1. Parties and Purpose
This Publisher Agreement ("Agreement") describes the general terms under which an approved publisher ("Publisher", "you", or "your") may provide advertising traffic, leads, inbound calls, or live transfers to Pace Advertising ("Pace", "we", "our", or "us").
Pace operates performance marketing and lead generation campaigns, including campaigns in ACA/Obamacare, Medicare, Final Expense, Hospital Indemnity, and other approved verticals.
2. Registration and Approval
- Publisher must provide accurate business, contact, ownership, and verification information during registration.
- Pace may request additional business, identity, compliance, traffic-source, or payment documentation.
- Registration does not guarantee approval or campaign access.
- Publisher may participate only in campaigns for which it has received explicit approval.
- Publisher must keep its account information current and protect its login credentials.
- Publisher must not transfer, share, or sell account access without written authorization from Pace.
3. Campaign Approval and Participation
Each campaign may have its own targeting, geographic restrictions, operating hours, qualification criteria, call duration requirements, caps, rates, and other conditions.
- Publisher must review and comply with all campaign instructions before launching traffic.
- Publisher must not begin a campaign until it has been approved by Pace.
- Approval for one campaign does not imply approval for another.
- Pace may modify, pause, limit, or discontinue campaigns based on advertiser requirements, compliance concerns, quality, or business needs.
- Publisher must obtain written approval before making material changes to an approved traffic source or campaign method.
4. Traffic Sources and Disclosure
Publisher must disclose the traffic sources and acquisition methods used for each campaign. These may include websites, landing pages, search advertising, social media advertising, affiliates, call generation, or other approved channels.
Publisher must:
- Use only lawful and approved traffic sources.
- Provide accurate source details when requested by Pace.
- Maintain records sufficient to demonstrate where traffic originated.
- Obtain prior written approval before subcontracting or using additional third-party publishers where required by the campaign.
- Ensure that all downstream sources follow the same applicable campaign requirements.
- Immediately disclose any material change in traffic acquisition methods.
5. Prohibited Traffic Practices
Publisher must not engage in or knowingly facilitate:
- Fake, fabricated, misleading, or artificially generated leads or calls.
- Caller ID spoofing, misleading caller identification, or call manipulation.
- Unauthorized robocalls, automated dialing, or prerecorded messages where prohibited or not properly authorized.
- AI-generated or automated consumer interactions presented as genuine human consumer engagement.
- Coaching consumers to provide false information or conceal relevant facts.
- Misrepresentation of eligibility, income, coverage, intent, or consumer identity.
- Duplicate submissions, recycled leads, or repeated calls intended to manipulate campaign billing.
- Incentivized traffic where incentives are not expressly authorized.
- Unauthorized transfers, forced transfers, misleading warm transfers, or deceptive call handling.
- Traffic obtained through malware, bots, deceptive advertisements, or unlawful methods.
- Any activity designed to bypass campaign filters, qualification rules, or compliance checks.
6. Consumer Consent and Regulatory Compliance
Publisher is responsible for ensuring that its advertising, lead collection, calling, and transfer practices comply with all applicable laws and regulations.
Depending on the campaign and applicable law, requirements may include:
- Telephone Consumer Protection Act (TCPA) and related telemarketing requirements.
- National and applicable state Do Not Call requirements.
- Consumer consent and disclosure requirements.
- Privacy and data protection laws.
- Applicable healthcare advertising and marketing requirements, including relevant CMS rules where applicable.
- Truthful advertising and consumer protection requirements.
Publisher must obtain and maintain legally required consumer consent and supporting records. Publisher must not represent that a consumer has consented unless that consent was actually obtained and can be substantiated.
Pace's review or approval of a traffic source does not relieve Publisher of its independent legal responsibilities.
7. Lead and Call Quality Requirements
All leads, calls, and transfers must meet the requirements of the applicable campaign and IO.
Depending on the campaign, activity may be rejected or treated as non-billable if it includes:
- Invalid or fabricated consumer information.
- Duplicate or previously submitted activity where duplicates are excluded.
- Dead-air calls or calls without genuine consumer engagement.
- Disconnected calls or calls below the agreed duration requirement.
- Consumers who fail the campaign's eligibility criteria.
- Calls with inaccurate or misleading qualification responses.
- Unauthorized, coached, spoofed, or manipulated transfers.
- Traffic from undisclosed or prohibited sources.
Specific acceptance, rejection, billing, and dispute criteria will be determined by the applicable campaign instructions and signed IO.
8. Campaign Rates and Payments
Publisher compensation is determined by the applicable campaign IO or other written agreement. Rates may be structured as CPA, CPL, pay-per-call, qualified transfer, or another agreed model.
- Publisher is entitled to payment only for activity that meets the applicable billing criteria.
- Payment schedules, payment methods, thresholds, and billing cycles must be agreed in writing.
- Campaign rates may not be changed retroactively except as permitted by the applicable agreement or mutually agreed in writing.
- Disputed or invalid activity may be withheld pending review under the agreed dispute process.
- Publisher must provide accurate invoicing and payment details.
- Publisher is responsible for its own applicable taxes and business expenses unless otherwise agreed.
No payment rate, minimum volume, campaign availability, or earnings level is guaranteed unless expressly agreed in a signed written document.
9. Reporting, Audits and Disputes
Pace may review campaign activity, traffic sources, lead records, call records where lawfully available, consent evidence, and other relevant documentation to verify compliance and billing accuracy.
- Publisher must cooperate with reasonable quality reviews and compliance investigations.
- Publisher must provide requested supporting records within a reasonable timeframe.
- Publisher must promptly report suspected fraud, unauthorized traffic, or data incidents.
- Billing disputes must be raised through the process and within the timeframe stated in the applicable IO or MSA.
- Pace may temporarily hold disputed amounts while a good-faith review is conducted, subject to the applicable agreement and law.
10. Consumer Data and Privacy
Publisher must handle consumer information securely and only for authorized campaign purposes.
- Publisher must not sell, rent, disclose, or redistribute consumer information without proper authorization.
- Publisher must restrict access to consumer information to authorized personnel.
- Publisher must use reasonable security measures to protect personal information.
- Publisher must notify Pace promptly of any suspected unauthorized access, disclosure, loss, or misuse of campaign data.
- Publisher must comply with applicable deletion, correction, access, and data retention requirements.
- Publisher must not retain consumer information longer than reasonably necessary or legally permitted.
11. Subcontractors and Third Parties
Publisher may not appoint subcontractors, sub-publishers, call centers, or other third parties to perform campaign activities where such use is prohibited or requires approval that has not been obtained.
Where third-party participation is approved, Publisher remains responsible for ensuring that those parties comply with the applicable campaign terms, confidentiality obligations, data protection requirements, and legal obligations.
12. Confidentiality
Publisher must protect all non-public information received from Pace or its advertisers, including campaign details, rates, customer information, business processes, login credentials, documents, and partner information.
Confidential information may only be used to perform authorized services and must not be disclosed to unauthorized third parties.
13. Intellectual Property and Brand Use
Publisher may not use Pace's name, logos, trademarks, advertiser branding, or campaign materials except as expressly authorized in writing.
All intellectual property rights remain with their respective owners. No ownership rights are transferred through campaign participation.
14. Suspension and Termination
Pace may suspend campaign access, restrict traffic, withhold disputed activity for review, or terminate a Publisher relationship where reasonably necessary, including in cases of suspected fraud, compliance violations, inaccurate disclosures, breach of agreement, security concerns, or advertiser instructions.
Publisher may discontinue participation subject to the notice and outstanding obligations specified in its signed MSA or applicable IO.
Termination does not eliminate payment obligations for valid approved activity or other obligations that survive termination under the applicable agreements.
15. Representations and Warranties
Publisher represents that:
- It has authority to enter into the applicable agreements.
- Information supplied to Pace is accurate and not misleading.
- Its traffic sources and marketing activities are lawful and appropriately authorized.
- It will comply with applicable laws and campaign requirements.
- It will not knowingly submit fraudulent, manipulated, or unauthorized activity.
16. Indemnification
Any indemnification obligations, including responsibility for third-party claims, regulatory actions, losses, or expenses arising from a party's breach, misconduct, or unlawful activity, will be governed by the applicable signed MSA or other written agreement. Nothing in this section creates an obligation beyond what is agreed in that contract or permitted by applicable law.
17. Limitation of Liability
The liability of Pace and Publisher will be governed by the applicable signed MSA or other written agreement. To the extent permitted by applicable law, neither party will be liable for indirect, incidental, special, or consequential damages except where such limitation is prohibited or the applicable agreement provides otherwise.
18. Electronic Agreements and Signatures
Pace may provide MSAs, IOs, and related documents through secure electronic signing links or its partner portal.
- Publisher must review each document before signing.
- Only an authorized representative may sign on behalf of Publisher.
- Electronic signatures and associated signing records may be retained electronically.
- Campaign-specific rates and requirements will be governed by the applicable IO or written agreement.
- Publisher should retain copies of its completed agreements.
19. Relationship Between the Parties
Publisher operates as an independent business and not as an employee, agent, joint venture partner, or legal representative of Pace, unless expressly agreed in writing. Publisher has no authority to make commitments or representations on behalf of Pace or its advertisers.
20. Governing Law and Disputes
The governing law, jurisdiction, and dispute resolution process for the Publisher relationship will be set out in the applicable signed MSA or other written agreement. Where no agreement addresses a particular issue, applicable law will govern.
21. Changes to This Agreement
Pace may update these general publisher requirements from time to time. Changes to an existing signed MSA or IO will be handled in accordance with the amendment provisions of that agreement and applicable law.
22. Contact Information
For publisher onboarding, campaign, compliance, or agreement questions:
Pace Advertising
Email: info@p4pace.online
Phone: +92 312 8691635
Office #4, Baqai Arcade, 6th Road,
Rawalpindi 46000, Pakistan.