Fraudulent Review Policy

Reviews are only worth something if they are real. A review economy that can be bought, filtered or faked is worth nothing to the consumer reading it and, in the end, nothing to the business that gamed it. This policy sets out where Cloutly stands, what we require of the businesses that use our platform, how we moderate the reviews we host ourselves, and what we do when someone breaks the rules.

1. Two roles, two sets of powers

Cloutly does two different things with reviews, and what we can do about a fraudulent one depends on which is involved.

Reviews hosted by someone else. Most reviews that pass through Cloutly live on Google, Facebook, TripAdvisor, ProductReview and similar platforms. We read them, analyse them, and publish the business’s responses back to them. We are a tool in that relationship, not the host. We cannot remove, hide or edit a review on a platform we do not operate — only that platform can, through its own process. Nobody can promise otherwise, and a vendor who offers to get a bad review taken down from Google is selling something they cannot deliver. If you have been told Cloutly does that, we do not and never have.

Reviews we host. Cloutly also collects first-party reviews — submitted directly to us through a review invitation, a QR code, a widget, or the “Write a review” button on a Cloutly review profile — and publishes them on surfaces we operate: Cloutly review profiles at cloutly.com/business/…, the widgets businesses embed on their own sites, and our own pages. For these we are the publisher. We set the standards, we moderate, and we remove content that breaches this policy. Section 5 sets out how.

The rest of this policy is written with that split in mind. Where it matters which kind of review is involved, we say so.

2. Our position

We do not accept fake, bought or manipulated reviews, and we do not build features that make them easier. Specifically:

• We never write reviews. Cloutly’s AI drafts responses to reviews on a business’s behalf, for a person to approve. It does not generate reviews, ratings or testimonials, and no feature of the platform produces review content attributed to a customer who did not write it.
• We do not sell, buy, broker or supply reviews, and we do not work with anyone who does.
• We do not filter who gets invited. When a business sends review invitations to a public platform through Cloutly, every contact in that send is invited on the same terms. The platform does not screen recipients by predicted sentiment, ask for a rating before deciding whether to show someone the review link, or divert unhappy customers away from it.
• We do not offer review removal as a service. We moderate the reviews we host, on the authenticity grounds in section 5. We do not take a review down because a business dislikes it, and that is not something a business can buy.
• We do not use the volume or rating of reviews as a pricing lever. Nothing in how we charge rewards a business for collecting better-looking reviews rather than more honest ones.

3. What businesses using Cloutly must not do

These rules form part of our Terms and Conditions (clauses 5 and 14). Breaching them is a breach of contract, not just a policy preference.

Businesses using Cloutly must not:

• Write, commission or publish fake reviews — including reviews written by the business, its owners, staff, family, contractors or agencies while presenting them as coming from genuine customers.
• Buy reviews, or exchange them with other businesses.
• Offer a reward that depends on what the review says. Rewarding a five-star review, withholding a reward from an unhappy customer, or making an incentive contingent on the rating given is buying an outcome, not collecting feedback. Unconditional incentives are a different matter — see below.
• Gate reviews. Do not use Cloutly, or anything alongside it, to survey customers first and then invite only the happy ones to review publicly. Invite everyone, or invite no one.
• Upload contacts who were never customers, or invite people who have not consented to be contacted where consent is required.
• Act on a business you are not authorised to manage. Monitoring and benchmarking other businesses, including competitors, is a normal and permitted use of Cloutly — see below. Taking action on one is not: do not connect or attempt to claim another business’s platform profile, publish responses or listing changes to it, send review invitations in its name, or collect reviews on its behalf.
• Post reviews about competitors, or use the platform to disparage a competitor under the guise of a customer.
• Misuse competitor data. Do not use what you learn about another business to make comparative claims you cannot substantiate, to publish or resell their review data as your own, or to target their customers with communications they have not consented to receive.
• Misrepresent who wrote a review or when. Do not re-date, re-attribute or edit the substance of a customer’s words.
• Publish a testimonial without the person’s consent, or use a video testimonial outside the scope of the consent given.
• Use display controls to create a false impression — see section 6.

Incentives: unconditional is fine, conditional is not

We do not prohibit rewarding customers for leaving a review. A coupon, a discount, an entry in a draw or a loyalty credit offered for taking the time to give feedback is a reasonable way to lift response rates, and it does not make the resulting reviews dishonest. What makes an incentive corrupting is attaching it to the outcome.

An incentive is acceptable under this policy when both of these hold:

• It is unconditional. Everyone invited gets the same offer for leaving a review, whatever they say and whatever they rate. The reviewer must know that before they write — an offer that reads as “leave us a 5-star review and get 10% off” fails this test even if you would have honoured it for a one-star review too.
• It is disclosed. The reader of the review needs to be able to tell that it was incentivised. Under the FTC’s Endorsement Guides in the US, and as misleading-conduct law is applied in Australia and the UK, an undisclosed material connection between a business and a reviewer is the problem — not the incentive itself.

The destination platform’s rules still apply, and some are stricter than ours. Google prohibits incentivised reviews outright: an unconditional coupon that is perfectly acceptable to us will still breach Google’s policy if the review lands on a Google profile, and Google enforces that itself — up to removing reviews or the profile. We are not the enforcer of another platform’s rules, but we are not going to pretend they do not exist. Check the policy of wherever the review is going before you offer anything, and if you are unsure, the safe path is to invite without an incentive.

First-party reviews on Cloutly review profiles are governed by this policy rather than a platform’s, so an unconditional, disclosed incentive is fine there.

Competitive intelligence, and where the line is

Cloutly includes competitor tracking, and businesses use it to benchmark themselves: ratings, review volumes and trends for named competitors, how those move over time, and which rivals AI assistants recommend on the queries that matter in their market. This is a legitimate and intended use of the platform. It reads only what those businesses have already published — public review pages, public listing details, and the answers AI assistants give anyone who asks — the same information any member of the public can see. No private data is involved, and nothing about a competitor’s account, customers or internal performance is accessible through it.

The line is between observing and acting. Reading what is public about another business is fine. Doing something to that business — claiming or connecting its profile, replying to its reviews, editing its listing, inviting its customers, or posting reviews about it — is not, and it is the kind of conduct that ends an account under section 9. Nor is competitor data a licence to mislead: a benchmark you show a customer must be one you can stand behind, and comparative advertising is subject to the same consumer law as any other claim you make.

4. How the platform is built to keep collection honest

Policies that depend on good intentions do not hold. These are structural:

Invitations are not screened by sentiment. When the destination of a campaign is a public review platform, the invitation link takes the recipient to that platform directly. There is no rating step in between and no branch that treats a likely-unhappy customer differently. This is a property of how the product is built, not a setting a business can change.

Every contact in a send is treated the same. Suppression exists for the reasons it should — frequency caps, quiet periods, unsubscribes and opt-outs, and holding off while a complaint from that customer is open in the inbox — and not for sentiment. A business cannot configure the platform to exclude contacts because of how they are expected to rate.

One customer, one invitation. Duplicate detection and send caps prevent the same person being pushed repeatedly toward leaving a review.

Attribution is honest about itself. Our reporting distinguishes reviews we observed a customer reach through an invitation from reviews we merely matched afterwards, and does not claim credit for the latter. A tool that overstates what it produced encourages the wrong behaviour.

Responses require a person. AI-drafted replies are suggestions. Nothing is published to a review platform without a person at the business approving it.

5. Cloutly review profiles and the reviews we host

A Cloutly review profile is a public page at cloutly.com/business/… showing a business’s reviews. It displays an overall rating and a star breakdown, a per-source summary of the platforms the business is reviewed on, and the first-party reviews submitted to Cloutly. Anyone can submit a review through the “Write a review” button. These pages are on our domain, under our branding, and are indexed by search engines — so the standards below are ours to enforce, not the business’s.

What we require of a review on a Cloutly profile

A review must be a genuine, first-hand account of a real experience with that business, written by the person who had it. We remove reviews that are:

• Fabricated, or not based on a real experience — including reviews of a business the writer has never dealt with.
• Written by the business, or by someone connected to it — owners, staff, family, contractors or agencies — while presenting themselves as an ordinary customer.
• Submitted in exchange for a reward conditional on the rating given, or otherwise bought. An unconditional, disclosed incentive does not make a review removable.
• Written by or on behalf of a competitor.
• Duplicated — the same experience posted repeatedly to move the rating.
• Defamatory, unlawful, or containing content that has no place on a public page — threats, harassment, or content that vilifies a person or group.
• Disclosing someone’s personal information — a customer’s or staff member’s contact details, or a third party’s private information.
• Not about the customer experience — spam, advertising, or commentary unrelated to dealing with the business.

We do not remove a review because it is negative, because it is inconvenient, or because the business asks us to. A critical review from a real customer describing a real experience stays up.

How moderation works

We assess reviews on report and, where our automated checks flag something, on our own initiative. Those checks — email validity, disposable-domain detection, duplicate detection and submission-pattern checks — catch the obvious cases and no more; we do not claim a detection system that catches everything, because no such system exists.

Where we remove a review, we tell the business it has been removed and why. Where we can contact the reviewer, we tell them too, and they can respond if they think we have it wrong. A business that believes a review breaches this policy can report it to us and we will assess it against the list above; a business that disagrees with our decision can ask us to look again, and a different person will.

Where the same account is repeatedly the subject of substantiated reports, we escalate under section 9 rather than treating each review in isolation.

Ratings shown on a Cloutly profile

The rating and star breakdown we publish on a Cloutly profile are ours — we calculate and display them, so we are responsible for them being an accurate representation of the reviews behind them. A review we remove under this section is gone from both the listing and the rating, because it should never have counted. Reviews are not otherwise excluded from the rating.

6. Display controls on a business’s own website

Separately from the profiles we publish, businesses can embed Cloutly review widgets on their own websites. Our widgets include a setting that displays only 4- and 5-star reviews, and businesses can choose to hide individual reviews from their embedded widgets.

These are editorial choices a business makes about its own site, in the same way it chooses which testimonials to put on a homepage — and the business is responsible for the result. Selectively displaying reviews can create a misleading impression of what customers actually say, which is regulated conduct under the Australian Consumer Law, the FTC’s rules on consumer reviews, and equivalent law elsewhere. If you use these settings, make sure the picture your site presents is not one a regulator would call misleading, and do not use them at all if you trade somewhere selective display is restricted.

Two things are not configurable, deliberately: the average rating shown by a widget is calculated across all of the business’s reviews, not just the displayed ones, and nothing a business does to its own widgets removes a review from Cloutly’s records or from the platform that hosts it.

7. AI and authenticity

We use AI heavily, and we are specific about where:

• AI drafts replies to reviews, for a person to edit and approve.
• AI classifies and summarises reviews — topic, sentiment, severity, recurring issues — so a business can see what customers are telling it.
• AI transcribes video testimonials.

AI does not write reviews, invent customers, or alter what a reviewer said. We do not offer a feature that generates review content, and we would not build one. Moderation decisions under section 5 are made by people; automated checks flag candidates, they do not decide.

8. Reporting a review you believe is fraudulent

If the review is on a Cloutly review profile (cloutly.com/business/…), on a Cloutly widget, or is otherwise a first-party review we host — report it to us at trust@cloutly.com. We host it, so we can act on it. Tell us the business, which review, and why you believe it breaches section 5.

If the review is on Google, Facebook, TripAdvisor, ProductReview or another platform — report it to that platform. Only they can remove it, their reporting tools are the fastest route, and we cannot escalate on your behalf.

If you believe a business is misusing Cloutly — soliciting fake reviews, gating, or inviting people who were never its customers — tell us at trust@cloutly.com, whichever platform the reviews ended up on. That is conduct on our platform and it is ours to deal with.

What happens next: we acknowledge reports promptly and investigate using the records available to us — how contacts were uploaded, how invitations were sent, what our checks recorded, and what the submission itself shows. We will tell you the outcome in general terms. We will not disclose another party’s confidential or personal information, and there are cases where we can confirm that we have acted without being able to say how.

Reports made in bad faith — for example, a competitor reporting a rival’s genuine reviews at volume — are treated as misuse of this process.

9. Enforcement

Where we find that a business has breached this policy, our response is proportionate to what happened and whether it was deliberate:

• Contact and correction for something that looks like a misunderstanding — an incentive offered without realising the destination platform prohibits it, contacts uploaded without a clear basis — with a required change.
• Removal of the offending first-party reviews, where they are ours to remove.
• Feature restriction or suspension where the conduct is continuing, where messaging is generating complaints, or while we investigate something serious. This can include unpublishing a Cloutly review profile.
• Termination for deliberate fraud: buying or fabricating reviews, systematic gating, or acting on a competitor’s profile or customers. Under our Terms this is a material breach, and it is not refundable.
• Referral to the relevant review platform, or to a regulator such as the ACCC or the FTC, where we are required to report or where the conduct warrants it.

We keep records of enforcement decisions. A business terminated for review fraud should not expect to be onboarded again under a different entity.

10. The rules that apply to us and our customers

This policy sits alongside, and does not replace, the law and the platforms’ own rules:

• Australia — the Australian Consumer Law (Competition and Consumer Act 2010 (Cth)), which prohibits misleading or deceptive conduct and false testimonials, enforced by the ACCC.
• United States — the FTC’s Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465), which prohibits fake and AI-generated reviews, undisclosed insider reviews, review suppression and buying positive reviews.
• United Kingdom and European Union — the Digital Markets, Competition and Consumers Act 2024 and the Unfair Commercial Practices Directive, which prohibit fake reviews and undisclosed incentives.
• Platform policies — Google Business Profile, Meta, TripAdvisor, ProductReview and others each set their own rules on fake reviews, gating and incentives, and several are stricter than this policy: Google prohibits incentivised reviews outright. They enforce independently of us, and a business that breaches them risks losing its profile — which no amount of compliance with our policy will prevent.

Where a platform’s rules or the law are stricter than this policy, they apply.

11. Changes to this policy

We may update this policy as the law, the platforms’ rules and our product change. The current version is always at cloutly.com/fraudulent-review-policy, with the “last updated” date shown above. Material changes affecting how customers must use the Service are notified under clause 27.1 of the Terms.

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Cloutly Co Pty Ltd (ACN 637 155 045) WOTSO Workspace, Level 2, 194 Varsity Parade, Varsity Lakes QLD 4227, Australia Report a concern: trust@cloutly.com · Web: cloutly.com