Affiliate Marketing Guide This guide will help put you on the road towards creating a successful, lawful engagement with your audience when promoting Coinbase. Applicable laws regulating affiliate marketing are complex and the most important thing to remember is that creativity in the ever changing cryptocurrency landscape is not an excuse to avoid legal compliance. Legal compliance must be at the forefront of your campaign to ensure trusting and transparent engagement with your audience and so your latest promotion does not become one of the “don’ts” of crypto affiliate marketing history. Remember, all Coinbase Affiliate Program Agreement terms and conditions apply to your Coinbase campaigns. The FTC (US) and CAP/ASA (UK) are not the only regulatory agencies enforcing the rules. Other countries have or soon will have their own marketing and advertising laws or self-regulatory guidelines applicable to cryptocurrency advertising that publishers will need to adhere to. We highly recommend that you refer to the rules and guidance applicable to each jurisdiction where your audience is based to ensure that you are not breaking rules applicable to affiliate marketing. To ensure all best practices of being an affiliate marketer for any industry are ever present keep the below rules and guidelines top of mind. ● CAP Guidance for Online Affiliate Marketing: ○ https://www.https://www.asa.org.uk/advice-online/affiliate-marketi ng.html ● CAP Guideline for Effective Disclosures on Social Media: ○ https://www.asa.org.uk/advice-online/remit-social-media.html ● FTC Endorsement Guides: ○ https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-publis hes-final-guides-governing-endorsements-testimonials/091005revisedendorse mentguides.pdf ● FTC’s Guideline for Effective Disclosures in Digital Advertising: ○ https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-staff-r evises-online-advertising-disclosure-guidelines/130312dotcomdisclosures.pdf ● FTC Guideline for Disclosure on Social Media: ○ https://www.ftc.gov/business-guidance/resources/disclosures-101-soci al-media-influencers Disclosure Guidelines It isn't enough to make a disclosure. It is your responsibility to ensure that the disclosures you make are clear and conspicuous, that your audience notices them, and are able to understand that the disclosure means you may receive compensation by advertising and promoting Coinbase. Although technical compliance with the laws applicable to affiliate marketing is required, strive to maintain a standard that will allow your audience to easily CONFIDENTIAL V2 2023-02-23 understand the relationship between you and Coinbase. Using clear and conspicuous disclosures will ensure that your audience understands the nature of the media and content they are consuming, improving the user experience. Country-Specific Disclosure Guidelines Cryptocurrency advertising is subject to more scrutiny than ever before. It’s critical as a Coinbase affiliate that you are keenly aware of and comply with all applicable rules when you advertise on our behalf. Below you will find a non-exhaustive list of resources we’ve gathered to assist you in ensuring compliance in certain jurisdictions. ● United Kingdom: Please see the CAP Advertising of Cryptoassets Enforcement Notice available for download here: https://www.asa.org.uk/resource/enforcement-notice-advertising-of-cryptoassets-cry ptocurrencies.html A special about disclosures in the United Kingdom: All crypto-related ads in the UK must include the following disclosure: "Capital may lose all value. Not regulated in the UK. Subject to CGT." The following disclaimer must be included in all advertisements that reference crypto pricing, in addition to the above disclosure: “Content is for informational purposes and is not investment advice. Past performance is not indicative of future results. Investing in cryptocurrency comes with risk.” ● India: See the Advertising Standards Council of India’s guidelines for crypto ads here: https://ascionline.in/images/pdf/vda-guidelines-23.02.22.pdf ● Spain: See the National Securities Market Commission guidelines for crypto ads here: https://cnmv.es/DocPortal/Legislacion/Circulares/Circular_1_2022_EN.pdf ● South Africa: See the Advertising Regulatory Board’s guidelines for crypto ads - Section 17 - here: https://arb.org.za/assets/section-iii-specific-categories-of-advertising-v2023.1.pdf ● Netherlands: To avoid having to add a lengthy disclosure, do not reference Coinbase’s Dutch registration. Social Media Disclosure Guidelines Do’s Don’ts CONFIDENTIAL V2 2023-02-23 ● Make the disclosure using hashtags like #ad, #advertisement, #sponsored, or #promotion. ● Place the disclosure at the very beginning of the post. ● Include written disclosures (e.g. #ad) at the beginning of the video description (including video stories) within photo content, in addition to the post description. For videos or live streams, also include an audible disclosure. ● Put the disclosure at the bottom of a post or mix in the middle of other hashtags. ● Only rely on tagging the advertiser or the platform to disclose. ● Make it difficult for the audience to know you're being compensated by Coinbase. ● Only include a disclosure on video content or photo content in the post description. Editorials, Blogs and Other Non-Social Content Disclosure Guidelines Do’s Don’ts ● Make your disclosure easy to understand. Prominent: ● Ensure your disclosure appears ‘above the fold’ meaning the user doesn’t have to scroll down to see it. ● Make the disclosure stand out visually so your audience has every opportunity to see it. ● Make sure it’s easy to read (e.g. contrasting text colors with page background color). Proximate: ● Put your disclosure near the relevant content (e.g. posting, statement, or endorsement) that causes you to have to make a disclosure. At a minimum the disclosure should be on every page that contains affiliate link(s). If hyperlinking to a disclosure page: ● Ensure the link itself is both prominent and proximate. ● Make your disclosure tough to understand. ● Only state ‘we use affiliate links.’ ● Put the disclosure at the footer of your site, or in an inconspicuous spot (i.e. middle of the page on the side, bottom of post, etc.). ● Bury your disclosure in an “About Us,” “Terms of Service,” “Privacy Policy” or other similar section. ● Only put a disclosure on your home page, on a disclosure page, or a link in the footer. ● Put in color or font that is difficult to read (i.e. light gray on white background). CONFIDENTIAL V2 2023-02-23 Geographic Restrictions Guidelines Coinbase’s products and services are not available in every country or in every state, territory, or province within a given country. While it’s understandable that certain users in restricted areas may access generally available content, any targeted marketing campaigns which promote Coinbase, including sending links related to Coinbase, must not be directed within the below prohibited jurisdictions. This list of restricted countries was last updated in February 2023 and may continue to be updated from time to time. ● North America: State of Hawaii (United States), Mexico. ● Latin America and the Caribbean: British Virgin Islands, Bermuda, Cayman Islands, Colombia, Costa Rica, Dominican Republic, Ecuador, Guatemala, Jamaica, Peru, Saint Lucia, and Uruguay. ● Europe: Andorra, Austria, Belgium, Bulgaria, Cyprus, Czechia, Estonia, Finland, France, Gibraltar, Greece, Guernsey, Iceland, Isle of Man, Liechtenstein, Lithuania, Luxembourg, Malta, Monaco, Norway, Poland, Portugal, Romania, San Marino, Slovakia, Spain, and Switzerland. ● Africa and the Middle East: Afghanistan, Algeria, Bahrain, Belarus, Côte d’Ivoire, Crimea, Djibouti, Egypt, Ethiopia, Georgia, Guinea-Bissau, Iraq, Israel, Jordan, Kuwait, Lebanon, Lesotho, Liberia, Macedonia, Mauritania, Morocco, Namibia, Niger, Qatar, Russia, Saudi Arabia, Senegal, Seychelles, South Africa, South Sudan, Sudan, Syrian Arab Republic, Tanzania, Tunisia, and United Arab Emirates. ● Asia Pacific, Central Asia and Japan: Bangladesh, China, Hong Kong, India, Indonesia, Macau, Malaysia, Mongolia, Myanmar, New Zealand, Philippines, Republic of Korea, Singapore, Taiwan, Thailand, Uzbekistan, and Vietnam. ● Other: any jurisdiction in which trading and/or usage of cryptocurrency or digital assets is prohibited, or any country or jurisdiction subject to embargo or sanctions by the U.S. Government (“Sanctioned Jurisdictions”), including, without limitation, Cuba, Iran, North Korea, Northern Sudan and Syria (or any additional country or jurisdiction added to this list by Coinbase from time to time, in its sole discretion, with notice to you). Offers & Incentives Guidelines As a Coinbase Affiliate, you may decide to provide an incentive or offer directly to your audience. You are permitted to make direct incentives or offers so long as you: (i) communicate clearly the incentive or offer is coming from you and not Coinbase, and (ii) ensure the incentive or offer is presented accurately and includes any required disclosures, relevant information, and/or terms and conditions as further outlined below. If you wish to run an offer or incentive which differs from the categories of offers, or which does not use the disclosures exactly as listed below, you must contact Coinbase for its prior written approval before publishing the offer or incentive. Note: Any offer or incentive which uses the word “free” must clearly communicate the CONFIDENTIAL V2 2023-02-23 requisite actions required to be eligible for the free reward. Type of Offer Guidelines for Offer Applicable Disclosures Currently Available Coinbase Offer ● Use the exact language Coinbase uses to promote its offer. For example, if Coinbase’s website or ads state “Get $5 in Bitcoin when you sign up for Coinbase” you must use this exact language in your promotion of this offer. ● Use the exact disclosure language Coinbase uses applicable to that offer. ● Ensure your disclosures are used in accordance with the guidance in the Disclosures section. ● Ensure that you only promote a Coinbase offer while the Coinbase offer is live and valid. Remove any promotion of an expired offer. For the offer which promotes receiving an amount of Bitcoin upon signing up with Coinbase, use the following disclosure: “After your photo ID is verified, BTC will be added to your portfolio. Limited time offer. Offer available to new users who have not previously verified their identification. Offer not available to new users who were referred to Coinbase through the Referral Program or who have previously opened an account using different contact information. Coinbase may update the conditions for eligibility at any time.” For the offer which promotes receiving an amount of Bitcoin upon making a user’s first trade with Coinbase, use the following disclosure: “After your first trade, BTC will be added to your portfolio. Limited time offer. Offer available to new users who have not previously made a crypto purchase on Coinbase. Offer not available to new users who were referred to Coinbase through the Referral Program or who have previously opened an account using different contact CONFIDENTIAL V2 2023-02-23 information. Coinbase may update the conditions for eligibility at any time.” For the offer which promotes the amount of reward earning potential through the Coinbase Earn product, use the following disclosure: “Limited while supplies last and amounts offered for each quiz may vary. Must verify ID to be eligible and complete quiz to earn. Customers may only earn once per quiz. Coinbase reserves the right to cancel the learning rewards offer at anytime. Coinbase receives fees from asset issuers in connection with creating and distributing asset and/or protocol specific learning rewards content.” Currently Available Coinbase Offer Plus an Affiliate Offer e.g. promo code ● Follow all guidelines above applicable to promoting a Coinbase offer. ● Make clear that the Affiliate offer is separate and distinct from the Coinbase offer. ● Make clear that Coinbase will provide the benefits of the Coinbase offer and the Affiliate will provide the benefits of the Affiliate offer. ● The same disclosures applicable to the Coinbase offer. ● Disclosures based on the Affiliate offer. Affiliate Offer Only e.g. cashback Make clear the Affiliate offer is coming from and offered by the Affiliate and not from Coinbase Any disclosure deemed necessary by the Affiliate to ensure compliance with legal requirements and the Disclosures section in these guidelines. Content Guidelines Coinbase desires to maintain its brand and image in the marketplace. To do that, we rely on our affiliates to ensure the promotion of Coinbase is in a similar form and fashion to how Coinbase promotes itself. If you choose to make statements or claims about Coinbase, or a Coinbase product or service, make sure the statement or claim is something that Coinbase has previously published and is up to date. You cannot, however, make statements or Claims about Coinbase, or its products or services, that would require proof that Coinbase itself doesn’t have. If you are making an endorsement of Coinbase, your statements must reflect CONFIDENTIAL V2 2023-02-23 your honest opinions, beliefs, or experiences and must not be false, misleading, or unsupported. In addition and to maintain our brand’s integrity, you are restricted from promoting Coinbase on sites and apps that contain or reference categories related to: ● Adult content, pornography, weapons, graphic violence (including any violent video game images), alcohol, drugs, tragedy, transportation accidents, sensitive social issues, political in nature, or gambling; ● Content that is offensive, profane, hateful, threatening, harmful, defamatory, libelous, harassing, or discriminatory (whether based on race, ethnicity, creed, religion, gender, sexual orientation, physical disability, or otherwise); and/or, ● Soliciting any unlawful behavior. Upon Coinbase’s request, you shall immediately comply with Coinbase’s instructions to modify or remove published content. Coinbase Content References You may wish to mention Coinbase in a consistent communication style and tone as Coinbase does. For examples of current copy for you to use in your marketing assets, please click here. Brand Use Guidelines You must comply with our trademark usage guidelines set out below when using Coinbase’s trademarks, service marks, trade names, logos, fonts, names of Coinbase software, products, and services, and any other Coinbase branding elements, whether registered or unregistered (collectively, “Coinbase Marks” or “Marks”) in your promotional and advertising materials. By using our Coinbase Marks you acknowledge that: Coinbase is the sole owner of those Marks; you promise not to use the Coinbase Marks except as expressly authorized by Coinbase; and all use of the Coinbase Marks and goodwill associated with your use will inure to the benefit of Coinbase. You agree not to take any action that is in conflict with Coinbase’s rights in, or ownership of its Marks, including without limitation registering any Coinbase formative trademark or domain name. Coinbase may review your use of the Coinbase Marks at any time and reserves the right to terminate, modify or require modification to any such use at any time. Trademark Usage Guidelines 1. You may only use the Coinbase Marks in educational, advertising, promotional, and sales material as authorized by Coinbase in this Guide and in the format provided here, or as otherwise provided to you by Coinbase. We reserve the right to prohibit CONFIDENTIAL V2 2023-02-23 the use of our Coinbase Mark in AdWord programs at our sole discretion. 2. You may not alter the image of the Coinbase Marks in any manner, including but not limited to, changing the proportion, color, or font of the Mark, or adding or removing any element(s) of the Mark. 3. The Mark must appear by itself with reasonable spacing between each side of the Mark and other visual, graphic, or textual elements, or as otherwise approved by Coinbase. Under no circumstances should the Mark be placed on any background which interferes with the visibility, readability or display of the Mark. 4. Do not combine our Coinbase Mark(s), either in whole or in part, with another mark(s) to create a new mark, domain name, or tagline (including #hashtags and slogans). 5. Do not use a registration ® with any Coinbase Mark. 6. Do not change any element of the Coinbase Mark through hyphenation, abbreviation, alternate spelling, spacing, pluralization, capitalization, or stylization. Prohibited examples: Cbase, C-Exchange, Coin-Base. 7. You may not use any Coinbase Mark to disparage Coinbase, its products or services, or in a manner that, in Coinbase’s sole discretion, may diminish or otherwise disparage or tarnish Coinbase’s goodwill in any of its Marks. 8. You may use Coinbase Marks only to promote Coinbase in your capacity as a Coinbase affiliate, as accessible and provided in your Impact account. Coinbase reserves the right, as it determines in its sole discretion, to modify these guidelines and/or the approved Coinbase Mark(s) at any time and to take appropriate action against any use without permission or any use that does not conform to this Guide. CONFIDENTIAL V2 2023-02-23