Customer Commitment | HSO Terminals

01. Introduction and Scope

1.1 Purpose

HSO Terminals ("Company," "we," "us," or "our") is committed to conducting all marketing, advertising, and commercial activities with the highest standards of integrity, transparency, and legal compliance. This Legal and Marketing Compliance Policy outlines the principles and regulations that govern our promotional activities, digital advertising, and customer communications across all platforms, including our website, the TOS Platform, and the Procurement Trade Desk (PTD).

1.2 Scope of Application

This policy applies to:

All marketing and advertising campaigns (digital, print, social media)
Sales and commercial communications
Customer data collection and processing activities
Third-party vendors and partners acting on behalf of HSO Terminals
All jurisdictions where HSO Terminals operates, with particular attention to U.S. federal and state laws (including Florida), as well as international regulations (GDPR, CCPA)

1.3 Policy Owner

The Legal Department, in coordination with the Marketing and Sales leadership, is responsible for the implementation, maintenance, and enforcement of this policy.

02. Legal and Regulatory Framework

HSO Terminals adheres to all applicable federal, state, and international laws governing marketing and advertising practices.

2.1 Federal Trade Commission (FTC) Act (U.S. Federal)

The FTC Act prohibits "unfair or deceptive acts or practices in or affecting commerce." This is the foundation of all U.S. advertising law.

2.2 State Laws (Including Florida)

Florida law, in line with federal regulations, prohibits any advertising practice that misleads the consumer. Specific attention is paid to:

Florida Deceptive and Unfair Trade Practices Act (FDUTPA)
Florida False Advertising Law

2.3 International Regulations

GDPR (EU): Governs data privacy and consent for users in the European Economic Area.
CCPA/CPRA (California): Governs data privacy rights for California residents.
CASL (Canada): Regulates commercial electronic messages.
CAN-SPAM Act (U.S.): Regulates commercial email.

03. Truth in Advertising and Marketing Communications

3.1 Prohibited Practices

We strictly prohibit any advertising or marketing practice that could be considered deceptive, misleading, or unfair. This includes:

Prohibited Practice	Description	Example / Relevance to HSO
False or Exaggerated Claims	Making claims about our products or services that cannot be substantiated.	Claiming the TOS Platform guarantees a specific ROI without clear context and disclaimers.
Omission of Material Information	Leaving out information that is crucial for a consumer to make an informed decision.	Not disclosing that certain PTD services have eligibility requirements or geographic limitations.
Bait and Switch	Advertising a product or service with no intention of fulfilling the offer, then attempting to sell a different, usually more expensive, item.	Promoting a "free terminal audit" but using it solely as a lead generation tool for paid consulting without disclosure.
Misleading Comparisons	Unfairly comparing our products to competitors without factual basis.	Making unsubstantiated claims about being "superior to all competitors" without data.

3.2 Substantiation Requirements

All claims made in our marketing materials must be:

Truthful and Accurate: Reflecting the actual capabilities of our TOS Platform and PTD services.
Substantiated: Supported by evidence (e.g., case studies, data from our platform, client testimonials with permission).
Clear and Conspicuous: Disclaimers and material terms must be easily noticeable and understandable.

3.3 Testimonials and Endorsements

All testimonials must reflect the genuine opinions, findings, or experiences of the endorser.
We will disclose any material connections between HSO Terminals and an endorser (e.g., paid influencers, partners) as required by FTC guidelines.
Client logos used on our website are done so with explicit permission.

04. Data Protection and Privacy in Marketing

4.1 Data Collection and Consent

In alignment with our Privacy Policy and global data protection laws:

Explicit Consent: We obtain explicit, informed consent from users before collecting their personal data for marketing purposes, except where a legitimate interest applies.
Clear Notice: Users are provided with clear, accessible information about what data is collected, how it will be used, and with whom it may be shared.
Opt-In Mechanisms: We use clear opt-in mechanisms (e.g., unchecked checkboxes) for email subscriptions and marketing communications. Pre-checked boxes are strictly prohibited.

4.2 Data Security

We implement appropriate technical and organizational measures to protect personal information collected through marketing activities against unauthorized access, loss, or disclosure. This includes encryption, access controls, and regular security assessments.

4.3 Third-Party Marketing Partners

When we engage third-party vendors for marketing services (e.g., email marketing platforms, advertising agencies), we:

Conduct due diligence on their data protection practices.
Enter into Data Processing Agreements (DPAs) that comply with GDPR and other applicable laws.
Ensure they process data only on our instructions.

05. Digital Advertising and Platform Compliance

5.1 Platform Policies

We comply with the advertising policies of all digital platforms we use, including but not limited to:

Google Ads: Prohibits ads for dangerous products, misleading claims, and non-compliance with their destination requirements.
LinkedIn Marketing Solutions: Requires adherence to their ad policies regarding professional content and data usage.
Meta (Facebook/Instagram): Restricts ads for certain regulated products and requires compliance with their special ad categories.

5.2 Cookies and Tracking Technologies

As detailed in our Cookie Policy:

We use cookies and similar tracking technologies to deliver targeted advertising and analyze campaign performance.
User Consent: We obtain prior consent for non-essential cookies (including marketing cookies) via our cookie banner.
Cookie Settings: Users can manage their preferences at any time through the "Cookie Settings" link in our website footer.

5.3 Retargeting and Behavioral Advertising

We engage in retargeting to show relevant ads to users who have previously visited our website. This is done in compliance with platform policies and data protection laws, and users can opt out through their ad settings on the respective platforms or via the Digital Advertising Alliance.

06. Intellectual Property and Copyright

6.1 Use of Content

We respect the intellectual property rights of others and expect the same in return. In all marketing materials, we ensure that:

Images and Videos: All visual content is either created in-house, licensed from reputable stock providers (with appropriate licenses), or used with explicit permission from the copyright holder.
Music and Audio: Any audio content used in videos or advertisements is properly licensed.
Text and Copy: All written content is original or properly attributed.

6.2 Trademark Usage

Our trademarks (HSO Terminals, HSO Trade, TOS Platform, Procurement Trade Desk, logos) are valuable assets and must be used consistently and correctly.
Use of third-party trademarks in our marketing is done only to refer to compatible technologies in a manner that does not imply endorsement or affiliation without permission.

6.3 Consequences of Infringement

Unauthorized use of copyrighted or trademarked material can result in:

Legal action, including lawsuits for damages.
Takedown notices and removal of content.
Reputational damage and loss of trust.

07. Advertising to Minors and Vulnerable Audiences

7.1 Policy

HSO Terminals' products and services (terminal management software, fuel trading, B2B services) are not intended for or targeted at minors (individuals under 18 years of age). We do not knowingly collect data from or market to children.

7.2 Prohibited Practices

In the event our content is accessible to minors (e.g., general website browsing), we ensure our marketing does not:

Exploit the inexperience or credulity of children.
Promote products or services that are illegal for minors (alcohol, gambling, etc.).
Use imagery or language that is sexually suggestive, violent, or otherwise inappropriate for a general audience.

7.3 Compliance

We adhere to the Children's Online Privacy Protection Act (COPPA) in the U.S. and equivalent laws in other jurisdictions.

08. Regulated Products and Services

8.1 Applicability

While HSO Terminals primarily provides software and B2B commercial enablement services (which are generally not considered "regulated products" like alcohol or tobacco), our PTD services may involve facilitating transactions for fuel products, which are subject to specific regulations.

8.2 Compliance Requirements

Age Restrictions: We ensure that all transactions comply with applicable age restrictions for the purchase, storage, and transport of fuel products.
Legal Warnings: Any marketing related to the use of fuel products will include necessary safety and legal warnings where required by law.
Jurisdictional Compliance: We comply with all state and federal laws regarding the marketing and sale of fuel products, including environmental and safety regulations.

09. Unfair Competition and Comparative Advertising

9.1 Policy

HSO Terminals competes fairly and ethically. We prohibit:

Defamation: Making false or disparaging statements about competitors, their products, or their business practices.
Misleading Comparisons: Comparing our products to competitors in a way that is unfair, deceptive, or not based on verifiable facts.
Passing Off: Imitating the trademarks, branding, or marketing materials of competitors.

9.2 Consequences of Violation

Engaging in unfair competition can lead to:

Fines and legal sanctions under the Florida Antitrust Act and federal laws.
Lawsuits from competitors.
Investigations by regulatory bodies.

10. Email Marketing and CAN-SPAM Compliance

10.1 CAN-SPAM Act Requirements

All commercial emails sent by HSO Terminals or on our behalf comply with the CAN-SPAM Act:

Accurate Header Information: "From," "To," and "Reply-To" fields accurately identify the sender.
Clear Subject Lines: Subject lines are not deceptive or misleading.
Identification as an Ad: The email is clearly identified as an advertisement or solicitation.
Physical Address: Each email includes our valid physical postal address (204 Hays St, Batesville, Mississippi, 38606).
Opt-Out Mechanism: Each email includes a clear and conspicuous explanation of how to opt out of future emails.
Prompt Processing: Opt-out requests are processed within 10 business days.

10.2 Consequences

Violations of CAN-SPAM can result in penalties of up to $50,952 per separate email .

11. Promotions, Contests, and Giveaways

11.1 Current Status

As of the effective date of this policy, Huron Smith Oil / HSO Terminals does not currently offer any promotional campaigns, contests, or giveaways. This section serves as a framework for any future activities.

11.2 Future Promotions Framework

Should HSO Terminals offer any promotions in the future, the following principles will apply:

Official Rules: Clear, written official rules will be published and accessible.
Eligibility: Eligibility requirements (age, residency, etc.) will be clearly stated.
No Purchase Necessary: Where applicable, sweepstakes will include a no-purchase-necessary method of entry.
Compliance: All promotions will comply with applicable federal, state, and local laws.

12. Reporting and Enforcement

12.1 Reporting Violations

Employees, partners, or clients who become aware of a potential violation of this policy should report it immediately to:

Email: legal@hsoterminals.com
Confidential: Reports can be made confidentially and will be investigated promptly.

12.2 Consequences of Non-Compliance

Failure to comply with this policy may result in:

Disciplinary action, up to and including termination of employment.
Termination of contracts with partners or vendors.
Legal action against the responsible individual or entity.
Requirement to remedy the violation (e.g., correcting misleading ads, issuing clarifications).

13. Training and Awareness

HSO Terminals provides regular training to relevant employees (Marketing, Sales, Product) on:

The requirements of this policy.
Key legal and regulatory frameworks (FTC, GDPR, CAN-SPAM).
Best practices for ethical marketing and data protection.
How to identify and report potential violations.

14. Policy Review and Updates

This Legal and Marketing Compliance Policy will be reviewed at least annually by the Legal Department and updated as necessary to reflect changes in the law, our business operations, or industry best practices. The "Effective Date" at the top of this policy will be updated upon any revision.

15. Contact Information

For questions or concerns regarding this policy or any marketing compliance matter, please contact:

Department	Contact Information	Purpose
Legal Department	legal@hsoterminals.com	Formal compliance inquiries, reporting violations
Marketing Department	sales@hsoterminals.com	Questions about specific campaigns or materials
Data Protection / Privacy	support@hsoterminals.com	Privacy-specific concerns related to marketing data
Postal Address	Legal Department, Huron Smith Oil Co., Inc., 204 Hays St, Batesville, Mississippi, 38606, USA	Formal written correspondence

Appendix A: Accepted Payment Methods

As a convenience for our clients, HSO Terminals accepts the following payment methods for subscriptions and PTD services (processed securely via Stripe and other payment gateways):

Card Type	Logo	Notes
Visa		All major credit and debit cards accepted.
Mastercard		All major credit and debit cards accepted.
American Express		Accepted for all services.
Discover		Accepted for all services.