Compliance Statement — Review Platform Guidelines

This statement may be published as a standalone page at /compliance or incorporated as a dedicated section within the Terms of Use at /terms.

1. About Pepper Reputation

Pepper Reputation is a B2B reputation management service operated by Peppergroup OÜ. We provide businesses with tools and managed services to:

• Monitor reviews and ratings across third-party review platforms (including Google Business Profile, Trustpilot, HelloPeter, SmartCustomer, Reviews.io, Casino Guru, G2, Capterra, and others);
• Aggregate review data and sentiment signals into a unified dashboard or reporting interface;
• Facilitate legitimate review acquisition by helping clients operationalise processes for inviting real, verified customers to share their genuine experiences on supported platforms;
• Manage and respond to existing reviews, including flagging reviews that appear to violate a platform’s own content policies, and supporting clients in submitting platform-compliant dispute or removal requests.

We do not operate the review platforms listed above and have no contractual or technical control over their content moderation decisions or outcomes.

2. Our Commitment to Review Platform Integrity

Peppergroup OÜ operates Pepper Reputation on the basis that authentic, organic reviews are the foundation of trustworthy online reputation. We maintain the following firm commitments in our own operations and in the services we deliver to clients.

2.1 No Fake or Fabricated Reviews

We do not create, generate, post, or assist in the creation of reviews that do not reflect a genuine, first-hand experience of the reviewed business. This prohibition applies regardless of the intended platform and regardless of whether the fabricated review would be positive, negative, or neutral. We do not use AI-generated content, scripted testimonials, or any other mechanism to simulate authentic customer feedback.

2.2 No Incentivised or Paid Reviews

We do not pay, gift, discount, or otherwise provide any benefit — monetary or non-monetary — to any individual in exchange for posting a review, or in exchange for posting a review with a specific sentiment or rating. Clients may not use Pepper Reputation tooling or services to structure or execute incentivised review schemes.

2.3 Genuine Customers Only

Any review invitation or outreach workflow facilitated through Pepper Reputation is restricted to individuals who have a verified, real transactional or service relationship with the client business. We do not assist in sending review invitations to individuals who are not genuine customers, tenants, users, or patients of the client.

2.4 No Selective or Gated Solicitation

We do not design, recommend, or implement review funnel architectures that selectively direct customers to review platforms based on predicted sentiment (commonly referred to as “review gating”). All customers who are eligible for review outreach must have the opportunity to submit their review, regardless of their anticipated satisfaction level.

2.5 No Manipulation of Platform Ranking or Filtering Systems

We do not engage in, advise on, or assist with practices designed to artificially inflate review counts, manipulate platform quality filters, suppress legitimate negative reviews through illegitimate means, or otherwise game platform ranking algorithms.

3. Compliance with Review Platform Guidelines

Pepper Reputation’s services are designed to operate within the published terms and community guidelines of the major review platforms. Our specific commitments by platform are set out below.

3.1 Google Business Profile

Our services comply with Google’s review policies as published at support.google.com/business. In particular:

• We do not solicit reviews using offers, incentives, or rewards.
• We do not discourage or prohibit customers from leaving negative reviews.
• We do not post reviews on behalf of customers.
• Review request communications facilitated through our platform do not instruct or pressure recipients regarding what rating to give.

3.2 Trustpilot

Our services comply with Trustpilot’s Guidelines for Businesses as published at legal.trustpilot.com. In particular:

• Invitation workflows are limited to verified customers (as defined by Trustpilot’s Verified Reviews programme requirements).
• We do not assist in the flagging or reporting of reviews for the purpose of removing legitimate negative feedback.
• We do not advise clients to offer any form of consideration in exchange for reviews or for changing an existing review.

3.3 Other Supported Platforms

For all other platforms on which Pepper Reputation provides monitoring, acquisition, or management services (including but not limited to HelloPeter, SmartCustomer, Reviews.io, Casino Guru, G2, and Capterra), we apply the same baseline commitments set out in Section 2 above, and we require that client-facing workflows comply with each platform’s then-current terms of service and review guidelines.

4. FTC Endorsement Guidelines (United States)

For clients operating in or targeting the United States market, Pepper Reputation acknowledges the applicability of the Federal Trade Commission’s Guides Concerning the Use of Endorsements and Testimonials in Advertising (16 C.F.R. Part 255, as updated in 2023).

We operate in accordance with the following FTC-related principles:

• Any material connection between a reviewer and the reviewed business (including any past or present commercial relationship, employment, or incentive) must be clearly and conspicuously disclosed in the review content itself, where applicable.
• We do not structure review acquisition programmes in a way that would require disclosure to be omitted or suppressed.
• We counsel clients that the FTC has confirmed that review gating — which can suppress negative reviews and create a misleadingly positive overall impression — may constitute deceptive practice under Section 5 of the FTC Act.
• Clients in the US are responsible for ensuring that their own use of review data in marketing materials (e.g. showcasing aggregate ratings in advertisements) complies with applicable FTC guidance on the use of testimonials and endorsements.

5. Client Obligations and Limitation of Liability

Pepper Reputation provides a platform and managed service. Clients retain full responsibility for ensuring that their own use of the service — including the content of review invitations they send, the audiences they target, and any use of review data in their marketing — complies with:

• The terms of service and community guidelines of any review platform on which they operate;
• Applicable consumer protection, advertising, and unfair commercial practices laws in their jurisdiction(s);
• Any applicable platform-specific verified reviews programmes or certification requirements.

Peppergroup OÜ accepts no liability for violations of review platform terms of service or applicable law arising from a client’s own actions, instructions, or configurations within the Pepper Reputation service. Clients who use our platform in a manner inconsistent with this Compliance Statement or with applicable platform guidelines do so at their own risk and may be subject to suspension or termination of service.

6. Reporting Concerns

If you believe that Pepper Reputation services are being used in a manner inconsistent with this Compliance Statement, or if you have questions about our practices, please contact us at:

Peppergroup OÜ Harju maakond, Tallinn, Kesklinna linnaosa, Karu tn 14-8, 10120, Estonia Email: [email protected]

This Compliance Statement was last updated in May 2026 and is subject to revision as platform guidelines and applicable law evolve.