Effective Date: June 3, 2025
1. Purpose
This policy describes how 37x.com (“37x,” “we,” “our,” or “us”), operating as an affiliate-marketing platform, prevents the sale or promotion of counterfeit goods, monitors affiliate compliance, and responds to suspected counterfeit incidents.
2. Scope
Applies to:
All product listings sourced via affiliate suppliers.
Domains and URLs used by affiliates that link to actually counterfeit or suspected counterfeit products.
Any reports or evidence (from brands, customers, or third parties) alleging that an affiliate is marketing counterfeit items.
It does not cover trademark misuse or general takedown requests, which are addressed by separate policies.
3. Definitions
Affiliate Supplier: A merchant approved to list products via 37x’s vetted affiliate networks.
Counterfeit Goods: Items that bear a brand name, logo, or design without authorization, intended to appear genuine or deceive consumers.
Infringing Supplier: Any affiliate or partner found to be distributing or promoting counterfeit merchandise.
4. Supplier Vetting & Onboarding
Vetted Networks Only:
We partner exclusively with reputable, industry-leading affiliate networks (e.g., Rakuten, CJ Affiliate, Awin, Sovrn etc..).
Each supplier must pass network-level verification (e.g., business registration, payment history, customer feedback).
Contractual Obligations:
Affiliates must agree to terms prohibiting counterfeit goods, including indemnification clauses and rights for immediate suspension.
Suppliers confirm, in writing, that all products listed are genuine and sourced through authorized channels.
5. Automated & Manual Filtering
Negative Keyword Filters:
We maintain a dynamic list of terms commonly associated with counterfeit or high-risk products (e.g., repeated “designer” misspellings, suspiciously low price indicators).
Any listing matching these terms is flagged for manual review.
Image Recognition & Metadata Checks:
Where feasible, we employ networked services to detect likely counterfeit images or suspicious EXIF metadata (e.g., stock photos used on multiple unauthorized retailer sites).
Manual Audits:
Periodic sampling of affiliate listings for high-volume or high-traffic categories (e.g., luxury handbags, electronics).
Customer review analysis: High return rates or complaints about authenticity trigger an audit.
6. Reporting & Investigation of Suspected Counterfeits
Receiving Reports:
Brands, third parties, or customers may report suspected counterfeit listings by emailing [email protected] with subject “Counterfeit Report – [Product Details].”
Include URLs, screenshots, order details, or any relevant purchase evidence.
Initial Verification (Within 72 Hours):
Our Compliance Team reviews the evidence, compares it to known genuine product identifiers (e.g., serial number ranges, packaging details), and contacts the affiliate supplier for documentation of product authenticity (invoices, supply chain records).
Decision Criteria:
Clear Evidence of Counterfeit: e.g., identical packaging errors, mismatched logo, admission by supplier.
Insufficient Evidence: If the affiliate provides valid chain-of-custody or authenticity proof, we may clear the supplier.
Inconclusive Evidence: We may temporarily suspend the listing pending deeper investigation or third-party authentication.
7. Enforcement Actions
Removal of Counterfeit Listings:
If products are confirmed counterfeit, 37x will remove the listing across all its domains within 48 hours of confirmation.
Supplier Suspension & Termination:
The offending supplier is immediately suspended from our vetted pool.
A full investigation follows; if confirmed, the supplier’s affiliate relationship is terminated, and no reinstatement is allowed without rigorous re-vetting.
Notification:
Notify the reporting party (brand or customer) of the action taken.
Inform the supplier of removal and suspension, requesting documentation if they believe there was an error.
8. Preventive Measures
Regular Training & Guidelines for Affiliates:
Provide clear documentation on how to avoid counterfeit risk (e.g., only use approved authorized supplier feeds, avoid suspicious “too good to be true” deals).
Blacklist High-Risk Suppliers:
Maintain a shared list of suppliers with known counterfeit history—these are blocked from re-entering our affiliate pool.
Price Anomaly Monitoring:
Automated alerts if a product’s price deviates more than 50% below the average market price for a known genuine item.
9. Customer Protection & Refunds
If a consumer purchases a counterfeit item via an affiliate link, we will:
Facilitate communication between the customer and the affiliate or brand to arrange a refund.
Assist in escalating disputes if the affiliate refuses to refund for a confirmed counterfeit.
Provide guidance on safe purchasing practices and direct them to official retailers.
10. Collaboration with Brands & Law Enforcement
When a credible brand or law enforcement agency provides evidence of large-scale counterfeit distribution, we cooperate fully by:
Sharing affiliate transaction data (order IDs, shipping addresses) as permitted under privacy laws.
Assisting in broader takedown efforts (e.g., submitting evidence to search engines or other marketplaces).
11. Appeals & Reinstatement
Affiliate Reinstatement:
A suspended supplier may appeal by submitting incontrovertible proof of authenticity (e.g., direct letters from brand, audited supply-chain invoices).
A re-audit is conducted; if all criteria are met, the supplier may be reinstated under probationary status (e.g., limited category access).
Customer Disputes:
If a customer disputes that an item is counterfeit, we request additional proof (e.g., official authentication report).
12. Policy Revisions
37x reserves the right to update this Counterfeit Goods Policy at any time. Substantial changes will be announced on the Help Center and communicated to all affiliate partners. Continued participation after notice indicates acceptance of the updated policy.