Can this be adapted to meet FTC disclosure rules ?

I've received an email from Winzip offering a registry tool

They state

================================================== =====
While we at WinZip Computing believe that the 3rd party
software promoted via our e-mail promotions are reputable
products (we always try them before promoting them),
please keep in mind that they are published by 3rd
parties and their development and operation is outside
the control of WinZip.

By purchasing, downloading or using any 3rd party
software promoted by WinZip, you acknowledge and agree
that WinZip has no responsibility or liability for any
harm, damage or other loss caused to you by that 3rd
party software.

You represent and warrant to WinZip that you have made
your own inquiries and decisions, and have not relied on
any representation by WinZip in determining to download,
purchase or install any such 3rd party software.
================================================== =====


Would this be acceptable to the FTC ?

(In particular, on a general note, would the word
'promote' be sufficient to indicate that you receive
commission on a sale)

And if so could it be adapted for the sale of ebooks.


Harvey


Disclaimer: I have not ploughed through all the FTC rules
so I might be way out with my question.