Review Policy Compliance

Boomerang Reviews complies with the Federal Trade Commission’s Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465), with the FTC’s Endorsement Guides (16 CFR Part 255), and with the published review policies of Google, Yelp, TripAdvisor, the Better Business Bureau, Meta, Trustpilot and G2.

That is a strong claim, so this page proves it rather than asserting it. Every rule below is quoted from the platform’s own published text, and each is followed by the specific feature of our mechanism that satisfies it.The reason we can make the claim is structural rather than a matter of policy or good intentions:

We do not give anything in exchange for a review. The prize wheel is offered for scanning a QR code. Every guest who scans plays it. A guest who declines to leave a review plays it. A guest who leaves a one-star review plays it, and wins from exactly the same prize set, at exactly the same odds.There is no exchange, so there is nothing for an anti-incentive rule to prohibit. There is no sentiment condition, so there is nothing for an anti-bias rule to prohibit. There is no filtering step, so there is nothing for an anti-gating rule to prohibit.

Our results come from timing and attention — the invitation reaches a guest who is still at the table, holding their phone — and not from paying for reviews. That is precisely why we can decline every shortcut described on this page without giving up performance.

This page is not legal advice and creates no attorney-client relationship. It describes our product and the published rules that apply to it. Merchants remain responsible for their own conduct.HOW THE MECHANISM WORKSThe printed tent makes no offer for a review. The physical table tent advertises a prize wheel. Verbatim from production tents across our design library: “A little surprise for you” · “Win some very cool gifts” · “Spin the wheel” · “Scan the code, spin the wheel and reveal your prize.” · “Scan to play”.

The printed offer never mentions reviews. What the guest is offered, and the only thing they are offered, is a spin in exchange for scanning a code. That is the advertised bargain, and it is the whole bargain.The guest journey.
1. The guest scans the QR code and lands on the venue’s wheel page.
2. Before spinning, an invitation appears: leave a Google review, or skip. If the guest skips, one further prompt appears; its skip control is labelled “Turn the wheel.” Both prompts are a single tap to dismiss, and declining carries no cost or penalty of any kind.
3. Every path arrives at the same wheel. Review, skip, or skip twice — the guest spins.
4. The prize is drawn at random from a fixed set of sectors the merchant configured at setup.
5. A winning guest receives a single-use digital coupon in Apple Wallet or Google Wallet.A NEGATIVE REVIEW REACHES THE WHEEL EXACTLY LIKE A POSITIVE ONEThis is the point on which the entire analysis turns, so we state it plainly. A guest who leaves a one-star review gets the same spin, at the same odds, for the same prizes, as a guest who leaves five stars — and as a guest who leaves nothing at all.

That is not a policy we enforce. It is a property of the architecture. The review is written inside Google’s own interface, on the guest’s own device. The content of that review never reaches us. We do not receive it, cannot read it, cannot preview it and cannot score it. The wheel therefore has no sentiment signal available to it: there is no field, flag, branch or parameter that could vary an outcome by what the guest wrote, because that information does not exist anywhere in our system.

A mechanism that cannot observe sentiment cannot condition on sentiment. Our compliance here is not a promise about our conduct; it is a consequence of how the system is built.THE REVIEW DESTINATION IS GOOGLE’S OWNWhen a guest chooses to leave a review, they are sent to the first-party Google destination for that business: https://search.google.com/local/writereview?placeid=<the venue’s Google Place ID>

We do not host, intercept, pre-screen, preview, filter or delay the review. It is published by Google, to Google, and neither we nor the merchant can remove it afterwards.FTC — 16 CFR § 465.4, INCENTIVESThe Rule provides: “It is an unfair or deceptive act or practice and a violation of this part for a business to provide compensation or other incentives in exchange for, or conditioned expressly or by implication on, the writing or creation of consumer reviews expressing a particular sentiment, whether positive or negative, regarding the product, service, or business that is the subject of the review.”

Why we comply. The Rule prohibits incentives tied to sentiment. Our mechanism is not tied to sentiment, and is not tied to the review at all: the wheel is delivered whether the guest reviews or not, and whether the review praises or criticises.

The Commission confirmed the scope of the provision in the Rule’s Statement of Basis and Purpose: “Sec. 465.4 does not prohibit paid or incentivized consumer reviews. It only prohibits paid or incentivized consumer reviews when the business soliciting the review provides compensation or an incentive in exchange for a review expressing a particular sentiment.” (89 FR 68055).

Our position does not depend on that concession. We are further from the line: we make no such offer in the first place.FTC — § 465.2 FAKE REVIEWS, § 465.7 SUPPRESSION§ 465.2 — fake or false reviews. Every review is written by a real person who is physically at the business at the moment they write it — the QR code is on the table in front of them. We never write, draft, template, suggest or edit review content, and we have no technical means of submitting a review on anyone’s behalf.

The Rule’s own exception describes our model precisely. § 465.2(d)(1) excludes “Reviews or testimonials that resulted from a business making generalized solicitations to purchasers to post reviews or testimonials about their experiences”. Our solicitation is generalized by construction: every guest who scans sees the same invitation, and we have no mechanism for targeting a subset.§ 465.7 — review suppression. We host no reviews. Reviews are published on Google, where neither we nor the merchant can suppress, hide, reorder or delay them. There is nothing to suppress and no display of ours that could misrepresent a body of reviews.FTC — ENDORSEMENT GUIDES AND REVIEW GATINGThe FTC defines review gating as “a business asks past purchasers to provide feedback on a product and then invites only those who provide positive feedback to post online reviews on one or more websites” (89 FR 68056 n.319). The governing provision, 16 CFR § 255.2(d), states that advertisers “should not take actions that have the effect of distorting or otherwise misrepresenting what consumers think of their products”.

Why we comply. Gating requires two things we do not have: a step that measures sentiment, and a branch that treats guests differently based on it. Boomerang Reviews has neither. There is no rating question, no “how was your visit?” fork, no private-feedback form, and no path that a dissatisfied guest is routed down. There is one invitation and one destination.

Example 11 to the Guides describes the prohibited pattern and then names the compliant alternative, which is what we do: “If, in the alternative, the marketer had simply invited all recent purchasers to provide feedback on third-party websites, the solicitation would not have been unfair or deceptive, even if it had expressed its hope for positive reviews”.GOOGLE — INCENTIVES AND THE SAFE HARBOURGoogle’s Maps user-contributed content policy states that merchants may not “Offer incentives – such as payment, discounts, free goods and/or services - in exchange for posting any review or revision or removal of a negative review”.

Why we comply. The prohibition turns on the words in exchange for. An exchange means the thing of value is given for the review — that withholding the review withholds the reward. In Boomerang Reviews it does not, and cannot. The advertised offer, printed on the tent the guest is looking at, is a prize for scanning; reviews are not mentioned on it. A guest who declines the review reaches the wheel and wins from the identical prize set. A guest who leaves a critical review reaches the same wheel with the same odds. Nothing is withheld from anyone for not reviewing, or for reviewing unfavourably.

Google’s safe harbour permits merchants to “Solicit or encourage the posting of content that does represent a genuine experience, without offering incentives to do so or attempting to influence the rating or the contents of the review”. We satisfy both limbs. We offer nothing to do so — the prize is not offered in order to obtain a review; it is offered for scanning, to everyone, and it arrives regardless of the guest’s choice. And we never ask for a star count, never suggest wording, never request that a staff member or product be named, and never see the review. Our invitation asks for a review; it does not ask for a good one.GOOGLE — SELECTIVE SOLICITATION AND ON-PREMISES REQUESTSGoogle further prohibits merchants from “Discourage or prohibit negative reviews, or selectively solicit positive reviews from customers”.

Why we comply. We do not discourage negative reviews — we deliver the prize to guests who leave them, on identical terms. We do not selectively solicit, because we have no ability to: the invitation is shown to every guest who scans, and we possess no data at that moment about whether the guest is happy.

Google also asks that, when soliciting reviews, merchants “should not require or pressure users to leave ratings or write reviews while on the premises, nor should they request that specific content be included”. A table tent is on the premises, so we hold ourselves expressly to this. Nothing is required: the skip control is a working path to the prize, and on the second prompt its label is literally “Turn the wheel.” Nothing is pressured: declining costs the guest nothing — not the spin, not the prize, not the odds. Google’s concern here is coercion, and there is no leverage in our flow to coerce with, because refusal has no consequence. We never request specific content, and our merchant terms forbid staff from watching, prompting or standing over guests.GOOGLE — THE OFFICIAL REVIEW MECHANISMGoogle publishes a first-party review link and QR-code generator, and expressly contemplates printing it for in-store display: “To make it easier for customers to leave reviews on your Business Profile, you can create and share a link or QR code to request reviews. … Print and display the QR code in your store”.

Boomerang Reviews routes to that same first-party destination, keyed to the venue’s Google Place ID. We use Google’s mechanism, in the manner Google describes.Enforcement context. The FTC’s Rule carries civil penalties, and they have been used. In In the Matter of Vanilla Chip LLC d/b/a TruHeight (File No. 242 3093, April 2026) the Commission charged § 465.4 where a business offered a discount to consumers who would “take a moment to leave a 5-star review”. The distinction that decides such cases is the one this page turns on: that business conditioned its discount on a five-star rating. Boomerang Reviews conditions nothing on anything.YELPYelp is the strictest platform in the market: it prohibits soliciting reviews at all, as a contractual representation and warranty rather than mere guidance. Under the Additional Terms for Business Accounts, a business warrants that it will not “offer incentives of any kind, such as discounts, freebies, refunds, gift cards, contest entries, offers, or deals in exchange for the posting of reviews of your Business … solicit or ask for reviews from your customers”.

Why we comply. Boomerang Reviews does not solicit Yelp reviews. It is configured for Google Business Profile; the review destination is a Google URL; no part of the product links to, mentions or directs a guest toward Yelp. Yelp’s obligations concern reviews of the business on Yelp, and we never seek one.

We treat this as a hard boundary rather than an assumption: our merchant terms make it a condition of use that the mechanism is not repointed at Yelp. No configuration of our product could be made Yelp-compliant, because our product asks — and on Yelp, asking is itself the violation.TRIPADVISORTripAdvisor encourages businesses to ask for reviews, but bans incentives in the broadest terms of any platform: “It is against our guidelines to offer or promise anything in exchange for any reviews, irrespective of rating. Examples include offers for free drinks, discounts, entry into a contest”.

Why we comply. We do not direct guests to TripAdvisor, so the rule is not engaged. But our mechanism would satisfy it on the merits: we offer nothing in exchange for a review of any rating, because the prize is not exchanged for the review.TripAdvisor also sets the most operationally precise gating standard published by any platform — a user-interface parity test: “If any survey or external website ultimately directs users to submit a review on Tripadvisor, the user interface and experience for submitting positive and negative reviews must be identical”.

We pass this test absolutely rather than approximately. There are not two interfaces whose parity must be maintained; there is one. A guest intending to praise and a guest intending to complain see the identical screen, tap the identical button and arrive at the identical page, because the system has no way to tell them apart.

Two further TripAdvisor prohibitions describe conduct our design excludes: “withholding any element of service until a user submits a review” — we withhold nothing — and “monitoring users while they write reviews”, which our merchant terms forbid.BETTER BUSINESS BUREAUBBB is stricter than federal law by design, and says so: “BBB’s Customer Review Acceptance Policy goes beyond FTC’s legal requirements and prohibits customer reviews that are incentivized even if a disclosure is made”. Every BBB reviewer attests that they “have not been offered and have not received any incentive or compensation originating from the business.”

Why we comply. Boomerang Reviews does not direct guests to BBB. And on the merits, a guest who plays our wheel has not been offered an incentive for a review: the spin was offered for scanning a code and would have been theirs had they never written a word.META — FACEBOOK AND INSTAGRAMUnder Fake Review Fraud and Scam, Meta’s Community Standards prohibit content that “Implicitly or explicitly incentivises users to provide reviews in exchange for discounts, refunds or free items”.

Why we comply. We do not solicit Facebook Page Recommendations, publish to Meta on a merchant’s behalf, or offer anything for a Meta review. Instagram provides no native business review feature, so there is nothing there to solicit.

On the merits, note Meta’s word “implicitly”. That word is aimed at unstated quid pro quos — arrangements where the exchange is understood although unspoken. Ours is the opposite case: the absence of an exchange is not merely unstated but demonstrable, because the guest who gives nothing receives exactly the same thing as the guest who gives a review.TRUSTPILOTTrustpilot states plainly: “We don’t allow incentivized reviews on Trustpilot”. Its Guidelines for Businesses prohibit offering “discounts, promo codes, prize draw entries, refunds, freebies, or any other benefit connected with your business for leaving a review”, and prohibit “Pre-screening people who leave a review by directing customers who have had a good experience to leave a review and those with a bad experience to contact you directly”.

Why we comply. We do not solicit Trustpilot reviews. On the merits, our invitation satisfies Trustpilot’s positive requirement exactly — it asks businesses to “Invite consistently and fairly … inviting everyone in the same way, and at the same point in the customer journey, regardless of whether they’ve had a positive or negative experience”. Our invitation is triggered by a QR scan, and a scan carries no information about whether the guest is pleased.FURTHER INFORMATIONG2G2 serves B2B software and is outside our market, but its rules are instructive because G2 permits incentives under defined conditions, and the first of those conditions is ours: “eligibility to receive an incentive is never based on the opinions, positive or negative, expressed in the review”. G2 separately prohibits “collecting reviews by any method that segments out potentially negative reviews or exclusively targets positive reviews; conditioning incentives on reviews being positive”.

We do not solicit G2 reviews. On the merits, our mechanism is sentiment-blind by construction, segments nothing, targets no subset and discourages nothing.What Boomerang Reviews does not doWe do not withhold, reduce, or alter any prize because a guest declined to review.
We do not withhold, reduce, or alter any prize because a review was critical.
We do not vary prize odds or prize value by review sentiment or review status.
We do not ask guests to rate their experience before deciding where to send them.
We do not route dissatisfied guests to a private form instead of the public page.
We do not write, draft, template, or suggest review text.
We do not submit reviews on anyone’s behalf.
We do not buy reviews or pay per review.
We do not see, preview, filter, delay, edit, remove, or suppress reviews — and have no technical means to.
We do not solicit reviews from staff, owners, or their relatives.
We do not target only customers we expect to be satisfied.
We do not offer anything for editing or deleting an existing review.
We do not direct guests to Yelp, TripAdvisor, BBB, Trustpilot, Meta, or G2.Conditions of use for merchantsThese are contractual conditions, not recommendations. A merchant who breaches them is outside our terms.

1. Never present the prize as payment for a review. The wheel belongs to every guest who scans. Staff must not say “leave a review and spin”.
2. Never ask only satisfied customers. Place the tent where every guest can see it.
3. Never watch, prompt, or stand over a guest while they use the wheel or write a review.
4. Never request a specific rating, specific wording, or a mention of a staff member.
5. Never offer anything for changing or removing an existing review.
6. Do not repoint the mechanism at Yelp, TripAdvisor, BBB, Trustpilot, Meta or G2. Boomerang Reviews is configured for Google Business Profile.
7. Respond to critical reviews honestly and publicly. A profile of unbroken praise is less persuasive than a real one, and suppressing criticism is unlawful.SOURCES, LIMITATIONS AND CONTACTPrimary sources. 16 CFR Part 465 (ecfr.gov) · Statement of Basis and Purpose, 89 FR 68034 · 16 CFR Part 255 (ecfr.gov) · FTC, The Consumer Reviews and Testimonials Rule: Questions and Answers (ftc.gov) · Google Maps user-contributed content policy (support.google.com/contributionpolicy/answer/7400114) · Google Business Profile review link and QR code (support.google.com/business/answer/16816815) · Yelp Terms of Service, Additional Terms for Business Accounts (terms.yelp.com) · TripAdvisor Trust & Safety Review Posting Guidelines (tripadvisor.com) · BBB, Are paid customer reviews legal? (bbb.org) · Meta Community Standards, Fraud, Scams and Deceptive Practices (transparency.meta.com) · Trustpilot Guidelines for Businesses, v7.2 June 2026 (corporate.trustpilot.com) · G2 Community Guidelines (legal.g2.com).

Limitations. This page is not legal advice. Platform policies change without notice; every quotation was verified against the primary source on the date shown above. Platform rules are independent of, and in places stricter than, federal law, and where they diverge we apply the stricter standard. Non-U.S. merchants are subject to their own consumer-protection regimes, which this page does not address.

Contact. Boomerangme, Inc., 24A Trolley Square, Unit #4087, Wilmington, DE 19806, United States. Questions about this page: support@boomerangme.com