Wholescale Authentication and Moderation Policy

Introduction

This Wholescale 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 Wholescale client (a “Client”) using Wholescale's collection solutions and/or (ii) syndicated to a Wholescale syndication partner (a “Syndication Partner”) via Wholescale’s syndication solutions, would qualify as Authentic Content, as defined below, and pass Wholescale’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 Wholescale and its Clients and Syndication Partners, as applicable.

Content Policy

Wholescale defines “Authentic Content” as Content that is:

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”);
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);
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);
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”).
Complies with our Incentivized Review Policy, in cases where the Content falls within the definition of Incentivized Reviews (see Incentivized Reviews Policy below).

Collection

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 Wholescale’s sole discretion. All imported content is subject to Wholescale’s internal authentication process and must comply with the Import Requirements section of this Policy.

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 Wholescale:

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.

Import Requirements

In instances where a Client or partner seeks to import or migrate existing reviews into Wholescale’s system (the “Imported Reviews”), the following standards shall apply to preserve authenticity and compliance:

Integrity of Original Content
Imported Reviews must be presented without alteration to the original text, rating, timestamp, reviewer identity, or other relevant metadata, except where formatting normalization is required (for example, character encoding or removal of malicious code). The review export provided by the Client must represent a complete, accurate, and unedited dataset of all relevant reviews from the source system, without omission, modification, or selective exclusion, and must faithfully reflect the original content as it was submitted.
Source Validation and Provenance
Clients submitting Imported Reviews must provide verifiable provenance data, including the original source system or platform, the original review IDs, associated timestamps, reviewer identifiers, and product-review mappings. Where available, export logs, hashes, or other integrity documentation must also be supplied.
Reviewer Identity Verification
Wholescale may require additional identity verification for reviewers associated with Imported Reviews, such as matching reviewer emails or user IDs to existing client records, requesting proof of purchase where feasible, or cross-validating data against order records.
Disclosure and Labeling
All Imported Reviews that meet the definition of an Incentivized Review must include the required disclosure and be labeled as “Incentivized” in accordance with Wholescale’s labeling and metadata standards. Imported Reviews that cannot be properly disclosed or labeled will be excluded from syndication.

No Imported Review may be syndicated, published, included in analytics, or otherwise distributed until it has successfully passed Wholescale’s internal authentication checks, and any such review — including legacy Authentic Content — shall be eligible for syndication only at Wholescale’s sole discretion. Wholescale reserves the right to audit the import process and to reject or quarantine reviews that fail verification.

Incentivized Reviews Policy

Wholescale defines “Incentivized Reviews” as any Content submitted by a Reviewer in exchange for, or in anticipation of receiving, any form of benefit, reward, or consideration (collectively, an “Incentive”). Incentives include, but are not limited to, monetary payments, discounts, rebates, gift cards, loyalty points, free or discounted products or services, sweepstakes entries, or any other thing of value provided as compensation for the submission of Content.

Content that meets the foregoing definition of an Incentivized Review shall be subject to, and must comply with, the following rules and obligations.

Disclosure Obligation
Any Content submitted in connection with an Incentive must include a clear, prominent, and easily understandable disclosure that the Reviewer received, was offered, or may receive an Incentive in exchange for the submission. Such disclosure must be displayed wherever the Content is published or displayed and must comply with all applicable laws, regulations, and industry guidelines, including, without limitation, the FTC Endorsement Guides and all equivalent consumer protection regulations in applicable jurisdictions.
To ensure consistency and compliance with applicable laws, industry standards, and partner requirements, Wholescale recommends the use of standardized disclosure language such as:
“[This review was collected as part of a promotion]” or similar.
Prohibition on Conditioned Sentiment
Incentives must not be promised, withheld, increased, decreased, or otherwise varied based on sentiment, tone or substance. Clients and third parties are prohibited from offering, promising, withholding, or modifying the nature or value of an Incentive based on whether the Content is positive, negative, or neutral.
Equal Opportunity Requirement
Where an Incentive is offered, it must be made available on substantially similar terms to all eligible Reviewers, regardless of the sentiment they are likely to express. Pre-screening, selective solicitation, or any other practice intended to influence sentiment is strictly prohibited.
Transparency and Recordkeeping
Clients must maintain accurate and complete records relating to Incentives, including the nature and terms of each Incentive, eligibility criteria, the disclosure language used, and the identity of Reviewers who received or were offered Incentives. Wholescale reserves the right to request and review such records at any time to verify compliance with these Standards.
Compliance and Enforcement
Any Content qualifying as an Incentivized Review that does not include the required disclosure or structured metadata shall be deemed non-Authentic and will not be syndicated, distributed, displayed, or otherwise made available through Wholescale’s services. Such Content will be excluded from all reporting, measurement, and analytics. Repeated or material violations of this requirement may, at Wholescale’s sole discretion, result in suspension or termination of services.

In addition to visible disclosure requirements, Wholescale will automatically label all Content meeting the definition of an Incentivized Review as “Incentivized” within its systems and data infrastructure. This labeling will be applied both to the Content itself and to all associated metadata, feeds, and syndication outputs in order to ensure compliance with applicable regulatory requirements, industry guidelines, and the policies of third-party platforms, distribution channels, and syndication partners.

Moderation

When Content enters Wholescale’s portal, it undergoes authentication and moderation (“Wholescale’s Authentication and Moderation System”, also referred to as “WAMS”) 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 WAMS. Authentic Content, including Authentic Content containing spelling and grammatical errors, will display and syndicate “as is”, provided WAMS 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 WAMS 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 WAMS, further moderation occurs by Wholescale'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, WAMS 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:

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.
Incentivized: Content that was produced and/or submitted in the context of an incentive or inducement of any kind.
Fraud: Content that was submitted in the context of fraud, whether the Reviewer’s sentiment is negative or positive.
Pre-Vetting: Content that was submitted following the Client’s awareness, to any extent, of the Reviewer’s sentiment, whether negative or positive.
Technical Data Point: Content that, when submitted, was not accompanied by sufficient technical Data Points.
Safety Risk: Content that poses a safety risk to an individual, a group or the public.
Abuse or Profanity: Content that contains specific profane or abusive language or that could be interpreted or construed as being profane or abusive.
Illegible or Incomprehensible: Content that is illegible or incomprehensible.
Personal: Content that contains personally identifiable information.
URL: Content that contains a URL.
Inapplicable: Content that does not apply to the applicable Product under review.
Unacceptable: Content that does not fall under an above-mentioned Label, but nevertheless is not within the spirit of this Policy.

Fraudulent Content Policy

“Fraudulent Content” refers to any user-generated review that is false, deceptive, or otherwise undermines the authenticity and integrity of the review ecosystem. Fraudulent Content includes, without limitation, reviews that are:

Inauthentic or Fabricated
Reviews written by individuals who have not actually purchased, used, or received the product, or reviews generated by bots, internal employees, or paid parties posing as genuine customers.
Incentivized Without Disclosure
Reviews submitted in exchange for compensation — including free products, discounts, payments, or any other form of value — without a clear and conspicuous disclosure of that incentive, as required under the FTC Endorsement Guides and other applicable laws.
Manipulated or Misleading
Reviews that have been selectively published to highlight only positive sentiment, that have been suppressed to hide negative sentiment, or that have been edited or altered in a way that changes their original meaning or misrepresents the reviewer’s experience.

Fraudulent Content will be rejected, removed, or excluded from syndication without notice. Wholescale reserves the right to suspend or terminate services, revoke access, or notify relevant partners or authorities in the event of repeated or material instances of fraud.

Display and Syndication

Wholescale 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 Wholescale shall have the following attribution tag: Review collected by Wholescale.

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 Wholescale counterparts to discuss the terms of this Policy and make suggestions to further its purpose.

Changes to the Policy

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

Actions

Content Audits
Clients shall cooperate fully with any reasonable requests by Wholescale to verify compliance with these Standards, including, without limitation, by providing documentation, records, data exports, communications, or other materials relating to the submission or sourcing of Content. Wholescale reserves the right, at its sole discretion, to audit or inspect such materials and processes upon reasonable notice. Failure to cooperate with such requests, or to provide sufficient evidence of compliance, may result in the rejection, removal, or exclusion of Content, or the suspension or termination of services.

Content Removal Policy
Wholescale 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.