Legal documentation · loupixa.com

Disclosure Policy

Version 1.3 · Effective: [03 / 05 / 2026] · Applies to: Clippers and Brand clients

ℹ

LoupiXa's role — intermediary, not editor. LoupiXa Agency acts as an intermediary service provider. It does not produce, edit, or publish the content distributed by Clippers. Clippers are solely and exclusively responsible for the content they publish, including the presence and compliance of any disclosure mention.

Art. 1

Scope

This Policy applies to all content published by Clippers in connection with a paid LoupiXa campaign, across all platforms — TikTok, Instagram Reels, YouTube Shorts, and any other platform on which LoupiXa campaigns are distributed.

Art. 2

Legal Framework

Source	Requirement
Law n°2023-451 of 9 June 2023 (as amended, Ordinance n°2024-1006)	Art. 5: mandatory mention "Publicité" or "Collaboration commerciale", clear, legible, and identifiable, visible for the entire duration of the promotion
Code de la consommation Art. L121-3	Failure to indicate commercial intent constitutes a deceptive commercial practice by omission
Code de la consommation Art. L132-2	Deceptive commercial practices: up to 2 years imprisonment and a fine of up to 300,000 euros
Digital Services Act (Reg. EU 2022/2065, Art. 26)	Commercial communications must be clearly identified as such
ARPP recommendations	Accepted mentions: "Publicité", "Sponsorisé par", "En partenariat avec"

Art. 3

The Disclosure Obligation

Every piece of content published by a Clipper in connection with a paid LoupiXa campaign constitutes sponsored content and must be disclosed as such. This obligation rests exclusively and personally on the Clipper. There are no exceptions.

3.1 — The Mandatory Mention

Wording: the mention must be "Publicité" or "Collaboration commerciale". Alternatives such as "#ad" or "#sponsored" must be pre-approved in writing by LoupiXa before use.

Clarity and legibility: the mention must be clearly readable — font size, colour, and contrast must make it easily visible against the background of the video.

Identification: the mention must be sufficiently prominent that a viewer who is not actively looking for it can still identify that the content is commercial.

Duration: the mention must be visible for the entire duration of the video. A disclosure that disappears after the first few seconds does not comply with the requirements of Law n°2023-451.

3.2 — Insufficient Disclosure

A brand logo alone — a logo does not substitute for the textual mention.

A mention in the video description, caption, or bio only — the mention must appear on the video itself.

A hashtag (#ad, #sponsored) buried among multiple other hashtags in the description.

A verbal mention only, without a corresponding visible on-screen text overlay.

A disclosure in a language other than French when the content targets a French-speaking audience.

Platform-native paid partnership labels as the sole disclosure — these do not satisfy Law n°2023-451 independently.

Art. 4

Platform-Specific Standards

TikTok — Short-form video (primary distribution platform)

REQUIREDOn-screen text overlay reading "Publicité" or "Collaboration commerciale" — visible for the entire duration of the video, with sufficient contrast for legibility.

REQUIREDDisclosure mention at the start of the video description (first line, before any hashtags or links).

REQUIREDTikTok native "Branded Content" toggle activated in Creator Tools.

RECOMMENDEDOverlay visible from the first frame of the video.

RECOMMENDEDVerbal mention of the commercial partnership within the first 5 seconds of audio.

Instagram Reels — Short-form video (secondary distribution platform)

REQUIREDOn-screen text overlay reading "Publicité" or "Collaboration commerciale" — visible for the entire duration of the Reel.

REQUIREDInstagram native "Paid Partnership" label activated (Advanced Settings).

REQUIREDDisclosure mention at the start of the Reel caption (first line, before hashtags or emoji).

RECOMMENDEDVisible in the thumbnail or cover frame if the Reel is shared to grid.

YouTube Shorts — Short-form video (tertiary distribution platform)

REQUIREDOn-screen text overlay reading "Publicité" or "Collaboration commerciale" — visible for the entire duration of the Short.

REQUIREDYouTube "Paid Promotion" checkbox activated in video settings.

REQUIREDDisclosure mention in the video description (first paragraph).

RECOMMENDEDVerbal disclosure within the first 5 seconds of the Short.

⚠

Platform-native labels are not sufficient alone. Activating TikTok's Branded Content toggle, Instagram's Paid Partnership label, or YouTube's Paid Promotion checkbox satisfies each platform's own policy requirements — but does not, independently, satisfy the requirements of Law n°2023-451, which requires a visible on-screen textual mention throughout the video's duration. Both obligations must be satisfied simultaneously.

Art. 5

Compliant vs Non-Compliant Disclosure

Examples of Compliant Disclosure

✓"Publicité" text overlay displayed continuously throughout the video, high contrast, clearly legible.

✓"Collaboration commerciale avec [Brand]" at the start of the video description, before hashtags.

✓On-screen text overlay + platform-native paid partnership label activated simultaneously.

✓Verbal mention within first 5 seconds + on-screen text overlay maintained for the full duration.

Examples of Non-Compliant Disclosure

✕Brand logo displayed on-screen without any accompanying textual disclosure mention.

✕"#ad" placed as the 15th hashtag in the description, with no mention on the video itself.

✕"Publicité" overlay visible only for the first 2 seconds of the video, then disappearing.

✕Platform-native paid partnership label activated, but no on-screen text overlay on the video.

✕"Sponsorisé" in small, low-contrast text overlaid on a visually complex background.

✕Verbal-only disclosure with no corresponding on-screen text visible throughout the video.

Art. 6

Post-Publication Verification

URL submissionWithin 24h of publication

Clipper submits published video URL with screenshot confirming on-screen disclosure. Mandatory self-report.

Automated checkAt URL submission

Verification of platform-native disclosure label (Branded Content / Paid Partnership).

Sampling reviewWithin 48h

On-screen text: presence, legibility, duration, positioning — on a sampled basis only.

Payment decisionPer campaign payment cycle

Payment released only for content submitted with evidence of compliant disclosure.

ℹ

Content submitted without evidence of a compliant disclosure is not eligible for payment. This applies regardless of performance metrics, view count, or campaign standing.

Art. 7

Sanctions

Violation	Sanction
First failure	Written warning (Strike 1). Payment withheld pending correction within 24 hours. Payment permanently forfeited if not corrected within 7 days.
Second failure, or first failure not corrected within 24 hours	Strike 2 — payment permanently forfeited. Suspension from active campaigns for 30 days.
Third failure	Strike 3 — permanent exclusion from the LoupiXa network.
Deliberate concealment	Immediate exclusion from the network without prior warning. All pending payments frozen.

Art. 8

Contact

Compliance queries	rights@loupixa.com — subject: "Disclosure Policy Query"
Report non-compliance	rights@loupixa.com — subject: "Disclosure Compliance Report"
General contact	contact@loupixa.com
Postal address	47 rue Vivienne, 75002 Paris, France
Response time	7 working days for compliance queries; 24 hours for urgent disclosure issues
DGCCRF	economie.gouv.fr/dgccrf
ARPP	arpp.org