Guidelines for Partners, Brokers and Affiliates
Important: All promotion of By Miles must be clear, fair and not misleading.
By Miles is authorised and regulated by the Financial Conduct Authority (FCA) and like any FCA regulated product there are strict guidelines for promoting By Miles.
Please remember that anything (advert, email, social media post etc.) that invites or induces a customer to purchase, is a ‘Financial Promotion’ under the Financial Services and Markets Act (FSMA) 2000. The FCA will view it as you committing a criminal offence if you make a financial promotion that has not been approved by us.
We approve all financial promotions to ensure:
- they take into account the target market and their needs and understanding
- they are clear, fair and not-misleading
- they have been approved by an FCA authorised person, in line with the FSMA 2000
A document with factual information only, e.g. a review of different types of insurance, would not be considered a financial promotion.
Retweeting someone else is seen as if the original message came from you, so be careful. Retweets can be a financial promotion.
Q) Do I need to be FCA regulated or an Appointed Representative of By Miles in order to promote By Miles?
A)You do not need to be FCA regulated or an Appointed Representative to promote By Miles, as long as you are only providing information about By Miles and take no other steps to assist in the conclusion of a contract of insurance.
While “arranging insurance” is deemed a regulated activity, activities which only consist of the provision of information are excluded under article 33B of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001.
This is important – as a non regulated partner your engagement with a potential customer must be limited to an ‘arms length’ passive display of information.
You must not take it any further – for example you must not:
- offer advice
- help the customer with their quote or pre-ask any questions
- actively persuade the customer to join
- link directly into our full quote page
- contact a customer about their renewal
Such activities would constitute “arranging insurance” and amount to regulated activities for which you would need to be an Appointed Representative or approved by the FCA.
You may still use the referral tracking links to ByMiles.co.uk, the Quick Quote Widget, our adverts, our reviews or any other promotional material we make available to you.
You must consult By Miles in advance of using any materials not previously approved or before conducting any activity which could be considered regulated activity.
Important: You are not regulated or authorised
You must not suggest or imply to customers that you are is regulated or authorised. Provided that you are only providing information, you do not need to be authorised or regulated and it is an offense to say you are regulated when you are not.
Promoting By Miles: Playing it safe
1) You can use any advert we’ve put on the adserver. To access the adserver just log in to your Referrer account.
Please do not alter these adverts and make sure you use the links we give you. The reason for this is that, if an advert becomes out-of-date or incorrect, it enables us to automatically update any advert without you needing to make any changes.
2) You can use the skeleton review of By Miles. We know our car insurance is very different to a lot of car insurance policies out there. We’ve put together a review so you’ve got clear facts on what we do offer, what we don’t offer and how the policy works.
3) If in doubt, ask. If you’re not sure whether your content is a financial promotion or not, contact us and wait for us to approve it before you release the material to the general public or your users.
4) A financial promotion won’t be approved if it says anything about By Miles that isn’t true (in all cases) or that could mislead customers e.g. you cannot say “By Miles is cheaper” or “By Miles offer cheaper car insurance“.
Although we might be cheaper for some people, we’re not necessarily cheaper for everyone. As a result, a blanket statement like “By Miles offers cheaper car insurance” isn’t true.
You can say “By Miles might offer you cheaper car insurance if you are a lower mileage driver“.
Similarly it must be clear (for example not putting text that is hard to read due to a small font, or text that is overly complex).
5) Many partners and affiliates run multiple sites and apps. That’s fine. But you do need to ensure you tell us about every site and/or app where you’d like to promote By Miles before you put us on that site. We need to check each site and app individually to ensure they’re appropriate and that our adverts are suitable for that audience.
6) Promoting By Miles: Making sure you don’t get it wrong
Please re-read our terms and conditions with respect to:
- Clause 12: Your Marketing of By Miles
- Clause 13: Email Marketing and Text Message Marketing of By Miles
- Clause 14: Prohibited Marketing Activity
For the avoidance of doubt, By Miles may consider any breach of the above clauses to be a material breach of the terms and conditions.
7) No spam, fraud or illegal promotions
Neither the regulator nor By Miles will tolerate any spam, fraud or any other type of illegal promotion.
It’s normally very obvious when affiliates and referrers aren’t playing by the rules.
For the avoidance of doubt, we won’t pay commissions generated through spam, fraud, churning (buying policies just to generate commissions) and we will consider these a material breach of the terms and conditions.
Please ensure you follow our terms and conditions.
8) Also see “Who can promote By Miles?”
Read more:
- Referral programme homepage
- Apply to the referral programme
- Referral programme log in
- Referral programme FAQs
- Referrer guidelines
- Skeleton Review of By Miles
- Quick Quote Widget for Partners
- Logos and images for By Miles Partners
