Last Updated Sep 23, 2016

"Affiliate Marketing" aka "Native Advertising" – the idea that a third party will promote a commercial VPN by creating content that closely resembles a review or feature. When a potential customer searches for a review of the service in question, legitimate reviews (if any exist) are drowned out by a sea of fake ones. This creates an environment in which inexperienced customers are usually fooled into thinking what they're reading is impartial and unbiased, and in turn, saddles them with something they don't need or want.

Let's look at each party's motivation in this model:

VPN Service – Wants to spread the word about their features, service, and to bring in new customers.

Affiliate – Wants to make money by selling VPN Service.

Customer – Wants an impartial and unbiased review of a given service. Wants a quality product.

When there isn't full disclosure between the VPN Service and the Affiliate, which party gets shafted with this model? The Customer – because interests are misaligned. The VPN Service makes money as do Affiliates, but the Customer oftentimes ends up with a worthless VPN that neither has professionals running it nor the inclination to provide a truly excellent product. This isn't just unethical, it's illegal in most developed countries.

Shortly after the project started, several companies were quick to update their terms and policies. Some of them were honestly trying to make improvements in the light of renewed transparency, others just wanted to look better on the comparison chart and considered it a place they could show off their willingness to improve. A number of companies decided to update one such policy, which is: requiring affiliates to provide full and prominent disclosure of their financial relationship with the company they advertise for – as per FTC rules (regardless of country or jurisdiction).

"Secret Shopping" / Undercover Investigation


So, what is the point of this? The point is that I approached each of these companies in secret as a potential affiliate. I then asked questions about their policies to see if they were serious about enforcing them.

I want to focus on the 5 companies on the Chart who have a policy in their terms requiring their affiliates to provide full and prominent disclosure. These companies are:

BolehVPN

IVPN

Private Internet Access

SaferVPN

Trust Zone

The plan:

Send an initial email/support ticket to each company stating that I have questions about their affiliate policies.

When they reply, state that I don't want to abide by their disclosure policy, and is it okay if I just ignore it.

If they say yes, it is okay to ignore it – approach the company (as TOPG), ask them to explain their decision, and what, if anything they plan to change for the future.

– approach the company (as TOPG), ask them to explain their decision, and what, if anything they plan to change for the future. If they say no, it is not okay to ignore it – point out that their existing affiliates don't follow the policy and ask further questions.

Here were the relevant responses:

BolehVPN

(Tepid response, not okay to ignore disclosure policy, but no penalty if not in compliance)


"I would still prefer that it's mentioned somewhere that it's an affiliate link"

–Reubster

(Tepid response when confronted about existing affiliates in non-compliance)

"We are beginning to look through our affiliates list and although we won't penalize, their earning level might be capped."

–Reubster

IVPN

(Weak response – Yes, okay to ignore disclosure policy)

"You are welcome to handle the situation at your discretion. We have made the legal requirements available to you as per the FCC [US], the "call" as to whether they apply to you or have jurisdiction over you is your own."

–John V.

(Strong response when confronted as TOPG)

"I'm disappointed at John's response. He doesn't have any authorisation to approve new affiliates and I'm betting he was not briefed on our new policy in which case our management is partly to blame. There is absolutely no 'call' to be made, the rules are clear and we intend on enforcing them strictly.

We've started the process of contacting our [existing] affiliates and are giving them until 31st August [2016] to comply [with this policy]. Failure to do so will result in [their] affiliate agreement with IVPN being cancelled."

–Nick P.

(I'll be following up on August 31st)

Update: 9-23-2016

I have been speaking to IVPN behind the scenes about the announcement that they finally made today – partially in response to this site's inquiry, they have made the decision