a  box on the Marketing partner’s site.  

• The Marketing partner must ensure that, at all times, the current versions of Zmarta’s  terms and conditions are presented to the customer. Current versions will be provided  by Zmarta.  

• The Marketing partner’s terms and conditions for marketing and usage of the  Marketing partner’s service should be displayed on a separate page (i.e. separately  from Zmarta’s terms and conditions). 

 

APPENDIX 2 – SPECIFIC REQUIREMENTS FOR AFFILIATE NETWORKS  

• Affiliate networks and their affiliate partners may only use Zmarta pre-approved email  and sms content. 

• In case an affiliate partner would like to use a different copy or modify the copy  Zmarta has provided, such copy needs to be reviewed and approved by Zmarta  before it is used. 

• Affiliate networks should ask for previews of the first two send-outs from all new  affiliate partners running Zmarta’s campaign to ensure that they are compliant with  the applicable rules for digital marketing and these guidelines.  

• Affiliate networks should monitor marketing activities of their affiliate partners on a  regular basis and report back to Zmarta all cases of affiliate partner in breach of any  rules.  

• Zmarta reserves the right to decide to warn or ban affiliate partners that act in breach  of any rules or guidelines.