Marketplace Ranking & Sponsored Placement Rules

Organic Search, Recommendation, Visibility, Sponsored Placement and Advertising Transparency

1. Scope and Relationship to Other GetClinic Rules

These Rules apply to Clinic ordering and visibility in GetClinic search results, browse pages, recommendation surfaces, inquiry routing, featured modules and sponsored/promoted placements.

They do not determine whether a healthcare advertisement is legally permissible. The Clinic Consent, Marketing & Advertising Policy (CMAP), where incorporated, governs healthcare-advertising legality, claim substantiation, Patient marketing authorization, before/after imagery, testimonials and promotional content. The Review Integrity Policy governs review collection, verification, moderation and scoring. The MSA and DSA / Content Moderation & Illegal Content Reporting Policy govern restrictions imposed for compliance, safety or illegal-content reasons.

These Rules are the sole canonical GetClinic statement of the main ranking parameters, the reasons for their relative importance and the role of remuneration in ranking. Other GetClinic agreements, schedules, policies, help text and interface disclosures may cross-reference or summarize these Rules where needed for context, but must not independently restate or vary the canonical parameter description. If a GetClinic text conflicts with these Rules on that description, these Rules control for the ranking-mechanics point, subject to the MSA’s overall contractual precedence and mandatory law. These Rules describe the ranking and advertising parameters at a level intended to be useful and understandable without disclosing source code, exact weights, anti-fraud thresholds or information that would materially enable manipulation, deception, fraud, security circumvention or gaming of GetClinic systems.

2. Organic Ranking - Main Parameters

GetClinic may use a combination of the following main parameters to determine the relative order, recommendation, routing or visibility of Clinics. Not every parameter is used on every surface.

3. Why the Relative Importance Can Change

Patient-selected filters or sort controls can change which parameters matter most for that search. For example, selecting a destination, language or timing preference can increase the importance of that criterion.

Different marketplace surfaces can have different purposes. A treatment-category page, destination page, default search result and inquiry-routing workflow do not need to use identical parameter importance.

Data availability matters. A newly onboarded Clinic may have little historical feedback or marketplace-performance data; absence of history is not automatically treated as evidence of poor medical quality.

Safety, legal, fraud or platform-integrity controls may override ordinary ranking where GetClinic reasonably needs to protect Patients, comply with law or enforce platform rules.

GetClinic may test or improve ranking systems, but a test must not be used as a disguised way to sell undisclosed organic rank.

4. Patient Controls and Recommendation Transparency

Where GetClinic provides filters, sort choices or recommendation options, Patients can use those controls to influence the information shown to them. Available controls may include Treatment/procedure, destination/location, language, availability, price/package characteristics or other marketplace criteria.

Where several recommender-system options are made available for the same prioritised surface and applicable law requires it, GetClinic will make the relevant selection control directly and easily accessible from that surface.

Search results, badges, rankings, recommendations and sponsored placements are marketplace-navigation tools. They are not individualized medical advice, a determination of clinical suitability or a guarantee that a higher-ranked Clinic is medically superior.

5. Organic Ranking Is Not Pay-to-Play

GetClinic's default rule is that ordinary commercial payments to GetClinic do not secretly improve organic ranking. Subscription tier, Case Workflow Fee, Usage-Based SaaS fees, use of GetClinic payment technology or the amount/value of a Patient Treatment is not by itself an organic-ranking factor.

A paid product feature may improve presentation or visibility only to the extent the effect is transparently described. If remuneration is used to influence placement, that effect must be treated as sponsored/promoted visibility or another paid mechanism disclosed under these Rules and the applicable campaign/order terms.

No Clinic can pay to remove a safety/compliance restriction, purchase a verification status, suppress genuine negative reviews or bypass the Clinic's legal, licensing, refund, privacy, advertising or Patient-protection obligations.

6. Sponsored Placement - What Payment Can Change

A Clinic may purchase sponsored/promoted visibility under an applicable Order Form or campaign order. Subject to legal and product availability, sponsored placement may affect:

• whether the Clinic is eligible to appear in a designated sponsored module or sponsored slot;
• the Clinic's relative position within sponsored inventory;
• campaign timing, geographic market, Treatment/procedure category or contextual search surface covered by the campaign;

campaign caps, pacing, budget or delivery frequency; and

other expressly disclosed paid-placement mechanics stated in the campaign/order terms.

Sponsored purchase does not guarantee impressions, clicks, inquiries, consultations, Bookings, Treatment outcomes, a specific organic position or any minimum commercial result unless the campaign/order terms expressly provide a measurable commitment.

7. Sponsored Placement - Labeling and Ad Transparency

Sponsored/promoted content must be distinguishable from ordinary organic results. GetClinic may use labels such as 'Sponsored', 'Promoted', 'Ad' or an equivalent clear term appropriate to the interface and applicable law.

Where the Digital Services Act or equivalent law applies to an advertisement, GetClinic will provide the legally required real-time advertising transparency, including, as applicable:

• a clear indication that the information is an advertisement;
• the natural or legal person on whose behalf the advertisement is presented;

the natural or legal person who paid for the advertisement if different; and

meaningful, directly accessible information about the main parameters used to determine the recipient/audience for the advertisement and, where applicable, how the recipient can change those parameters.

A sponsored label is not a disclaimer that cures an otherwise unlawful or misleading healthcare advertisement. Clinic advertising content remains subject to CMAP, the Healthcare Advertising Jurisdiction Register where applicable, the MSA and mandatory healthcare-advertising rules.

Where Digital Services Act Article 26(2) applies, GetClinic will provide the applicable functionality for a Clinic or other content provider to declare that content is or contains a commercial communication. Clinic must use that functionality accurately and must not intentionally omit or misstate a required commercial-communication declaration.

8. Health Data, Profiling and Minors in Sponsored Delivery

GetClinic will not use Patient Health Data from private medical interactions, medical records, private Patient-Clinic messages or other private health-data surfaces to build targeted-advertising audiences for Clinic sponsored placement.

Where EU Digital Services Act Article 26(3) or equivalent law applies, GetClinic will not present advertisements based on profiling that uses special-category personal data. Contextual placement based on the content of the current marketplace page or a Patient's current search/filter choice must not be converted into a hidden longitudinal health-advertising profile where that would be unlawful.

Where Digital Services Act Article 28(2) applies and GetClinic is aware with reasonable certainty that a recipient is a minor, GetClinic will not present advertisements to that recipient based on profiling using that recipient's personal data. This does not require GetClinic to process additional personal data solely to determine whether a recipient is a minor. This advertising rule is separate from CMAP's stricter default prohibition on promotional content involving minors unless expressly cleared.

9. Contextual Sponsored Matching

Sponsored inventory may be contextually matched to the marketplace surface being viewed, such as a Treatment category, destination, language or other current-search criterion, where lawful. Contextual relevance is intended to keep sponsored results useful to the Patient; payment does not entitle a Clinic to appear for an unrelated Treatment, geography or category.

Clinic must not misclassify Treatments, destinations, languages, facilities or other campaign attributes merely to enter a higher-demand sponsored inventory segment.

10. Restrictions, Demotions and Ranking Enforcement

Compliance, safety, fraud, sanctions, payment-risk, privacy/security, misleading-content or repeated Patient-protection failures can reduce Clinic visibility or routing under the MSA. Such a restriction is different from an ordinary position change caused by dynamic relevance, availability or other ranking parameters.

Where applicable law or the MSA requires a statement of reasons for a restriction, suspension or delisting, GetClinic will provide it through the applicable MSA Schedule 6 / DSA process. GetClinic is not required to issue an individualized notice every time a Clinic moves up or down because ordinary ranking inputs or Patient search criteria changed.

Buying sponsored placement does not neutralize, conceal or override a ranking restriction. A restricted Clinic may be excluded from sponsored inventory if necessary to enforce the restriction or protect Patients.

11. Accuracy, Data Quality and Clinic Conduct

Clinic is responsible for keeping marketplace information that can affect ranking or sponsored eligibility accurate and current. Clinic must not manipulate ranking by falsifying availability, creating fake reviews, generating artificial inquiries, misclassifying procedures, using duplicate listings, misrepresenting response activity or coordinating other deceptive activity.

GetClinic may disregard, down-weight, remove or investigate signals reasonably believed to be fraudulent, duplicated, manipulated, technically anomalous or otherwise unreliable. The specific anti-gaming thresholds and fraud-detection logic are internal controls and are not published where disclosure would materially facilitate circumvention.

12. Sponsored Campaign Eligibility and Content Gate

A paid campaign is not publication approval. Sponsored delivery should fail closed unless the Clinic/listing is eligible for the represented scope and the sponsored content passes the applicable advertising, consent, jurisdiction and product gates.

Recommended sponsored-placement gate: sponsored_placement_deliverable = clinic_scope_eligible AND campaign_order_active AND campaign_creative_approved AND healthcare_advertising_clearance_satisfied AND payment_status_valid AND no_active_visibility_prohibition

If a campaign becomes ineligible after launch, GetClinic may pause or stop delivery. Commercial credits/refunds, if any, are governed by the applicable campaign/order terms and mandatory law rather than by this Policy alone.

13. Clinic Complaints and Ranking Questions

Clinic may submit a question or complaint concerning ranking transparency, an alleged ranking/restriction measure, sponsored-campaign delivery or GetClinic's application of these Rules through the Clinic portal support channel or [email protected].

Where MSA Schedule 6 applies, the Clinic complaint process, statement-of-reasons rights, P2B rights and DSA redress rights remain available according to that Schedule. A complaint does not entitle Clinic to exact algorithmic weights, confidential anti-fraud logic, another Clinic's confidential data or information whose disclosure would materially enable manipulation or compromise security.

14. Changes to Ranking Systems and These Rules

GetClinic may update ranking systems as the marketplace, Patient needs, safety controls and law evolve. Material changes to the main parameters, the reasons for their relative importance or the role of remuneration in ranking will be made in these Rules as the canonical text and, where required, before the changed terms take effect.

For Clinics, these Rules are incorporated by the MSA rather than by an optional policy field. A future MRSP version may become effective only through the MSA Section 1.2 notice/update mechanism and any additional mandatory-law requirement; a new Portal Commercial Record or separate policy-incorporation event is not required merely because the MRSP version changes. GetClinic will not silently replace the text of an MRSP version already effective for Clinic, and publication of a new version does not by itself accelerate or bypass the applicable notice period.

For Patients, the then-current public Rules supplement the ranking disclosures in the Patient Marketplace Terms. If mandatory law requires the main recommender parameters to appear directly in terms and conditions, the Patient Terms remain the controlling terms-level disclosure.

15. Regulatory Transparency Reference

These Rules are designed to support, where applicable, the ranking-transparency requirements in Regulation (EU) 2019/1150 Article 5 and the advertising/recommender transparency requirements in Regulation (EU) 2022/2065 Articles 26 and 27. They do not state that either Regulation applies to every Clinic, Patient, market or GetClinic service configuration.

Annex A - Public Ranking Parameter Summary

Internal controls. GetClinic maintains separate internal campaign, disclosure and anti-manipulation records to evidence implementation of these Rules. Those internal records and thresholds are not part of this public Policy where disclosure would add no material user transparency or would materially facilitate gaming, fraud or security circumvention.