Content Moderation and Appeals Policy

This Content Moderation and Appeals Policy (the "Policy") is issued by Welobadge, LLC, a Delaware limited liability company with its registered office at 131 Continental Dr, Suite 305, Newark, DE 19713, United States ("Welo", "we", "us").

Version: 1.0. Effective date: 5 November 2026.

This Policy explains how Welo moderates content hosted on its services, how anyone can report content, how we notify people of our decisions and how those decisions can be challenged. It forms part of the Terms and Conditions and of the Business Service Agreement. The substantive rules about what reviews and responses may contain are set out in the Review Guidelines; this Policy sets out the procedures Welo follows to apply them.

1. Principles

1.1 Authenticity. Welo Reviews exist to reflect genuine experiences. Moderation protects consumers, honest reviewers and honest businesses from fabricated, manipulated, unlawful or abusive content.

1.2 Independence. Welo, and not the reviewed business, makes moderation decisions. A business cannot purchase, negotiate, or obtain through any plan, fee, program, partnership or custom agreement: the removal, suppression, delay, hiding, reordering or alteration of an authentic review; a veto over any review; or a particular moderation outcome. Moderation staff do not receive incentives linked to the commercial relationship with any business.

1.3 Neutrality as to sentiment. A review is never removed, held, restricted or excluded from ratings because it is negative, critical, unfavorable or disliked by the business concerned. The same rules, thresholds and procedures apply to positive, neutral and negative content.

1.4 Diligence, objectivity and proportionality. Welo applies its rules in a timely, diligent, non-arbitrary and objective manner, with due regard to the rights and legitimate interests of everyone involved, including freedom of expression and information, the right to an effective remedy, the protection of personal data and the protection of consumers. The measure chosen is proportionate to the seriousness of the issue.

1.5 Transparency. Welo publishes its rules, explains its decisions to the persons affected, and offers a route to challenge them.

1.6 Integrity of the record. Welo does not fabricate reviews, does not invent experiences, does not change the substantive meaning of a review, does not change a reviewer's star rating, does not change the original date of submission of a review, and does not present a selection of reviews or a review count in a way that misrepresents the feedback actually received.

2. Scope and definitions

2.1 This Policy applies to all content that Welo hosts or displays at the request of users, including on Welo Pages, widgets and other Welo services ("Content"), namely:

(a) "Reviews": star ratings, titles, texts, photos, videos, attachments and other material submitted about a business;
(b) "Business Responses": public replies by a business to a Review;
(c) "Business Content": descriptions, images, logos, links and other material that a business submits for its Welo Page; and
(d) "Reports": notices, flags and complaints submitted to Welo about Content.

2.2 This Policy does not apply to "Welo Content", meaning Welo's own statements, such as Certification decisions, Certification Levels and Statuses, Trust Scores, Evaluation reports, labels and notices. Welo Content is governed by the Welo Trust Standard and the Badge Usage Policy and is challenged through the certification appeal route in Section 13.

2.3 In this Policy, a "Moderation Decision" is any decision by Welo to approve, hold, label, redact, restrict, demote from ratings calculations, reject or remove Content, or to restrict an account, review collection features or other functionality because of Content or conduct related to Content. An "Affected Person" is the author of the Content concerned, the business to which it relates, and any person who submitted a Report about it.

3. Status of user content

3.1 Reviews and Business Responses express the opinions and experiences of their authors. Their publication does not mean that Welo endorses them, agrees with them, has verified every statement in them, or has determined the truth of any fact in dispute.

3.2 A "verified" or similar label on a Review means only that Welo has taken the steps described in the Review Guidelines to assess the origin of the Review (for example, a unique invitation linked to an interaction with the business). It does not certify that the content is accurate.

3.3 Welo acts as a host of Content. Welo does not adopt Content as its own by moderating it, labeling it, displaying it in widgets or calculating ratings from it.

4. Grounds for moderation

4.1 Welo may take a Moderation Decision where Content, or the conduct of the person who submitted it, falls within one or more of the following grounds, as described in more detail in the Review Guidelines:

(a) Fabricated experience: the Content does not reflect a genuine experience of the author with the business;
(b) Manipulation: the Content was purchased, sold, commissioned, incentivized conditional on sentiment, written by or for the business or a competitor, generated or multiplied by automated means to simulate experiences, or submitted as part of an exchange of reviews;
(c) Fraudulent or fake accounts: the Content was submitted through a fake, stolen or synthetic identity, a bot, or a network of accounts;
(d) Coordinated attacks: the Content is part of a coordinated campaign (including "review bombing") not based on the authors' own experiences;
(e) Undisclosed conflict of interest: the author has an employment, family, financial, competitive or other material connection with the business that is not clearly disclosed;
(f) Impersonation: the Content impersonates another person, business or Welo, or misrepresents the author's identity or affiliation;
(g) Illegal content: the Content is unlawful under applicable law, including content that is defamatory, infringes intellectual property, constitutes unlawful hate speech, incites violence, relates to child sexual abuse, or facilitates criminal activity;
(h) Threats, harassment and abuse: threats, intimidation, harassment, hateful or discriminatory content, or seriously offensive, obscene or sexually explicit material;
(i) Privacy violations: personal data or confidential information beyond what is necessary, such as home addresses, private phone numbers or emails, identity documents, payment data, health data, complete order numbers or images of identifiable people without a lawful basis;
(j) Extortion: the Content was used, or threatened, to obtain a payment, refund, product or other benefit to which the author was not entitled;
(k) Spam and promotion: advertising, promotional codes, unrelated links, solicitations or malware;
(l) Duplicates: multiple submissions about the same experience by the same person, or the same Content submitted for multiple businesses;
(m) Irrelevant content: Content that does not relate to the business's products, services, customer service or conduct, or that relates to the wrong business;
(n) Materially misleading content: statements presented as established facts that are clearly false or misleading in a material respect, as distinct from opinions, criticism or a different account of disputed events;
(o) Confidential business information: trade secrets or confidential commercial information whose disclosure is not justified;
(p) Breach of the Review Guidelines or the Terms in any other respect stated in those documents.

4.2 Grounds that are not sufficient. The following are not, by themselves, grounds for removing or restricting a Review: a low rating; negative, critical or harsh (but not abusive) language; a business's disagreement with the reviewer's opinion or account; the business's assertion that it has resolved the issue; the absence of a specific form of proof of purchase where other information supports the experience; the fact that the business has cancelled its subscription or Certification; or the business's plan, payments or commercial importance.

4.3 Business Responses and Business Content are moderated on the same grounds as applicable, and also where they disclose personal data of a reviewer, retaliate against or attempt to identify a reviewer, make offers conditional on removing a Review, or make claims that are inconsistent with the business's Certification Status or the Badge Usage Policy.

5. How moderation works

5.1 Means. Welo uses a combination of: (a) automated systems, including rules, risk scoring, duplicate and anomaly detection, fraud detection signals (such as invitation tokens, form-completion signals, hashed network information and device information), and machine-learning and artificial intelligence models that assess authenticity, safety and quality; and (b) review by trained human moderators.

5.2 Automated decisions. Automated systems may approve Content, hold Content for human review, or recommend an action. Where an automated system is used to reject or remove Content, or to restrict an account, Welo will say so in the statement of reasons. Welo applies human review to Moderation Decisions that are uncertain, complex, disputed or of significant consequence, and in every appeal under Section 12. Welo periodically reviews the accuracy and error rates of its automated systems, including for disparate effects on positive and negative Reviews.

5.3 Risk-based assessment. The depth of review depends on risk. Welo may apply additional checks to Content or accounts showing risk signals, to businesses with a history of manipulation, or during unusual activity, provided that such checks are applied consistently regardless of the sentiment of the Content.

5.4 Pre-publication checks. Welo may hold a Review before publication while checks are completed. A hold lasts no longer than reasonably necessary. Holds are not used to delay negative Reviews selectively.

5.5 Contextual signals. Welo may consider information from the business (for example, whether a person was a customer), provided that the business's input is treated as one piece of evidence and never as decisive by itself, and that Welo protects the reviewer's personal data in accordance with Section 7.4.

6. Available measures

6.1 Depending on the ground, the seriousness, the evidence and the history of the account, Welo may:

(a) approve and publish Content;
(b) temporarily hold Content pending checks or additional information;
(c) request information or evidence from the author or the business (Section 8);
(d) add a label (for example, to disclose an incentive, a connection with the business, or that the Review was edited by its author);
(e) redact limited parts of Content, such as personal data or a link, without changing the meaning of the remainder;
(f) restrict the visibility of Content or exclude it from rating calculations, where the Content is ineligible under the published rules;
(g) reject or remove Content;
(h) merge or remove duplicates;
(i) restrict, suspend or close an account, or restrict its ability to submit Content or Reports;
(j) suspend a business's ability to send review invitations, or display a consumer notice on a Welo Page where Welo has found manipulation affecting it;
(k) refer the matter for certification review under the Welo Trust Standard; and
(l) report the matter to competent authorities where required or permitted by law.

6.2 Editing. Welo does not rewrite Content. Apart from redaction under Section 6.1(e) and technical formatting that does not alter meaning, any change of text is made only by the author or with the author's consent. Welo never changes a star rating or the original submission date of a Review. Where Welo corrects a technical error affecting a date (for example, an import error), it records the correction and the reason in its audit log.

6.3 Rating calculations. Ratings and review counts displayed by Welo are calculated from the Reviews that are eligible under the published rules, applied uniformly regardless of sentiment. Welo does not add to a review count, or to a rating, any number that does not correspond to eligible Reviews on Welo, unless the source and nature of the additional number are clearly disclosed next to it and substantiated.

7. Reporting Content (notice and action)

7.1 Who may report. Any person or entity may report Content that they consider to be illegal or in breach of the Review Guidelines, using the report function on the Welo Page or widget, the business dashboard, or by email to support@welobadge.com.

7.2 Content of a notice of illegal content. To allow Welo to assess a notice that Content is illegal, the notice should contain: (a) a sufficiently substantiated explanation of the reasons why the person considers the Content illegal; (b) a clear indication of the exact electronic location of the Content, such as the URL or the review identifier, and any additional information needed to identify it; (c) the name and email address of the person submitting the notice, except in the case of information considered to involve child sexual abuse material or similar offences; and (d) a statement confirming the person's good faith belief that the information and allegations in the notice are accurate and complete.

7.3 Handling. Welo will send a confirmation of receipt to the notifier where an electronic contact address is provided, assess the notice in a timely, diligent, non-arbitrary and objective manner, and inform the notifier of its decision and of the available redress options without undue delay. Where Welo uses automated means to process or decide on a notice, it will say so. A notice that meets the requirements of Section 7.2 may give rise to actual knowledge of the Content concerned for the purposes of applicable law.

7.4 Reports by businesses. A business may report a Review through its dashboard by selecting the ground and explaining specifically why the Review breaches the Review Guidelines or the law, with any supporting information. Welo will not disclose to the business the reviewer's private contact details or private evidence, except where necessary and lawful (for example, to allow the business to confirm whether a person was a customer through a pseudonymous reference), and will share only what is proportionate.

7.5 Status during assessment. A Report does not cause Content to be hidden. Content remains visible while a Report is assessed, unless Welo determines that Content is manifestly illegal, discloses personal data that should be protected, presents a credible risk to safety, or shows strong indicators of fraud, in which case Welo may restrict it temporarily under Section 10.

7.6 Insufficient reports. Welo may decline to act on a Report that is incomplete, generic, repetitive, or based solely on disagreement with an opinion, and will tell the reporter why.

8. Requests for information and evidence

8.1 From reviewers. Welo may ask the author of a Review for information reasonably necessary to assess its authenticity or the relevant facts, such as the approximate date and channel of the interaction, a partial order reference, or a document showing the interaction with sensitive data removed. Information provided through Welo's private channel is not published and is not shared with the business except as described in Section 7.4.

8.2 From businesses. Welo may ask a business for information reasonably necessary to assess a Report, such as records showing whether a transaction occurred, or evidence supporting a claim that a statement is false.

8.3 Response period. Welo will state a reasonable period for responding, which will normally be not less than seven (7) days. Welo may decide on the basis of the information available if no response is received.

8.4 Assessment of evidence. Welo assesses all available information as a whole. The absence of a particular document does not by itself make a Review fake. Evidence that has been altered, forged or obtained unlawfully may be disregarded and may itself lead to measures against the person who provided it.

8.5 Data minimization. Persons should provide only the information requested and should redact data that is not needed. Evidence is retained in accordance with the Privacy Policy and Section 16.

9. Specific categories of complaint

9.1 Defamation. Welo is not a court and cannot finally determine whether a statement is true or defamatory. Where a person alleges that a Review is defamatory, Welo will: (a) distinguish between opinions and statements of fact; (b) where the complaint identifies specific statements of fact and provides credible evidence that they are false, invite the author to substantiate them (Section 8); and (c) remove or restrict the specific statements, or the Review, where they are manifestly unlawful, where the author does not substantiate them and the complainant's evidence is credible, or where a court or competent authority so orders. Where the law of the United Kingdom applies and the complainant serves a notice that meets the requirements of the Defamation (Operators of Websites) Regulations 2013, Welo may follow the procedure set out in those Regulations. Nothing in this Section obliges Welo to remove a Review merely because a person asserts that it is defamatory.

9.2 Copyright and other intellectual property. Rights holders may submit a notice under Section 7, or, for content hosted in the United States, a notice meeting the requirements of 17 U.S.C. § 512(c)(3) to Welo's designated agent: Welobadge, LLC, Attn: Copyright Agent, 131 Continental Dr, Suite 305, Newark, DE 19713, United States, email daniel@welobadge.com (subject "DMCA Notice"). A person whose Content is removed may submit a counter-notification meeting the requirements of 17 U.S.C. § 512(g)(3). Welo may restore Content in accordance with that section. Welo will, in appropriate circumstances, terminate the accounts of repeat infringers. Knowingly material misrepresentations in a notice or counter-notification may create liability under 17 U.S.C. § 512(f).

9.3 Privacy. A person who considers that Content contains his or her personal data unlawfully may report it under Section 7 or exercise data protection rights as described in the Privacy Policy. Welo will generally prefer redaction of the specific personal data to removal of the whole Review, where that resolves the issue.

9.4 Impersonation. A person or business that is impersonated may report it under Section 7 with evidence of identity or authority. Welo may require verification before acting and may suspend the account concerned.

9.5 Fraud and manipulation. Reports of fake Reviews, review exchanges, incentives conditioned on sentiment or other manipulation may be made under Section 7. Welo will investigate using the means in Section 5, may request information under Section 8, and may take the measures in Section 6, including measures against the business that benefits.

9.6 Requests from authorities. Welo will respond to orders and requests from courts, law enforcement and other competent authorities in accordance with applicable law, including orders to act against illegal content and orders to provide information under Articles 9 and 10 of Regulation (EU) 2022/2065 (the Digital Services Act, "DSA") where applicable. Welo will assess the legal validity and scope of each request, and will notify the affected user unless prohibited by law or the order. Where Welo becomes aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person has taken place, is taking place or is likely to take place, it will promptly inform the competent law enforcement or judicial authorities, as required by Article 18 of the DSA where applicable.

10. Urgent measures

10.1 Welo may act immediately, before completing its ordinary assessment and before notifying the Affected Persons, where it reasonably believes that Content or conduct presents a credible: (a) risk to the safety of any person; (b) risk of fraud or of large-scale manipulation; (c) security risk to the Platform or its users; (d) disclosure of sensitive personal data; or (e) manifest illegality; or where immediate action is required by law or an authority.

10.2 An urgent measure is limited to what is necessary (for example, temporary restriction rather than deletion), is reviewed as soon as possible, and is followed by a statement of reasons under Section 11 unless an exception applies.

11. Notification and statement of reasons

11.1 When Welo removes, rejects, restricts, demotes from ratings, or labels Content, or suspends or terminates an account or a feature because of Content, it will provide the affected author (and, where relevant, the business) with a clear and specific statement of reasons, at the latest when the decision takes effect, unless an exception in Section 11.3 applies. The statement of reasons will include, as applicable:

(a) the measure taken, its territorial scope and its duration;
(b) the facts and circumstances relied on, including whether the decision followed a Report or Welo's own initiative and, where strictly necessary, the identity of the reporter (only where the law permits);
(c) whether automated means were used to detect the Content or to make the decision;
(d) where the decision concerns allegedly illegal Content, the legal ground relied on and why the Content is considered illegal;
(e) where the decision is based on incompatibility with Welo's rules, the provision of the Review Guidelines, the Terms or this Policy relied on and why the Content is considered incompatible; and
(f) the redress available, including the appeal under Section 12 and, where applicable, out-of-court dispute settlement and judicial redress.

11.2 Reporters will be informed of the outcome of their Report under Section 7.3.

11.3 A statement of reasons need not be given: where Welo does not have electronic contact details of the person; where the Content is deceptive high-volume commercial content (such as spam); where disclosure is prohibited by law or by an order of a competent authority; or where providing it would compromise an ongoing investigation into fraud, security or a criminal offence, in which case Welo will provide it once that risk has passed, where possible.

11.4 Where Welo approves a Review that a business has reported, Welo will inform the business that the Report was not upheld and of the reasons.

12. Content appeals

12.1 Who may appeal. An Affected Person may appeal a Moderation Decision, including a decision not to act on a Report.

12.2 How and when. Appeals must be submitted within six (6) months of the date on which the person was informed of the decision, through the appeal link in the decision notice, the dashboard, or by email to support@welobadge.com, identifying the decision, the Content and the reasons for the appeal, with any supporting information. Appeals are free of charge.

12.3 Review. Appeals are handled in a timely, non-discriminatory, diligent and non-arbitrary manner by human reviewers, and not solely by automated means. Where reasonably practicable, the appeal is assessed by a person who was not involved in the original decision. Welo may request additional information under Section 8.

12.4 Outcome. Welo will reverse the decision without undue delay where the appeal contains sufficient grounds to consider that the decision was unfounded, or that the Content is not illegal and not incompatible with Welo's rules, or that the measure was disproportionate. Welo will inform the appellant of its reasoned decision and of any further redress available.

12.5 One appeal. Each Moderation Decision may be appealed once. A new appeal may be considered if it is based on new and relevant information that was not reasonably available at the time of the first appeal.

12.6 Out-of-court dispute settlement. Where Article 21 of the DSA applies to Welo, users in the European Union may refer disputes about Moderation Decisions to an out-of-court dispute settlement body certified under that Article. Welo will engage with such a body in good faith as required by that Article. Use of such a body does not limit the right to seek judicial redress.

12.7 Judicial redress. Nothing in this Policy limits any person's right to bring proceedings before a competent court or to complain to a competent authority.

13. Certification appeals and account enforcement are separate

13.1 Certification appeals. Decisions about Certification, Certification Levels, Certification Statuses and Trust Scores are Welo Content made under the Welo Trust Standard. They are challenged through the reconsideration procedure in Section 16 of the Badge Usage Policy, not through this Policy.

13.2 Account enforcement. Suspension or termination of an account for reasons unrelated to Content (for example, non-payment, security or breach of the Business Service Agreement) is governed by the Terms and Conditions and the Business Service Agreement.

13.3 Linked cases. Where a single set of facts gives rise to both a Moderation Decision and a certification or account measure (for example, review manipulation by a business), Welo may coordinate the procedures and will tell the business which route applies to each decision.

14. Misuse of the moderation system

14.1 Repeat infringers. Welo may, after a prior warning, suspend for a reasonable period the accounts of persons who frequently submit manifestly illegal Content or Content that manifestly breaches the Review Guidelines.

14.2 Abusive reporting. Welo may, after a prior warning, suspend for a reasonable period the processing of Reports and appeals from persons or businesses that frequently submit manifestly unfounded Reports or appeals, including Reports submitted to suppress legitimate criticism, to intimidate reviewers or to overload moderation systems.

14.3 Assessment. Decisions under this Section 14 take into account, on a case-by-case basis, the absolute number and the proportion of manifestly illegal or unfounded items, the gravity of the misuse and its consequences, and the intent of the person, where identifiable.

14.4 Bad-faith appeals and evidence. Submitting forged evidence, impersonating a reviewer, or pressuring a reviewer to withdraw a Review in connection with a Report or appeal is a serious breach of the Review Guidelines and of the Business Service Agreement.

15. Disputes between consumers and businesses

15.1 Welo is not a party to transactions between consumers and businesses and does not act as a mediator, arbitrator, payment guarantor or complaints-handling body for them. Welo's procedures address whether Content may be hosted and displayed, not who is right in an underlying commercial dispute.

15.2 Welo may provide tools that allow a business to respond publicly or to invite the reviewer to contact it privately. Welo has no obligation to investigate or resolve the underlying dispute, to obtain a refund or to enforce any consumer right. Consumers retain all their rights against the business under applicable law and may contact competent consumer protection authorities.

16. Records, audit trail and data protection

16.1 Welo keeps records of Moderation Decisions, including the Content concerned, the ground applied, whether automated means were used, the identity of the human reviewer (internally), Reports received, communications with Affected Persons, appeals and their outcomes, and any changes to Content or its metadata. These records are kept to ensure accountability, to handle appeals, to prevent abuse and to comply with law, and are retained in accordance with the Privacy Policy.

16.2 Personal data processed under this Policy is processed by Welo as an independent controller, as described in the Privacy Policy. Reporters' identities are not disclosed to the author of the Content, except where necessary and permitted by law (for example, in intellectual property notices where the law requires it).

17. Points of contact and transparency

17.1 Users. Users may contact Welo about this Policy at support@welobadge.com. Welo communicates with users in English and Italian.

17.2 Authorities. The single point of contact for authorities of the Member States, the European Commission and the European Board for Digital Services under Article 11 of the DSA is daniel@welobadge.com (subject "DSA"), in English and Italian.

17.3 Legal representative. Welo will publish on this page the name and contact details of its legal representative in the European Union under Article 13 of the DSA. In the meantime, communications may be sent to the point of contact in Section 17.2.

17.4 Transparency. Where required by law, Welo will publish transparency information about its content moderation. Welo may also publish such information voluntarily.

18. Changes to this Policy

Welo may update this Policy to reflect changes to its services, moderation systems, risks or the law. Welo will publish each version with a version number and effective date and keep prior versions available on request. Material changes will be notified in advance through the Platform or by email to account holders, except where an immediate change is required by law or to address an urgent risk.

19. Relationship with other documents

19.1 This Policy controls with respect to moderation procedures, Reports, statements of reasons and content appeals. The Review Guidelines control with respect to the substantive rules for Reviews and Business Responses. The Badge Usage Policy and the Welo Trust Standard control with respect to certification. Where this Policy conflicts with mandatory law, mandatory law prevails.

19.2 Nothing in this Policy grants a business a contractual right to a particular Moderation Decision, or creates an obligation for Welo to monitor all Content proactively.

19.3 The English version of this Policy is binding. Translations are provided for convenience; in the event of an inconsistency, the English version prevails, unless mandatory law requires otherwise.