Introduction

This ReviewHub authenticity and moderation policy (the “Policy”) lays out the conditions under which user-generated content, including, but not limited to, ratings, reviews, images and multimedia (“Content”), which is (i) collected by a ReviewHub client (a “Client”) using ReviewHub's collection solutions and/or (ii) syndicated to a ReviewHub syndication partner (a “Syndication Partner”) via ReviewHub’s syndication solutions, would qualify as Authentic Content, as defined below, and pass ReviewHub’s moderation process.

The purpose of this Policy is to encourage the collection, display and syndication of Authentic Content, as defined below, to protect, inform and guide shoppers, consumers, suppliers, brands and retailers, and to promote an honest, vibrant and content-rich marketplace.

This Policy is incorporated by reference into the agreements between ReviewHub and its Clients and Syndication Partners, as applicable.

Authentic Content

Authentic Content ReviewHub defines “Authentic Content” as Content that is:

1. Submitted by (i) a human being who purchased a product or service (the “Product”) for his or her personal use or use by one or more members of his or her household or family unit (the “Consumer”) or (ii) in the case where the Consumer purchased the Product for one or more individuals, the recipient of such Product (a “Recipient”, and together with the “Consumer”, the “Reviewer”);

2. Not incentivized (i.e. the Reviewer did not receive, and was not under any impression that he, she or someone else would receive, a direct or indirect incentive or inducement to submit Content);

3. Not fraudulent (i.e. the Reviewer did not have a direct or indirect past, present or future interest, whether positive or negative, to submit a review at the time of submission);

4. Not pre-vetted(i.e. prior to allowing the Reviewer to submit Content, the Client did not deduce whether the Reviewer’s sentiment would be positive or negative, and in the case where the Client was able to deduce the former or the latter, did not facilitate or impinge in any way the Reviewer’s ability to submit Content);

5. Accompanied by specific data points in respect of the Reviewer, which include:

   1. Timestamp;

   2. Name;

   3. Email address or phone number;

   4. IP address;

   5. Device information; and

   6. Digital fingerprint (“Data Points”).

Collect

Review Submission Conditions

Reviewers are required to agree to Wholescale’s terms and conditions, and/or the Client’s terms and conditions, as applicable, prior to submitting Content.

Importing Legacy Content

Clients may import legacy Authentic Content, which may be eligible for syndication, in both cases and in each instance, at ReviewHub’s sole discretion.

Relationships to Client

All contextual information concerning the Reviewer shall be disclosed by the Reviewer in accordance with this Policy. If one of the following circumstances applies to the Reviewer, the Reviewer, and/or the Client in the event the Client is aware prior, during or after the Reviewer’s Content submission, shall disclose the applicable circumstance to ReviewHub:

• The Reviewer is an employee or agent of the Client, product manufacturer, retailer, or a related party; or

• The Reviewer was requested, encouraged, paid, gifted, induced or incentivized to submit Content in exchange for an inducement of any kind, directly or indirectly.
  
  

Moderation

When Content enters ReviewHub’s portal, it undergoes authentication and moderation (“ReviewHub’s Authentication and Moderation System”, also referred to as “RAMS”) to determine whether it may be displayed by a Client and/or syndicated to Syndication Partners. If Content qualifies as Authentic Content that is not determined to be Unacceptable Content, as defined below, it will be displayed and syndicated accordingly. Content that is prima facie Authentic Content may ultimately be deemed to be non- Authentic Content (“Deemed Non-Authentic Content”) when further evaluated in RAMS. Authentic Content, including Authentic Content containing spelling and grammatical errors, will display and syndicate “as is”, provided RAMS does not determine or suspect that such Authentic Content is profane, abusive, manipulative, illegible, incomprehensible, inapplicable or unacceptable (“Unacceptable Content”, and together with Deemed Non-Authentic Content, “Rejected Content”). Rejected Content will receive a Label, as defined below, and will either be denied display and syndication or, if applicable, undergo further evaluation within RAMS to determine if such content was incorrectly qualified as Rejected Content. In such a case, such Content would be relabeled accordingly and made available for display and syndication.

In respect of images and multimedia, in addition to moderation within RAMS, further moderation occurs by ReviewHub's human moderation process whereby a human being determines whether such content should be flagged as Rejected Content.

In certain circumstances, Clients may moderate Authentic Content to allow or disallow Authentic Content to display on their respective digital assets (“Client-Moderated Content”). Client-Moderated Content that is allowed, disallowed, pinned, boosted, deleted, published, unpublished, archived or unarchived by a Client does not impact whether that particular piece of Client-Moderated Content syndicates to Syndication Partners.

Authenticity and Moderation Labels

While authenticating and moderating Content, RAMS may determine that certain Content cannot be displayed or syndicated for a particular reason, and such reasons will result in the corresponding pieces of Content receiving specific labels (“Labels”), which are described here:

1. Duplicate: Content that is at least the second piece of Content submitted by a Reviewer within a certain period of time in respect of a Product.

2. Incentivized: Content that was produced and/or submitted in the context of an incentive or inducement of any kind.

3. Fraud: Content that was submitted in the context of fraud, whether the Reviewer’s sentiment is negative or positive.

4. Pre-Vetting: Content that was submitted following the Client’s awareness, to any extent, of the Reviewer’s sentiment, whether negative or positive.

5. Technical Data Point: Content that, when submitted, was not accompanied by sufficient technical Data Points.

6. SafetyRisk: Content that poses a safety risk to an individual, a group or the public.

7. Abuse or Profanity: Content that contains specific profane or abusive language or that could be interpreted or construed as being profane or abusive.

8. Illegible or Incomprehensible: Content that is illegible or incomprehensible.

9. Personal: Content that contains personally identifiable information.

10. URL: Content that contains a URL.

11. Inapplicable: Content that does not apply to the applicable Product under review.

12. Unacceptable: Content that does not fall under an above-mentioned Label, but nevertheless is not within the spirit of this Policy.

Display and Syndication

ReviewHub works with Clients and Syndication Partners to determine the phrasing of attribution tags that accompany displayed and syndicated Content. By default, Content collected and syndicated by ReviewHub shall have the following attribution tag: Review collected by ReviewHub.

Overall Ratings and Review Totals

The overall star rating and review totals per product should exclude all non-Authentic Content and be updated as new Authentic Content is displayed and/or syndicated.

Reviews that only comprise a star-rating and not a written review shall be excluded from display and syndication.

Collaboration

Clients and Syndication Partners are encouraged to communicate with their ReviewHub counterparts to discuss the terms of this Policy and make suggestions to further its purpose.

Changes to the Policy

ReviewHub may, in its sole discretion, update this Policy as it deems necessary to advance the spirit and function of this Policy.

Actions

ReviewHub may, at its sole discretion, audit, hide, unhide, approve, delete, archive and unarchive Content, and discuss with one or more members of a Client or Syndication Partner’s team any suspected violation of this Policy, along with steps to remediate violations and/or terminate an ongoing Agreement.