Advertising Policy

This policy applies to all advertising and promotional communications for PORTMAN University (“PORTMAN”), including work by employees, agencies, resellers, student ambassadors, affiliates/KOLs/KOCs, franchisees, and contractors worldwide.

1. Principles

Truthful & verifiable. All claims must be accurate, current, and supported with written evidence.
Student-first. Communications must be fair, not misleading, and avoid exploiting vulnerable audiences.
Compliant by design. We follow applicable laws and platform policies (e.g., consumer protection, privacy, advertising, and education marketing rules) in each country where ads run.
Brand safety. Creative reflects PORTMAN’s values; no shock tactics or deceptive design patterns.

2. Claims & Substantiation

2.1 Substantiation required

Keep a Claims Dossier for each campaign containing:

Source documents (accreditation letters, program handbooks, syllabi, tuition schedules),
Data files (completion time distributions, scholarship counts, capacity),
Screenshots/exports dated within the last 12 months.

2.2 Prohibited/Restricted claims

No guarantees: “Guaranteed degree/job/visa/admission/scholarship” is prohibited.
Outcomes: Job placement/income uplift claims require current, auditable data and context (cohorts, geography, timeframes). Otherwise use general benefit language with disclaimers.
Time-to-completion: Use conditional phrasing only (e.g., “typically completed in as little as 12 months depending on pace, credits, and assessment”). Do not say “12 months guaranteed” or “no coursework” unless strictly true and documented.
Accreditation: State accrediting body precisely and never imply government recognition that we do not hold.
Superlatives: “#1”, “first”, “only”, “best”, “highest paid commission” require third-party verification dated within the last 12 months and must cite the source in the ad/landing page. If not available, do not use.
Pricing: Advertised tuition and fees must match the official tuition page at the time of publication and note currency, taxes, and any additional charges.

2.3 Evidence retention

Retain substantiation for 24 months after the campaign ends (or longer if required by law).

3. Program Naming, Accreditation & PIEL Language

Use official program names exactly as approved by Academic Affairs.
PIEL (Prior Industry Experiential Learning) language:
- Approved phrasing: “PORTMAN recognizes relevant professional experience through its PIEL pathway, subject to assessment and portfolio review.”
- Add: “Assessment outcomes vary by applicant and jurisdiction.”

4. Pricing, Promotions & Scholarships

Price integrity: All advertised prices must be current, inclusive/exclusive of taxes as labeled, and include required fees or clearly identify optional fees.
Promotions: “Limited-time” or “limited seats” claims require internal documentation (start/end dates, seat caps). Remove/promote end states promptly.
Scholarships: Disclose eligibility criteria, application steps, selection process, number/value of awards, and key dates. Include: “Terms & conditions apply.”
Payment plans: Clearly disclose deposit amounts, monthly installment count, total payable, due dates, and consequences of default.

5. Audience Targeting & Sensitive Categories

Age: Do not target minors for higher education programs; default 18+ (or local age of majority). For MBA/DBA, recommend 21+ with relevant interest/experience filters.
Sensitive attributes: Never target or exclude based on race, religion, health, sexual orientation, political affiliation, union membership, or other protected characteristics. Follow each platform’s Restricted Targeting policies.
Geography: Run ads only in jurisdictions where the program is available and compliant. Block sanctioned countries.

6. Lead Generation, Consent & Privacy

Consent: All lead forms (web, WhatsApp, Messenger, SMS, phone) must collect explicit consent for contact and link to the Privacy Notice.
Opt-out: Provide an easy opt-out (“Stop”/unsubscribe link) and honor requests within required timeframes.
Retargeting: Disclose use of cookies/pixels; obtain consent where required. Respect platform rules for Customer Lists/Lookalikes.
Data minimization: Collect only necessary fields; store securely; limit access; delete according to retention schedules.
Channel specifics:
- Email: Include sender identity, mailing address, subject line accuracy, unsubscribe.
- WhatsApp/Meta: Use approved templates for outbound initiations; do not spam; respect 24‑hour windows.
- Telemarketing/Voice bots: Obtain prior consent; display caller ID; maintain do‑not‑call lists.

7. Endorsements, Testimonials & Influencers

Disclosures: If a material connection exists (payment, discount, free access), disclose clearly and upfront (e.g., “Ad”, “Sponsored”, “Partner”, #ad).
Authenticity: No fabricated testimonials. Get written consent for names, photos, videos, or employer references; verify identity.
Typicality: If featuring exceptional outcomes, add: “Results vary based on experience, effort, and assessment.”
Script control: Influencers must not imply guarantees or unapproved claims.

8. Creative Standards & Brand Use

Use approved logos, colors, and typefaces from the Brand Guide. Do not alter trademarks, add government emblems, or mimic official seals.
AI-generated media: Disclose in captions where realistic avatars/spokespeople are used (e.g., “Featuring an AI-generated presenter”). Never impersonate real staff or students without consent.
Accessibility: Provide alt text, adequate contrast, readable font sizes, and captions/subtitles on video.

9. Channel-Specific Rules

9.1 Search (SEM/SEO)

Do not promise outcomes in ad titles. Use approved sitelinks only. Landing page must match ad claims.

9.2 Social & Display

Avoid banned content categories (adult, tobacco, weapons, illegal services, misinformation). No clickbait (fake countdowns, deceptive CTAs).

9.3 Email/SMS/WhatsApp

Use double opt‑in where practical. No purchased lists. Keep contact cadence within 3 marketing sends/week/person (unless transactional or requested).

9.4 Landing pages

Primary claim mirrored above-the-fold; required disclaimers near CTA; link to Tuition, Accreditation, Privacy, and Terms.

9.5 Events & Webinars

Clearly state if recordings will be shared; obtain consent to contact registrants.

10. Affiliate/KOL/KOC Advertising Policy

Pre‑approval required to join the program. Each partner must agree to this Policy.
Brand bidding prohibited: No bidding on “PORTMAN University”, brand misspellings, or program names in SEM or app store ads. No trademark use in display URLs.
No impersonation: Partners may not pose as PORTMAN. Bios and pages must disclose independent status.
Creative use: Only use approved creatives or get written approval for new assets. No edits to accreditation or pricing messages.
Channels: No spam, unsolicited DMs, automated cold messaging, or bulk telemarketing without prior consent.
Traffic quality: No incentivized clicks, cookie stuffing, toolbars, adware, or forced redirects.
Coupons/Deals: Coupon sites allowed only with written approval and current offers. Expired or misleading coupons are prohibited.
Measurement: Use assigned UTM structure and do not strip tracking parameters.
Disclosures: Must mark posts as advertising (#ad, “Sponsored”, etc.).
Violations: Egregious violations lead to immediate suspension and clawback of commissions.

11. Review & Approval Workflow

Requires Legal/Compliance sign‑off when any of the below appear:
- Accreditation/recognition claims; employment outcomes; scholarship counts/values; superlatives; pricing/fees.
Standard approval: Marketing Lead → Compliance → Final publish.
Pre‑flight checklist (attach to ticket):

1) Claims Dossier attached,
2) Tuition link verified,
3) Accreditation phrasing matches §3,
4) Targeting age/geos confirmed,
5) Privacy links included,
6) Disclaimers present,
7) UTM validated,
8) Local legal review (if new country).

12. Monitoring, Enforcement & Penalties

Always‑on monitoring: Brand safety tool + manual audits of top‑spend creatives and top affiliates.
Notice & cure: Standard 48‑hour window to fix issues (24 hours for moderate; immediate takedown for severe risks such as false accreditation, guaranteed outcomes, or privacy violations).
Penalties: Creative takedown, budget pause, affiliate suspension, commission clawbacks, termination, and legal action where applicable.

13. Recordkeeping & Audit

Maintain approval logs, ad versions, targeting parameters, spend, and performance for 24 months minimum.
Affiliates must keep traffic logs and provide upon request within 5 business days.

14. Exceptions & Contact

Any exception must be approved in writing by Compliance and the Marketing Lead with a specific expiry date.
Contacts:
- Marketing Compliance: james@portman.university
- Legal: james@portman.university
- Data Protection/Privacy: james@portman.university

Appendix A — “Do / Don’t” Copy Examples

Completion time

✅ “Many learners complete in as little as 12 months, depending on pace, assessment outcomes, and credit recognition.”
❌ “Finish your doctorate in 12 months guaranteed with no coursework.”

Accreditation

✅ “PORTMAN University is globally recognised.
❌ “Government‑approved worldwide” or “Fully recognized everywhere.”

Scholarships

✅ “Scholarship available. Eligibility criteria apply. ”
❌ “Everyone gets a scholarship” / “Guaranteed award.”

Outcomes

✅ “Graduates report career advancement across diverse industries; individual results vary.”
❌ “Double your salary.”

Pricing

✅ “Tuition from $[X] (excludes taxes). See full fee schedule through website.”
❌ “Only $[X] today” when additional mandatory fees exist.

Appendix B — Mandatory Disclaimers (use as applicable)

Completion: “Completion timelines vary by learner pace, assessment outcomes, and prior learning recognition.”
Outcomes: “PORTMAN does not guarantee employment, promotions, immigration outcomes, or salary increases.”
Scholarships: “Awards are limited and subject to eligibility, application quality, and available funds.”
Privacy/Tracking: “We use cookies and similar technologies for analytics and personalized offers. Manage preferences at https://portman.university/privacy-policy/.”