Online Review Policies & Procedures

for Belle Canadienne

Last Updated: 13/07/2023

Asking for Reviews

As discussed in Section E (Monitoring for New Reviews), we proactively monitor for new online

reviews on a combination of platforms, both compatible and incompatible with the Marketing rule.

With respect to asking for reviews, we encourage reviewers to write their review on: our own website / Google / Social Medias etc.. Our rationale for encouraging reviews on these platforms is based upon our active account established with the platform, our ability to be notified immediately when we receive a new review, our ability to incorporate disclosures required to promote the review as a testimonial or endorsement, etc.

We intend to ask for reviews from Customers only.

We purposely selected all existing customers to receive the same email with a review solicitation request.

Following our initial outreach, we [will / did] incorporate review solicitation practices into our everyday business practices. To avoid cherry-picking concerns, we identified the following ways

we will primarily request reviews among our current customers:

• Email signatures updated to include a link to write a review
• Link to write a review included in customer newsletters

Compensating for Reviews (aka Testimonials & Endorsements)

• We generally will not offer any form of compensation to customers for reviews.

Anonymous Reviews

• When clients and non-clients write a review but prefer to remain publicly anonymous, we will honor their request while following all other policies related to prohibitions and disclosure requirements.

Reviews from Non-Customers

• Beyond our current customers, we may receive review from non-customer, but we will not send any review request to a non-customer

Section E. : Monitoring for New Reviews

• As there are countless websites where we could receive unsolicited reviews at any time, it is not practical for us to proactively monitor every possible platform. Further, most of these platforms are not compatible with the Marketing rule’s disclosure requirements. Therefore we explicitly disclaim any review published on these platforms from being considered a promoted testimonial or endorsement for our brand.

• We do proactively monitor for new reviews about our brand on our website and social Medias accounts 

Reviewing Content of New Reviews

Section G applies to new reviews we receive, including testimonials and endorsements, that we intend to become advertisements for our brand. The discussion includes activities we conduct through our pre-publication checklist to identify prohibited content, unsubstantiated material statements of fact and/or spam, and inappropriate content.

G.1. Identifying and Addressing Prohibited Content

Before publishing an online review as a testimonial or endorsement, our review pre-publication checklist includes assessing its content against the list of SEC prohibitions. In situations where a prohibition is triggered, we take the following actions:

• Redacting or removing the prohibited language and publishing the review with accompanying disclosure to explain the redaction or revisions

• Not publishing the review on your website, and notify the customer about the review not be published due to an SEC prohibition

G.2. Documenting Unsubstantiated Material Statements of Fact

Prior to publishing an online review as a testimonial or endorsement, our pre-publication checklist includes assessing its content to identify any unsubstantiated material statements of fact. In situations where a material statement of fact is unsubstantiated, we consider the following actions:

• In certain instances, we may include a statement of substantiation within the review’s accompanying disclosures for quick recollection of the circumstances

G.3. Handling Spam and Inappropriate Content

Our policy for handling online reviews which are spam or include inappropriate content is based upon the Consumer Review Fairness Act of 2016, which states that as a business, we have the right to remove a review from our website (and/or request the removal of reviews about our business on third party websites) that:

• contains the personal information or likeness of another person, or is libelous, harassing, abusive, obscene, vulgar, sexually explicit, or is inappropriate with respect to race, gender, sexuality, ethnicity, or other intrinsic characteristic;

• is unrelated to the goods or services we offer;
• is clearly false or misleading;
• contains trade secrets or commercial or financial information obtained from a person and considered privileged or confidential;

• personnel and medical files and similar information the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;

• records or information compiled for law enforcement purposes, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy;

• content that is unlawful;
• content that contains any computer viruses, worms, or other potentially damaging computer code, processes, programs, applications, or files.

If we receive a review on our business website that is clearly spam, we will delete it with no further action taken. Otherwise, in situations where the reviewer is known to us and/or provides valid contact information, we will contact the reviewer (usually by phone or email) to notify them of our policy and our resulting actions.

For reviews we receive on unaffiliated third-party websites, we will also contact the review platform and follow their procedures to request appropriate action be taken consistent with our policy.

G.4. Preparing Clear and Prominent and Additional Disclosures

Once our pre-publication checklist items G.1 through G.3 have been completed, and a review has been determined to meet the requirements to become a testimonial or endorsement, we next prepare the clear and prominent and additional disclosures which will accompany the online review. Our pre-publication checklist is designed to ensure all disclosures are appropriately included and formatted for compliance with the Marketing rule.

Responding to Online Reviews

Our policy is to not publicly respond or reply to any review on SEC-incompatible review platforms, whether favorable or otherwise, to mitigate risks of triggering adoption or entanglement as described in the Marketing rule.

Further, regardless of the SEC compatibility of the online review platform, our policy is to handle

Negative Reviews

Consistent with our policy for responding to online reviews, we will handle any communications with reviewers about their reviews individually by phone or email. Any concerns raised in the review will be handled in the same manner as our existing policies for handling concerns that are made known to us through other means. For negative reviews received on our website and/or SEC-compatible platforms where we solicit and promote reviews, we will use the additional disclosures field accompanying the review to document our perspective on any concerns raised.

Review Aggregation

While we appreciate reviewers who take the time to write a review about us on any online review platform, we recognize our responsibility to only promote reviews as testimonials and endorsements which meet Marketing rule requirements.

Because we believe consumers may generally benefit by reading multiple reviews about our brand,

we choose to aggregate reviews from SEC-Incompatible Platforms where we maintain an account and proactively monitor for new reviews (For a list of these platforms, refer to Section E). We define review aggregation as the process of importing reviews (testimonials and endorsements) from SEC-Incompatible Platforms to our own website and/or other SEC-Compatible platform(s) for the purpose of promoting them as advertisements, once disclosures required by the Marketing rule are added. (For a list of SEC-Compatible platforms we use to promote testimonials and endorsements, refer to Section E).

To avoid cherry-picking concerns, our policy is to ask each reviewer (who is known to us and/or whose contact information we can readily ascertain) for their permission by email to republish their review on SEC-Compatible platforms, except for any reviews we identify as containing prohibited content or otherwise unable to meet SEC requirements for testimonials and endorsements.

To comply with federal law, we will only aggregate reviews where explicit permission has been received from the reviewer for their review to be republished and become a promoted testimonial or endorsement. Our email outreach to these reviewers will generally include the following text:

• I’m grateful for the recent review you wrote on Google / Medias, sharing your experience using our products. Your review is truly appreciated and helps other people looking to buy wigs decide if we may be a good brand to buy from. Would you mind if I republish your review on my own website?

To meet our recordkeeping obligations for online reviews, testimonials and endorsements, promoted as advertisements, we maintain records in an easily accessible place.