Client reviews & feedback policy

1. Our commitment

At Montelux, we believe trust is built on transparency.

This policy explains how we collect, verify, moderate, publish, and manage client reviews and feedback across our entities. The same Montelux standards apply globally. Where local laws impose additional or specific obligations, those are set out in the regional sections below.

This policy is designed to comply with:

• the EU Omnibus Directive (2019/2161), the Unfair Commercial Practices Directive, the GDPR, and the Digital Services Act, in the European Union and EEA;
• the Canadian Competition Act (including section 74.01 on misleading representations), PIPEDA, and applicable Ontario consumer protection law, in Canada.

Each Montelux entity collects, stores, and publishes reviews from its own clients independently. Reviews are not pooled or shared across entities.

2. Reviews vs. formal complaints

Reviews are public feedback intended to inform other clients. They are not a substitute for our formal complaints procedure.

If you wish to file a formal complaint regarding our services (including matters related to payments, fees, account access, or regulatory issues) please follow our dedicated complaints procedure available here. Complaints are handled in accordance with the regulatory obligations of the Montelux entity with which you contracted (see Annex A).

3. Who can leave a review

Only individuals or entities who are, or have been, clients of a Montelux entity may submit a review to that entity. We do not accept reviews from non-clients, employees, competitors, or third parties unrelated to a genuine service experience.

Reviews may be submitted:

• voluntarily, through your client account or direct communications with us;
• in response to an occasional feedback request from our team (e.g. by email).

Not all clients are systematically invited to leave a review.

4. No incentives for positive reviews

We do not offer payment, discounts, gifts, or any other benefit in exchange for positive reviews. Where any incentive is offered for participating in a feedback process (regardless of the rating given), this will be clearly disclosed at the time of the request, and the resulting review will be flagged accordingly.

We do not publish fake or fabricated reviews, commission reviews from third parties posing as clients, or suppress legitimate negative reviews.

5. Authenticity & verification

We take reasonable and proportionate measures to ensure that published reviews originate from genuine clients who have used our services.

Our verification process includes:

• linking the review to an active or past client account of the relevant Montelux entity;
• cross-checking that the reviewer has used the service referenced in the review;
• screening for indicators of inauthentic, automated, or manipulated activity.

A review that has been successfully matched to a verified client relationship is displayed with a “Verified Review” indicator. Reviews that cannot be verified may still be published if they are consistent with our standards, but they will not carry the “Verified” label.

6. Moderation

All reviews are reviewed prior to publication. Reviews are published whether they are positive, neutral, or negative, provided they comply with this policy.

A review may be rejected, anonymised, or removed if it contains:

• unlawful, abusive, defamatory, discriminatory, harassing, or fraudulent content;
• sensitive personal data (of the author or of third parties);
• confidential client information, account numbers, or transaction data;
• spam, promotional content, or material unrelated to our services;
• content that misrepresents the reviewer’s relationship with us.

We do not edit the substance or meaning of client reviews. Where we redact content (e.g. to remove personal data), this will not alter the overall assessment expressed by the client.

Moderation is performed by the team of the relevant Montelux entity, supported where appropriate by automated filters that detect spam, profanity, or duplicate submissions. No automated decision results in a final removal without human review.

7. Publication & display

Reviews are generally published within a reasonable timeframe following submission and verification.

Reviews are displayed by Montelux entity. Visitors to our website are shown the reviews that correspond to their region or to the entity they select. Reviews from one entity are not aggregated with reviews from another.

When we display an aggregated rating for a given entity, it is calculated as a simple arithmetic mean of all eligible reviews published for that entity over the displayed period. The number of reviews used for the calculation is displayed alongside the rating.

Within a given entity’s set of reviews, items are displayed in chronological order by default; users may sort or filter them according to the options available on the page.

8. Right of reply

The relevant Montelux entity may publicly respond to a review to provide additional context, correct factual inaccuracies, or signal that an issue has been resolved. Responses are clearly identified as coming from Montelux.

9. Personal data

Reviews are typically displayed with limited identifying information, such as a first name, an initial, or a username, together with the country and the date of the review.

Personal data collected through reviews is processed in accordance with our Privacy Notice and the applicable laws set out below. Reviews and associated personal data are retained for as long as the review remains relevant for prospective and existing clients, and in any event no longer than 5 years from publication, after which they are deleted or anonymised.

Each Montelux entity acts as the independent controller of the personal data of its own clients. Reviews submitted to one entity are stored and processed on infrastructure dedicated to that entity, and are not shared with the other Montelux entity.

9.1 Additional information for EU/EEA clients

If you are a client of Montelux Finance UAB, the GDPR applies to the processing of your personal data.

• Controller: Montelux Finance UAB, Žalgirio g. 88-101, LT-09303 Vilnius, Lithuania.
• Legal basis: legitimate interest in collecting and publishing client feedback, and your consent for the publication of any optional content (e.g. first name).
• Your rights: access, rectification, erasure, restriction, objection, portability, and the right to lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI) or your local supervisory authority.
• Data Protection Officer: dpo@montelux.com.
• Reviews contact: reviews-eu@montelux.com.

9.2 Additional information for Canadian clients

If you are a client of Montelux Payments Ltd (Canada), PIPEDA and applicable Ontario law apply to the processing of your personal data.

• Controller / Accountable organisation: Montelux Payments Ltd, 18 King Street East, Toronto, Ontario, Canada.
• Purpose: collection and publication of client feedback to inform prospective and existing clients, and to improve our services.
• Your rights: access to your personal information, correction of inaccurate information, and withdrawal of consent (subject to legal and contractual restrictions).
• Data location: reviews submitted to Montelux Payments Ltd (Canada) are stored on infrastructure dedicated to the Canadian entity.
• Complaints: you may file a privacy complaint with the Office of the Privacy Commissioner of Canada (OPC) or, where applicable, with the Information and Privacy Commissioner of Ontario.
• Privacy Officer: privacy.ca@montelux.com.
• Reviews contact: reviews-ca@montelux.com.

10. Reporting a review

If you believe a review is inappropriate, misleading, fraudulent, or otherwise non-compliant with this policy, you can report it by contacting the relevant Montelux entity (see Annex A).

Each report is acknowledged and reviewed within a reasonable timeframe, generally 7 business days. We will inform you of our decision and the reasons for it. Where a review is removed, the author will be notified and may appeal the decision by replying to that notification within 14 days.

11. Policy updates

We may update this policy from time to time to reflect changes in our practices, technologies, legal obligations, or regulatory expectations. The date of the latest update is shown below. Material changes will be communicated to clients through appropriate channels.

Annex A. Montelux entities and contact details