SPAIN Law and Practice Contributed by: Rubén Canales and Ignacio Temiño, Abril Abogados
appropriate for the channel, and suitable for all devic - es. Inserting the label at the end of a long caption, for example, where the consumer has to scroll or click to see it, or hiding it amongst other hashtags, will not be compliant. In addition, the label regarding the advertising nature of the reference or content must remain or be added when the influencer shares or “reposts” content on other social media, platforms or web pages. Autocontrol’s Influencers Code recommends includ - ing the disclosure at the very beginning of a post, in a title, a thumbnail, or an image. This Code includes an example list of recommended locations of the identi - fication for advertising references or content: • Blogger: include the identifying word or label in the title of the post; • Discord: include the identifying word or label in the title or at the beginning of the message or post, or state it aloud before discussing the promoted product or service; likewise, the identification of the advertising nature can be included in the title or subtitle of the channel; • Facebook: include the identifying word or label: (a) post: at the beginning of the text or on the image or video from the start; (b) story: at the beginning of each story, on the image or video; and (c) video/reel: at the beginning of the text or on the image or video from the start; in the case of live streams, the indication must be included from the start of the promotional action; • Instagram: include the identifying word or label: (a) post: at the beginning of the text or on the image or video from the start; and (b) story: at the beginning of each story, on the image or video; (c) video/reel: at the beginning of the text or on the image or video from the start; in the case of live streams, the indication must be included from the start of the promotional action; • Pinterest: include the identifying word or label in the title of the publication or superimpose the iden - tifying word or tag on the content itself; • Reddit: include the identifying word or label in the title of the message, post, or community;
• Snapchat: include the identifying word or label at the beginning of the message; • Spotify: include the identifying word or label in: (a) audio-only format: in the description or cover, or say it aloud before talking about the promot - ed product or service; and (b) video podcast or clip: from the start of the promotional action; likewise, the identification of the advertising nature can be included in the title of the live broadcast or video or in the description so that the identifying word or label is directly visible before accessing the content; • Threads: include the identifying word or label at the beginning of the message or superimpose the identifying word or label on the image or video content itself; • TikTok: include the identifying word or label: (a) post: at the beginning of the text or on the image or video from the start; (b) live streams: from the start of the promotional action; and (c) story: at the beginning of each story, on the image or video; • Twitch: overlay the identifying word or label on the live stream, video, or short while commenting on the product or service, or say it aloud before talk - ing about the promoted product or service; • Vlogs: superimpose the identifying word or label while commenting on the product or service, or state it out loud before talking about the promoted product or service; • X: include the identifying word or label at the beginning of the message or superimpose the identifying word or label on the image or video content itself; • YouTube: include the identifying word or label in: (a) video, short, live: from the start of the promo - tional action; it can also be included verbally before talking about the promoted product or service; (b) the tag provided by YouTube may be included as long as the advertising message is broad - cast at the same time or at times or stages close to it; and (c) publications: at the beginning of the text or on the image or video from the start.
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