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1 © INFOMEDIA Services Limited, All Rights Reserved 2016 CHARGE TO MOBILE UAE FRAMEWORK VERSION 5.2 JUNE 2017

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Page 1: CHARGE TO MOBILE UAE FRAMEWORK

1 © INFOMEDIA Services Limited, All Rights Reserved 2016

CHARGE TO MOBILE UAE FRAMEWORK VERSION 5.2 JUNE 2017

Page 2: CHARGE TO MOBILE UAE FRAMEWORK

2 © INFOMEDIA Services Limited, All Rights Reserved 2016

DOCUMENT CONTROL

TITLE: CHARGE TO MOBILE UAE FRAMEWORK

OWNER: Iain Lill

VERSION CONTROL

VERSION AUTHORS COMMENTS

1.6 SM Initial version

2.0 CL 2nd Draft

2.1 MGT Amends

2.2 GC Amends for du compliance alignment

2.3 GC Addition of Explicit Terms formatting

2.4 GC Amends

2.5 GC Amends for Etisalat Customer Life Cycle Policy v1.4

2.6 AS

Updates to: double opt in flows, refund policy, whitelisting and blacklisting policy, price format display, adding monthly reminder message, inactivity policy, MSISDN announcement display through flows, T&C’s split per operator, engagement data, self-help portal, CS scripts, advertising data

2.7 AS

Updates to advertising flows: turning the top of the page into a help area, reiterating charge to

mobile on all pages, updating success pages to include SMS info and simplifying the help

section, changing CTA to ‘subscribe’ instead of ‘join’, restricting animation, changed terms &

conditions to links with some terms displayed, banning back button redirects to further

subscription landing pages, banning countdown timers, clarifying there should be no landing

page pop ups without banner clicks and merging the 1st 2 steps of the WiFi flow. Clarification

on retry policy

2.8-9 AS

Amends to include Etisalat’s Customer Life Cycle Policy v1.5

Confirming breaches ramifications, confirming prohibited websites, DCB platform running rate,

step charging policy, retry policy, pending payment cycles policy, content access for failed bills,

use of Etisalat logo, displaying name of service on WiFi pages, SMS embargo times and days,

protecting customer information, 24/7 customer support through email and portals, working

UAE office hours, storage for 1 year, setting the CS KPI level, setting CS SLAs, removing

inactivity warning message.

2.10

2.11

IL 10/05/16

o Incorporate update to TRA CPR v1.1

o Moved Privacy requirements into Cultural Policy section

o Harm & Offence section - this provides further clarity and detail in relation to material

which is prohibited and that this covers both advertising material and content and

particularly references Shari'ah

o Whitelisting - greater clarity and states cannot be invoiced for

o Advertising - clarifies eye movement monitoring technology cannot be considered

'interaction'

o Landing page - CTA must include any free trial period in the text on it

o Refunds - permits refunds by money transfer services (e.g. paypal)

- sets out requirements for 'unsatisfied with service' type refund scenarios

o Added more detailed CS KPI section

o Added updated Etisalat requirements

2.12 IL 25/07/16

o Added Du step charging requirements

o Added Growth Caps and Free Trial sections

o Clarity around double opt-in on WIFI flow

o Updated Introduction for clarity

o Simplified flows to single section with key carrier differences set out in that section

o Added STOP commands section

o Section and layout re-arrangement for clarity, consistent with other Frameworks, also

grammatical and spelling corrections

3.0 IL 07/10/2016

o Changed User Inactivity Limit for Etisalat – 90 days for weekly billing, 6 months for

monthly billing, consequential update to Service Delivery Modes section.

o Re-drafted Retries & Stepcharging Policies following updates from Etisalat and Du

o Removed requirement for pricing banner

Page 3: CHARGE TO MOBILE UAE FRAMEWORK

3 © INFOMEDIA Services Limited, All Rights Reserved 2016

o Added Du breach penalties

o Updated Advertising to specifically reference TRA Consumer Protection Guidelines s.16

o Fully updated User Acquisition flows and consequential section arrangement

o Clarified Success page only mandatory on Etisalat

o Clarified that no carrier logos should be used

4.0 IL 21/11/2016

o 7.2 Consent To Charge – requirements added

o 9.2 User Acquisition Flows – updated to show flows for C2C flows only (du single click

and coincident changes), merchants to contact IMS if not using C2C.

o 10 Customer Messaging – updated to remove superfluous recommendations

o 10.5 Incorrect Subs Message – must state all unsubscription options within message

o 11.1 Customer Care – Only email is mandatory, telephone support is recommended but

right to mandate is reserved in case of unacceptable CS rates from carrier. Other minor

changes to improve clarity of section. Requirement for Etisalat CS Reporting added,

particularly requirement for reporting user service usage details.

4.1 IL 22/11/2016

o 9.1.2/9.2.2 Added new TRA requirement for close button on all landing pages

o 8.2/8.5 Advertising rules and requirements clarified, prohibited practices now all in one

place (8.2) and banners section (8.5) limited to positive requirements

4.2 IL 08/12/2016

o Etisalat require pricing on banners

4.3 IL 30/01/2014

o Etisalat policy changes:

o 7.4 - Mandatory free trial

o 9.1.2 & 9.2.2 – Service details text now prescribed

o Pop-up must have cancel button or link

4.4 IL 30/01/2014

o Etisalat policy changes clarified:

o 9.1.2 & 9.2.2 - Price, frequency and free period must be displayed directly

below CTA

o 9.1.2 & 9.2.2 – Prescribed service text must be in bullet points

4.5 IL 20/02/2017

o Du Policy Changes

o No new products will be approved with a web-based subscription flow. All

new products must be based on a native app download prior to

subscription.

o All subscription flows, new and existing, must be a PIN or password flow

with the user requesting their PIN/password, being sent it by text and then

entering that password in a confirmation page.

4.5.1 IL 20/02/2017

o Etisalat: Exit button must be a button not a link (9.1,9.2)

5.0 IL 29/03/2017

o Adverts should not target users under 18 (8.2)

o Creative in advertising banners should be linked to creative on landing page (8.5)

o Substantial changes to flows following TRA requirement for PIN or similar flows (9)

5.1 IL 25/04/2017

o New Etisalat Policy:

o Text of PIN message

5.2 IL 07/06/2017

o Etisalat requirements updated; text appearing on CTA buttons mandated.

o Recommendation to place PIN as close as possible to the start of PIN message

Page 4: CHARGE TO MOBILE UAE FRAMEWORK

4 © INFOMEDIA Services Limited, All Rights Reserved 2016

CONTENTS

1 INTRODUCTION ................................................................................................. 6

2 CONTACT ........................................................................................................... 6

3 BREACHES ......................................................................................................... 7

4 SPEND LIMITS .................................................................................................... 7

5 COMMENCEMENT OF A SERVICE ................................................................... 8

6 CULTURAL POLICY ............................................................................................ 9

6.1 TRUTHFULNESS ............................................................................................. 9

6.2 LEGALITY ......................................................................................................... 9

6.3 PRIVACY .......................................................................................................... 9

6.4 HARM AND OFFENCE ................................................................................... 10

7 SUBSCRIPTION SERVICES ............................................................................. 11

7.1 ACTIVATING AND DEACTIVATING SUBSCRIPTION SERVICES ................ 11

7.2 CONSENT TO CHARGE ................................................................................ 11

7.3 SUBSCRIPTION RENEWAL .......................................................................... 12

7.4 FREE TRIAL PERIODS .................................................................................. 12

7.5 GROWTH CAPS ............................................................................................. 12

7.6 RETRY AND STEP CHARGING POLICIES ................................................... 13

7.7 WHITELISTING & BLACKLISTING ................................................................ 15

7.8 PULL/PUSH MODE SERVICE DELIVERY & USEAGE .................................. 15

7.9 USER INACTIVITY LIMITS ............................................................................. 15

8 ADVERTISING & MARKETING ......................................................................... 16

8.1 AFFILIATE MARKETING ADVICE: ................................................................. 16

8.2 PROHIBITED MARKETING PRACTISES ....................................................... 17

8.3 NON-EXPLOITATION OF CUSTOMERS ....................................................... 17

8.4 CARRIER LOGOS .......................................................................................... 18

8.5 ADVERTISING BANNERS ............................................................................. 18

9 USER ACQUISITION FLOWS ........................................................................... 19

9.1 3G/4G HE USER ACQUISITION FLOW ......................................................... 19

9.1.1 FLOW OVERVIEW ..................................Error! Bookmark not defined.

9.1.2 LANDING/CONFIRMATION PAGE LAYOUT AND CONTENT

REQUIREMENTS .................................................Error! Bookmark not defined.

9.2 WIFI/NON-HE USER ACUISITION FLOW .........Error! Bookmark not defined.

9.2.1 FLOW OVERVIEW (PIN FLOW) .......................................................... 23

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5 © INFOMEDIA Services Limited, All Rights Reserved 2016

9.2.2 PIN FLOW LANDING PAGE LAYOUT AND CONTENT

REQUIREMENTS .................................................Error! Bookmark not defined.

9.3 SUCCESS PAGE ............................................................................................ 26

9.4 TERMS AND CONDITIONS FOR SUBSCRIPTION SERVICES .................... 27

10 CUSTOMER MESSAGING ............................................................................ 29

10.1 PIN MESSAGE ............................................................................................. 30

10.2 WELCOME MESSAGE ................................................................................. 30

10.3 SUBSCRIPTION RENEWAL MESSAGE ...................................................... 30

10.4 EXITING A SERVICE .................................................................................... 32

10.5 INCORRECT UNSUBSCRIPTION REQUEST MESSAGES ........................ 33

10.6 SPEND LIMIT MESSAGES .......................................................................... 33

10.7 STEP CHARGING MESSAGE ...................................................................... 33

10.8 USER INACTIVITY MESSAGE ..................................................................... 33

10.9 MARKETING MESSAGES ............................................................................ 34

11 CUSTOMER SUPPORT ................................................................................. 35

11.1 CUSTOMER CARE....................................................................................... 35

11.2 CUSTOMER SUPPORT KEY PERFORMANCE INDICATOR ...................... 37

11.3 REFUNDS ..................................................................................................... 38

11.4 UNSUBSCRIPTION FUNCTIONALITY ......................................................... 39

12 DATA .............................................................................................................. 41

Page 6: CHARGE TO MOBILE UAE FRAMEWORK

6 © INFOMEDIA Services Limited, All Rights Reserved 2016

1 INTRODUCTION

This document applies to premium rate services (PRS) that run billing via

INFOMEDIA for customers of Etisalat / du in the United Arab Emirates.

The document provides the framework for all services that use the INFOMEDIA

Mobile Payment Platform in the territory. Merchants must follow this guidance on the

user acquisition flows and in-life messaging to ensure the operation of compliant

services with minimal customer service impact.

Evidence of compliance with this Framework must be documented in Merchant’s

Product Pack because INFOMEDIA, as holder of the exclusive right to bill users for

merchant services, are continually required by the carriers and regulatory bodies to

ensure that due diligence has been undertaken on every service before its launch.

The Product Pack is a mechanism for INFOMEDIA to collect the necessary

information to undertake that review. INFOMEDIA may provide the Product Packs to

the carrier for their clearance as well.

INFOMEDIA will undertake quality and content reviews on every service prior to

launch to ensure compliance with this framework; furthermore INFOMEDIA shall

conduct ad-hoc monitoring of services to ensure on-going compliance in addition to

automated monitoring of key service metrics.

In addition to the requirements set out in this framework, all services must comply

with the Telecommunications Regulatory Authority Code of Practice and Consumer

Protection Regulations at all times. Please see http://www.tra.gov.ae for more

details.

This framework will refer to the TRA Code of Practice but Merchants should refer

back to the TRA site for further guidance for the running of their services.

2 CONTACT

Any merchant requiring advice or clarification should contact

[email protected] or their Account Manager at INFOMEDIA.

Any advice provided is not legal opinion as INFOMEDIA are not legal or regulatory

specialists on any matters regarding the territory.

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7 © INFOMEDIA Services Limited, All Rights Reserved 2016

3 BREACHES

If a breach of this framework or the TRA Codes is found by INFOMEDIA, the

network, or the regulator, the Merchant will be notified through a formal email from

the INFOMEDIA Compliance Team. Attached to this email will be a report detailing

the nature of the breach. Merchants are required to make corrective changes within

24 hours, reporting back to INFOMEDIA within that time to allow for internal testing.

Please note that the turnaround time applies 7 days a week.

INFOMEDIA will record any breaches noted from our automated monitoring and from

our manual compliance testing. This will be compiled into a report and included in

INFOMEDIA’s monthly review with the carrier.

The report shall detail all compliance KPI’s as well as all breaches. This will allow all

interested parties to see the trend for any specific product or Merchant.

ETISALAT action in response to deviations is as follows:

At any stage Etisalat reserve the sole right to apply an immediate penalty if the

Merchant breaches any article from this policy, otherwise:

o In the first two deviations, the Merchant will receive a memo.

o The penalty action and amount will be decided case by case.

DU action in response to deviations is as follows:

Penalty of 1000AED for first breach, 5000AED for second breach and 25000AED for

third breach. Further breaches may result in service suspension. All penalties and

suspension are at Du’s discretion.

4 SPEND LIMITS

Irrespective of the number of requests made by a user a maximum spend of 40 AED

per MSISDN must be applied to the user in any single day.

It is recommended, to mitigate bill shock, that where an end user spends 40 AED in

a 24 hour period on one service they should be blocked until the next day when

billing can recommence, and an SMS message should be sent informing them that

this limit has been hit.

If a service requires a larger spend limit than 40 AED then prior permission must be

sought in advance from INFOMEDIA who will work with the carriers to seek any

exception. INFOMEDIA cannot guarantee that an exception will be granted and the

final decisions sits solely with the carriers.

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8 © INFOMEDIA Services Limited, All Rights Reserved 2016

5 COMMENCEMENT OF A SERVICE

The following information is required before the commencement of a service and

must be included in the Product Pack:

o Merchant’s identity and CS contact details (both toll free phone number and

support email address);

o The name and description of the service, as it will be known by the end user;

o Full cost of the service in Dirham in a clear format. This must include details

on any in-life price changes e.g. promotions such as 5 AED for the first week

then AED 10 per week thereafter;

o The Merchant’s customer care or Helpline number (note: this must be free to

call and available in English and Arabic and comply with the requirements of

section 11);

o Header enrichment including end user mobile number where available is

used. However, where an end user is required to enter their mobile number

into a Mobile site in order to access either a subscription or an event-based

service, no charges should be incurred until the end user’s identity has been

verified, either by an SMS to the short-code or entry of a unique identifier into

the site (such as a PIN number sent to the user’s handset);

o Confirmation of how dates and frequency of billing will be made clear to the

end user, including details of any time lag between service initiation and the

commencement of billing for the service;

o Copies of: ➢ Landing Pages for launch complying with section 9;

➢ Full Terms and Conditions as they will appear in the service;

➢ Advertising for launch complying with section 8;

➢ Copies of Customer Support scripts including any answerphone

messages and IVR messages;

➢ Any other information or data as may be required by a carrier.

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9 © INFOMEDIA Services Limited, All Rights Reserved 2016

6 CULTURAL POLICY

6.1 TRUTHFULNESS

The service must meet the following criteria:

(i) No communication shall be deemed misleading to the consumer.

(ii) No untrue claims about the service may be made.

(iii) Footnotes and disclaimers must be visible, legible, and understandable (i.e.

not hidden below the fold).

6.2 LEGALITY

Marketing communications shall comply with the laws, heritage and the religious,

moral, cultural, and social norms of the UAE and not encourage any unlawful or

immoral behaviour.

6.3 PRIVACY

Customers shall not be tracked in any way that exposed their private information

without clear consent. Any stored information shall be stored safely, encrypted and

should not be shared with 3rd parties

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10 © INFOMEDIA Services Limited, All Rights Reserved 2016

6.4 HARM AND OFFENCE

Merchants must not include in their marketing communications or service content

any material which may cause harm or offence in the territories in which those

services are available. Material may include images, text or links.

The following lists material defined as causing harm and offence. This is not a

definitive list; please see ‘Legality’ section above.

o Material that violates any national, provincial, state or local law, court order or

industry rule or regulation.

o Material that violates the principles of Islamic Law and Principles (Islamic

Shari’ah) and/or conflict with the customs, traditions and customs of the GCC

and Arabian societies;

o Material that is harassing, defamatory, libellous, abusive, threatening,

obscene, or coercive;

o Material that violates the rights of any person or company protected by

copyright, trade secret patent or other Intellectual Property Rights or similar

laws or regulations;

o Material that Merchant’s know, or should have a reasonable basis to know, is

derived from services or sites that permit illegal peer-to-peer sharing of

copyrighted content;

o Material that disparages carriers, operators or any other service partner in any

way;

o Materials that are sexually explicit, or relate to tobacco, drugs, alcohol or

gambling;

o Material that would constitute "junk mail" or "unsolicited bulk e-mail," or other

advertising material or communications to persons or entities that have not

specifically agreed to receive such messages from DCB partner;

o Materials that include or introduce malicious programs into End Users’

equipment or the Operator network including, but not limited to: viruses,

worms, Trojan horses, e-mail bombs, cancelbots or other computer

programming routines that are intended to damage, interfere with, intercept or

expropriate any system, data or personal information, including executing any

form of network monitoring that will intercept data not expressly approved for

use.

Online and/or Mobile Advertising shall also not be placed on prohibited Websites,

Mobile Sites, and/or Applications, or Websites, Mobile Sites and/or Applications that

contain any of the above listed material.

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11 © INFOMEDIA Services Limited, All Rights Reserved 2016

7 SUBSCRIPTION SERVICES

7.1 ACTIVATING AND DEACTIVATING

SUBSCRIPTION SERVICES

Subscribers must have expressively activated the service and Merchants must be

able to show how and when this activation occurred.

Subscribers must not be deemed to have accepted a subscription simply by not

opting out of an offer, with the exception of services with a free period.

Merchants must adopt procedures to inform consumers of service:

✓ Activation

✓ Deactivation

The method of service deactivation shall be no more complicated than activation of

that service.

Exit interviews may be conducted with the end user’s permission, providing the

interview occurs after service deactivation.

Subscribers must be made aware of and consent to any service upgrade or

migration.

7.2 CONSENT TO CHARGE

INFOMEDIA has secured agreements with UAE carriers for advantageous user

acquisition flows (merchant hosting on Etisalat, alternatives to PIN flow on Du) where

the merchant flows incorporate INFOMEDIA’s Consent To Charge technology

(“C2C”).

It is mandatory for all user acquisition flows to have C2C in place.

There are two steps to evidencing consent:

1. Information: The user must have been provided with the required information to be able to reach an informed decision as to whether to subscribe to or purchase the service, as set out in the ‘Advertising and Marketing’ sections below.

2. Opt-in: The user must have taken active steps to opt-in and such evidence of this must be available by way of an audit trail.

INFOMEDIA’s C2C allows the merchant, INFOMEDIA, carrier and regulators to have

an enhanced level of certainty as to the authenticity of user acquisitions by capturing

screenshots of the actual pages seen by the user during acquisition along with meta

data such as the user agent, x-y coordinates of user clicks and user IP address.

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12 © INFOMEDIA Services Limited, All Rights Reserved 2016

• Flows on the Etisalat carrier which do not include C2C must be hosted by

INFOMEDIA.

• Flows on the du carrier which do not include C2C cannot use single click as

an authentication.

7.3 SUBSCRIPTION RENEWAL

After the initial activation of the subscription for a customer, attempts will be made to

be charge that customer again in return for subscription renewal once the initially

billed period has ended.

Each time a charge is successfully made against an Etisalat customer’s account a

charge confirmation SMS, see messages section for more details.

Rules:

1. Charges shall occur on the same day of the subscription renewal within the 24

hours.

2. Partners can give a grace period in order to gain better chances to charge a

prepaid customer. This should be the only reason to apply back-dated

charges against the customer account. A grace period shall not exceed the

Subscription duration.

7.4 FREE TRIAL PERIODS

ETISALAT – Etisalat requires that all products offer a minimum of 24 hour free trial

periods for subscription services to allow users adjustment time and minimise early

life complaints to carriers and refund requests.

DU - INFOMEDIA recommends all Merchants to offer a minimum of 24 hour free trial

periods for subscription services to allow users adjustment time and minimise early

life complaints to carriers and refund requests.

7.5 GROWTH CAPS

New merchants launching services through INFOMEDIA shall be subject to revenue-

based growth caps during the first 3-6 months of operation.

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13 © INFOMEDIA Services Limited, All Rights Reserved 2016

This is to ensure that customer service rates can be monitored and kept at a

manageable level in the early stages of the service and identify any potential

problems without causing excessive CS traffic to carriers.

Growth cap curves will be bespoke and developed with individual merchants by

INFOMEDIA’s account managers.

7.6 RETRY AND STEP CHARGING POLICIES

ETISALAT Retry Policy:

If a subscription renewal charge fails, the merchant is eligible to retry the customer

for 6 months based on the following:

Subscription period

Same price retail frequency

Step charge frequency

1st 2 months 1 time per day 2 times per day on 2 different price points

2nd 2 months 4 times per week 2 times on the same failure day on 2 different price points

3rd 2 months 2 times per week 2 times on the same failure day on different price points

Step Charging:

Price points will be calculated based on the following formula:

Subscription period

First Trial 2nd Trial

Daily services No stepped charging allowed

Weekly services Price = (service price* 50%) Period = 4 days

Price = (service price* 25%) Period = 2 days

Monthly services

Price = (service price* 50%) Period = 15 days

Price = (service price* 25%) Period = 7 days

In case the step charging was successfully applied, a notification message shall be

sent to the customers see message section for more information.

Grace Period:

Etisalat customers must be able to access their services in full for 48 hours after the

first billing attempt fails, after which the service may be restricted or deactivated.

Churn:

After the end of the trail period of a full six months without any successful charge, the

partner shall automatically unsubscribe the customer and send him/her an exit

notification message.

DU Retry Policy:

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14 © INFOMEDIA Services Limited, All Rights Reserved 2016

A user’s billing may be retried twice per billing period (e.g. daily, weekly or monthly)

per service.

Step Charging:

The second billing attempt may be for a lower amount than the first billing attempt.

There should be no attempt to recover the unpaid portion in future billing periods.

Grace Period:

A user may be suspended from accessing the service after 48 hours of unsuccessful

billing (or a longer period at the merchant’s discretion) until such time as the user is

successfully billed again.

Churn:

If a user has failed to bill for 30 consecutive days then no further billing attempts

should be made the user will be unable to access the service unless they re-

subscribe with a successful bill.

Re-subscription:

If the user re-subscribes after losing access to a service they may not (at the

merchant’s discretion) benefit from any free trial period and if the first billing attempt

of the new subscription fails they will immediately lose access to the service until

such time as a billing attempt is successful. If billing attempts on the re-subscription

fail for 30 consecutive days they may (at the merchant’s discretion) be barred from

further attempts.

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15 © INFOMEDIA Services Limited, All Rights Reserved 2016

7.7 WHITELISTING & BLACKLISTING

WHITELISTING We have an automated whitelisting process which identifies VIP MSISDNs. These

are excluded from billing however the service is still provided; consequentially these

services cannot be invoiced.

BLACKLISTING This is carried out manually at the request of the carrier. If the blacklisted user is

already subscribed before the request they will be removed before their next bill.

7.8 PULL/PUSH MODE SERVICE DELIVERY & USEAGE

Customers can be provided access to the purchased product/service by either:

1. Receiving content directly (Push-mode) Push of content should happen

between 8 am and 10 pm UAE time (GMT+4.) and if the customer has more

than one pending payment cycle on the queue, he/she will only pay for one

subscription cycle and the drop the rest.

2. Through a specific destination (Web site, App, Game, Mobile site etc.) where

they can use the product/service (Pull-mode.)

7.9 USER INACTIVITY LIMITS

ETISALAT ONLY: Customers who do not interact with or receive push content

(where this is the sole nature of the service to which the user subscribed) from any

service to which they are subscribed for a period exceeding 90 days on weekly

billing, 4.5 months on bi-weekly billing or 6 months on monthly billing shall be

automatically unsubscribed from the service.

If a user is not deactivated in accordance with the above then this shall be grounds

for a full refund for the period of inactivity exceeding the above limits.

It is recommended that Merchants agree user re-engagement strategies with

INFOMEDIA in order to mitigate the impact of this policy.

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16 © INFOMEDIA Services Limited, All Rights Reserved 2016

8 ADVERTISING & MARKETING

Advertising is where merchants use third party advertising to promote services to

end users. INFOMEDIA advise that all advertising be contextual and in appropriate

media.

Merchants will not promote their services within games, applications, mobile internet

sites or fixed line web sites that are specifically targeted at children under 16 or

where their primary market is children under 16 years of age or where surrounding

content is in breach of any item under section 6.0. Merchants must not target

towards tablets specifically on the du network.

Merchants are responsible for checking the appropriateness of the placing of all

marketing and promotional material even if and advertising network is being used.

Merchants must provide INFOMEDIA with a documented process that demonstrates

the steps they take in which they protect against any breaches of these

requirements. Merchants are required to document this process using the

Advertising Control Template in the Product Pack. We recommend that Merchants

have an advertising whitelisting process and contractual steps with their advertising

partners to add in these reassurances.

8.1 AFFILIATE MARKETING ADVICE:

Merchants that use affiliate marketers are responsible for ensuring that promotions

are compliant, regardless of whether this activity is sub-contracted, and active

monitoring must be part of the Merchants own ongoing compliance processes.

Clear expectations must be placed on affiliate marketers around compliance and

Merchants must obtain a clear commitment to this end as part of any contract

signed.

Expectations include (but are not limited to):

o Clear description of the service;

o Any marketing be directly related to the PRS offering i.e. not unrelated or

misleading;

o Affiliates must not engage in any misleading practices.

o All promotional materials and placement must meet the requirements of the

Cultural Policy (above).

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17 © INFOMEDIA Services Limited, All Rights Reserved 2016

8.2 PROHIBITED MARKETING PRACTISES

The following practices are not permitted by a Merchant or their affiliate marketer:

o Promoting products and services in a misleading manner;

o Directly targeting an audience under the age of 18;

o Using self-initiating pop-ups or pop-unders for advertising copy or landing

pages;

o Using self-clicking advertising;

o Promoting unrelated content based on popular search terms among natural

search results;

o Redirecting users to unrelated third party websites to promote unrelated

content;

o Hijacking or automating clicks to redirect users to unrelated third party

websites to promote unrelated content;

o Automating clicks or otherwise promoting false positive inputs on any Call to

Action that leads to the end user being signed up to a service;

o Posting false URL links on social networking websites to mislead users;

o Misleading users into liking webpages they did not intend to like;

o Inserting malicious code within advertisements;

o Sending deceptive email spam;

o Entice users to non-existent content via social network ‘liking’;

o Sending advertisements that might be perceived as official notifications;

o Misleading users into completing PRS offers to unlock content;

o Use of Malicious Software or Trojans to lock users’ internet browsers until

payment is made or subscriptions joined in order to unlock browsers.

It is strongly recommended that Merchants read section 16 of the UAE

Telecommunications Regulatory Authority Consumer Protection Regulations

‘Marketing Communications and Practices’.

It is recommended that Merchants analyse their traffic on an ongoing basis,

responding to any abnormal activity and gaining an understanding of how consumers

arrive at a promotion, and monitor and audit their affiliate marketing periodically

regardless of activity to ensure that is both effective and compliant. INFOMEDIA may

request evidence of these activities as part of our ongoing compliance checks.

For the avoidance of doubt, Merchants must, on request by INFOMEDIA, be able to

provide full details of all advertising including copies of all adverts together with

URLs and advertising flows/logs to show how any individual end user has signed up

to a service.

8.3 NON-EXPLOITATION OF CUSTOMERS

Marketing communications shall not exploit lack of knowledge or understanding by

Consumers, nor take advantage of any vulnerable groups or individuals.

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8.4 CARRIER LOGOS

Carrier logos, names and/or any branding items shall not be used without prior

consent.

8.5 ADVERTISING BANNERS

All PRS promotions must be as accurate as possible and must not mislead or breach

any of the requirements of ‘Prohibited Marketing Practices’ above.

Advertising banners must:

o Include the name of the service, or a clear description for it;

o Be directly related to the service being advertised and the creative on the

landing page;

o ETISALAT ONLY: Display the pricing, frequency and free period

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9 USER ACQUISITION FLOWS

User Acquisition flows are split below between the two UAE mobile network

operators, Du and Etisalat.

On the Du network subscription is only permitted from within a native application

downloaded by the user. Exceptions may exist on a case by case basis only, for

further advice please speak to your Account Manager.

Please also see the ‘UAE Flow Guidance’ documentation.

9.1 ETISALAT

Etisalat only permits one flow type; SMS PIN flow.

9.1.1 SMS PIN FLOW OVERVIEW

1. User clicks on an advertisement

2. User is taken to Landing Page (1st Page)

3. User enters MSISDN (or MSISDN is detected via HE) and clicks PIN Request

button

4. User is sent PIN

5. User is taken to the Pin Entry Page (2nd Page)

6. User enters PIN and clicks CTA

7. User is subscribed

8. User is sent Welcome Message

9.1.2 SMS PIN FLOW DETAILS

TEXT

o In addition to specific rules for specific page sections below, all text elements,

including text in images, must be minimum of font size 9pt (12px), clear and

legible to the average reader and in a colour clearly contrasting to the

background.

LANGUAGE

o All pages must be available in English and Arabic

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o A button to switch between language must be clearly visible on the pages.

o The language buttons should contain text of the language to which the button

switches and not just be flags.

SERVICE DETAILS & PRICE

o The product name must appear clearly on the pages.

o The price, billing frequency and free period must appear directly above, below

or on the CTA.

o The price, billing frequency and free period must appear at the top of the

page.

o Service details must be the following prescribed text and in bullet points as

below:

o All of the above Service Details must be visible on the page upon load and

without scrolling.

MSISDN / PIN ENTRY BOX

o There shall be a box on the page for the user to enter their MSISDN, clearly

labelled as such (if not detected by header enrichment).

o Once the user has clicked the PIN Request button this box may become the

PIN Entry box.

BACK/HOME/EXIT BUTTON ACTION

o If the user presses their handset’s ‘BACK’ or ‘HOME’ button they cannot just

be directed to another subscription landing page and trap the user in the

subscription flow; user must be directed to their homepage or a neutral site

such as Google.

o An ‘Exit’ button must appear below the CTA. It must be labelled ‘Exit’ and not

Terms and Conditions:

By clicking on the above subscribe button, you will agree on the below

terms and conditions:

• You will start the paid subscription after the free period

automatically

• No commitment, you can cancel your subscription at any time by

sending [STOP keyword] to [shortcode]

• To get support, please contact [email] or [telephone]

• The free trial is valid only for new subscribers

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‘Cancel’, ‘Close’ or (X).

PIN REQUEST BUTTON (1st Page)

o Shall be clearly labelled “Subscribe via PIN Code”.

o The button and text within must be legible, unobstructed, visible and static at

all times. A minimal amount of animation is permitted on the button, for

example a slowly flashing arrow.

o The PIN Request button may become the Call To Action button on the 2nd

Page.

CALL TO ACTION BUTTON (2nd Page)

o Shall contain the word “SUBSCRIBE” of “SUBSCRIPTION”. If a merchant

wishes to use another word or phrase this must be approved by the Etisalat.

INFOMEDIA recommends using ‘Subscribe’ to avoid delays in service launch.

o The button and text within must be legible, unobstructed, visible and static at

all times. A minimal amount of animation is permitted on the button, for

example a slowly flashing arrow.

MSISDN DISPLAY

o The user’s MSISDN should be displayed on the 2nd Page

2ND PAGE LIGHTBOX

o Merchants may, instead of simply changing the buttons and data entry box on

the 2nd Page, use a lightbox (or ‘pop-up’) over the 1st Page.

o The lightbox should contain:

o User’s MSISDN

o Service name

o Price, billing frequency and any trial period

o PIN Entry box

o CTA button

o ‘Exit’ button (if used in a lightbox this button may return the user to the

1st Page rather than exiting the flow)

TERMS & PRIVACY POLICY

o There shall be links to the Terms and Conditions and a Privacy Policy; both

are mandatory. The Terms and Conditions and Privacy Policy must be

available from within the service after subscribing.

ANIMATION

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o Limited animation is permitted so long as it is not distracting from, obstructing

or obscuring the required information set out above.

COUNTDOWN TIMER

o No countdown timer or similar function or language creating an undue sense

of urgency should be used to rush customers’ decision to subscribe.

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9.2 DU

Du permits three flow types; SMS PIN flow (Wifi or 3G/4G), MSISDN confirmation

flow (3G/4G only) and On-Screen PIN Flow (3G/4G only)

9.2.1 SMS PIN FLOW OVERVIEW

o Available for Wifi or 3G/4G

1. User clicks on an advertisement

2. User is taken to Landing Page (1st Page)

3. User enters MSISDN (or MSISDN is detected via HE) and clicks PIN Request

button

4. User is sent PIN

5. User is taken to the Pin Entry Page (2nd Page)

6. User enters PIN and clicks CTA

7. User is subscribed

8. User is sent Welcome Message

9.2.2 MSISDN CONFIRMATION FLOW OVERVIEW

o Available for 3G/4G only

1. User clicks on an advertisement

2. User is taken to Landing Page (1st Page)

3. User clicks ‘Subscribe’ CTA

4. User is taken to MSISDN Confirmation Page (2nd Page)

5. User enters the last three digits of their MSISDN and clicks ‘Confirm’

6. MSISDN entry is verified against MSISDN detected via HE

7. Upon correct MSISDN verification user is subscribed

8. User is sent Welcome Message

o Steps 3 – 6 may be reversed in terms of page order, i.e. the user enters their

MSISDN on the 1st Page and clicks the ‘Subscribe’ button on the second

page.

9.2.3 ON-SCREEN PIN FLOW OVERVIEW

o Available for 3G/4G only

1. User clicks on an advertisement

2. User is taken to Landing Page (1st Page)

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3. User clicks ‘Subscribe’ CTA

4. User is taken to PIN Entry page (2nd Page)

5. User PIN is displayed on page

6. User enters PIN into PIN Entry Box

7. User clicks ‘Confirm’

8. User is subscribed

9. User is sent Welcome Message

9.2.4 FLOW DETAILS – ALL FLOWS

TEXT:

o In addition to specific rules for specific page sections below, all text elements,

including text in images, must be minimum of font size 9pt (12px), clear and

legible to the average reader and in a colour clearly contrasting to the

background.

LANGUAGE

o All pages must be available in English and Arabic

o A button to switch between language must be clearly visible on the pages.

o The language buttons should contain text of the language to which the button

switches and not just be flags.

SERVICE DETAILS & PRICE

o The product name must appear clearly on the pages.

o The price, billing frequency and free period must appear directly above, below

or on the CTA.

o Service details shall contain the following information:

▪ Product name

▪ Product description

▪ Price, billing frequency and any free period

▪ Statement that renewal will be automatic until unsubscription

▪ Statement of acceptance of Terms and Conditions

▪ How to unsubscribe

▪ Customer service details

▪ Example:

[product name] is a games service costing AED 2/day, automatically

renewed daily until you unsubscribe. By clicking on ‘Subscribe’ you

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agree to the Terms and Conditions. To unsubscribe send STOP

[keyword] to [shortcode]. Help? Call [number]

o All of the above Service Details must be visible on the page upon load and

without scrolling.

BACK/HOME/EXIT BUTTON ACTION

o If the user presses their handset’s ‘BACK’ or ‘HOME’ button they cannot just

be directed to another subscription landing page and trap the user in the

subscription flow; user must be directed to their homepage or a neutral site

such as Google.

o An ‘Exit’ button must appear below the CTA. It must be labelled ‘Exit’ and not

‘Cancel’, ‘Close’ or (X).

PIN REQUEST BUTTON (1st Page)

o Shall be clearly labelled to inform the user they will be sent a PIN message.

o The button and text within must be legible, unobstructed, visible and static at

all times. A minimal amount of animation is permitted on the button, for

example a slowly flashing arrow.

o The PIN Request button may become the Call To Action button on the 2nd

Page.

SUBSCRIBE/CONFIRM BUTTON

o The ‘Subscribe’ Button, as referred to in the Flow Overviews, shall contain the

word “SUBSCRIBE” or similar wording which clearly and unambiguously

informs the user that they are entering into an obligation to pay.

o The ‘Confirm’ Button, as referred to in the Flow Overviews, shall contain

wording which clearly and unambiguously links the user to the action of

confirming data entered on the page.

o The button and text within must be legible, unobstructed, visible and static at

all times. A minimal amount of animation is permitted on the button, for

example a slowly flashing arrow.

2ND PAGE LIGHTBOX

o Merchants may use a lightbox (or ‘pop-up’) over the 1st Page instead of a 2nd

Page.

o The lightbox should contain:

o Service name

o Price, billing frequency and any trial period

o Relevant Data Entry box

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o Relevant CTA button

o ‘Exit’ button (if used in a lightbox this button may return the user to the

1st Page rather than exiting the flow)

TERMS & PRIVACY POLICY

o There shall be links to the Terms and Conditions and a Privacy Policy; both

are mandatory. The Terms and Conditions and Privacy Policy must be

available from within the service after subscribing.

ANIMATION

o Limited animation is permitted so long as it is not distracting from, obstructing

or obscuring the required information set out above.

COUNTDOWN TIMER

o No countdown timer or similar function or language creating an undue sense

of urgency should be used to rush customers’ decision to subscribe.

9.3 SUCCESS PAGE

A success page is mandatory on ETISALAT and recommended on DU

Upon completing the flow successfully the user must be redirected to a success

page. This page must contain:

o Confirmation of successful subscription;

o A confirmatory SMS has been sent;

o Link to access service (if the customer does not click the link they should be

automatically redirected to the service after no less than 10 seconds). o Information on how to unsubscribe, INFOMEDIA recommends displaying a

link to be able to unsubscribe and information about how to text to

unsubscribe

o INFOMEDIA recommends displaying the terms & conditions and privacy

policy links again too, at the bottom of the page

Product/service activation for the customer should happen immediately and the

customer should be able to benefit from the product/service immediately. The

merchant should not save the customer request to try again at a later time.

If the subscription fails users should be shown a failure page which informs them that

their subscription has been unsuccessful. It should include a links to return to the

landing page or close the page.

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9.4 TERMS AND CONDITIONS FOR SUBSCRIPTION

SERVICES

The Terms linked to from the landing page must clearly state the user is entering into

a recurring subscription service. There needs to be clear guidance on the cost of the

service and how the user can unsubscribe from the service. The below format must

be followed.

The terms and conditions for ETISALAT services can only state Etisalat’s opt out

information.

TERMS AND CONDITIONS FORMAT:

This is a [type of service e.g. games/apps/sports/music] subscription service. [Details

of any free period]. [After the free period,] you will be charged [AEDXX] every [billing

frequency] to you mobile phone bill and your subscription will be renewed

automatically. You can unsubscribe from the service by sending STOP [keyword(s)

to short-codes for the different operators] or by visiting here: [clickable hyperlink].

Operator charges may apply as per your plan. By signing up for and/or using the

service you acknowledge and confirm that you have read the Terms & Conditions

[Terms & Conditions must be a hyperlink that take the user to a page with the full

Terms of the service] and Privacy Policy [Privacy Policy must be a hyperlink that

take the user to a page with the full Privacy Policy of the service], that you are a

resident of the United Arab Emirates, you are 18 years or older and are the mobile

account holder or you have consent from the mobile account holder. Help desk [FAQ

page/email address] or call [customer support phone number]

EXAMPLE DU:

This is a games subscription service. The first 24hrs are free, after the free period

you will be charged AED10 every week to your mobile phone bill and your

subscription will be renewed automatically. You can unsubscribe from the service by

sending Stop GHUB to 8823 if you are on the du mobile network or by clicking here.

By signing up for and/or using the service you acknowledge and confirm that you

have read the Terms & Conditions and Privacy Policy, that you are a resident of the

United Arab Emirates, you are 18 years or older and are the authorised mobile

account holder or that you have the consent of the mobile account holder. To stop

receiving marketing info opt out via this page. Help desk: email

[email protected] or call 8000-3570-4437.

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EXAMPLE ETISALAT:

This is a games subscription service. The first 24hrs are free, after the free period

you will be charged AED10 every week to your mobile phone bill and your

subscription will be renewed automatically. You can unsubscribe from the service by

sending Stop GHUB to 1156 if you are on the Etisalat mobile network or by clicking

here. By signing up for and/or using the service you acknowledge and confirm that

you have read the Terms & Conditions and Privacy Policy, that you are a resident of

the United Arab Emirates, you are 18 years or older and are the authorised mobile

account holder or that you have the consent of the mobile account holder. To stop

receiving marketing info opt out via this page. Help desk: email

[email protected] or call 8000-3570-4437.

ETISALAT ONLY: TERMS AND CONDITIONS PAGE - FAQ’s:

Within the Terms & Conditions section a FAQ must be included for customer care for

the service provided. As a minimum this must contain:

o Full details of the subscription service and details of what is provided within

the service;

o Price;

o Charging frequency;

o Details on how you subscribe and unsubscribe;

o How to obtain help for the service.

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10 CUSTOMER MESSAGING

During a user’s time in a service they will be sent an SMS confirming or providing them with the agreed information as detailed in the below sections. All SMS’s sent must be in the same language as the language the user opted to use to view the Landing Page originally, for example, if the user opts to view the Landing Page in Arabic all SMS’s sent to them must be in Arabic.

All SMS to users for these services will run through the INFOMEDIA SMS platform.

This will allow INFOMEDIA to set up automated monitoring for welcome, reminder,

exit and marketing messages.

In every communication with the end user the relevant Merchants Customer

Support details will be indicated.

INFOMEDIA will set up alarms against each merchant and service/product for the

above types and requirement to send these messages and then will work with the

Merchants if these alarms are triggered.

The alarms that will be created, include but are not limited to; ensuring any

welcome messages are being sent by checking against new billing events for the

same MSISDN and merchant product, that once an exit message goes out no

further billing events occur without the presence of another welcome SMS for that

MSISDN.

Alarms will be based on a daily failure percentage going below an agreed rate for

each of the KPI’s that are created. Merchants will be sent any deviation data so

that they can address any issues on their products.

No marketing SMS’s to be sent between the hours of 9.00pm and 9.00am

UAE time, and shall exclude official off days and public holidays.

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10.1 PIN MESSAGE

On the WIFI flow the PIN message shall contain:

o The product/service name;

o PIN (minimum 4 digits)

Etisalat Additional Message Requirements

o State customer mobile number

o State ‘If you did not request this service pls ignore this message’

o State ‘No charges have been applied yet’

INFOMEDIA strongly recommends placing the PIN as near to the start of the

message as possible to allow it to appear in users’ message preview bars, for

example: “Enter PIN 1234 to confirm your subscription to…”

10.2 WELCOME MESSAGE

A subscription confirmation SMS must be sent as soon as a user joins a service,

even if there is an initial free period for the service. The message must contain:

o Indication of successful transaction;

o The product/service name;

o Price and frequency;

o Trial period (if applicable);

o Date of first charge (if on a free trial);

o How to access the service;

o How to stop the service;

o Support details (email, and or local rate number)

Etisalat Additional Message Requirements

o Include a URL for the full service terms and conditions

10.3 SUBSCRIPTION RENEWAL MESSAGE

ETISALAT ONLY - Each time a charge is successfully made against an end user’s

account for the renewal of a subscription, an SMS confirmation must be sent

(however for daily subscriptions this can be sent every 3 days). This SMS should

include:

o Indication of successful transaction;

o Service name;

o Price and frequency;

o How to access the service;

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o Date of next renewal

o Support details.

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10.4 EXITING A SERVICE

Users must be able to stop their subscription using the details provided in the

welcome and subscription renewal messages. Other mechanisms should also be

made available to the user such as contacting customer services or by visiting an

online portal linked to the product/service.

The ‘STOP’ commands recognised must include the use of the Arabic word “ فق ” If a user sends only the keyword ‘STOP’ to a short-code that has multiple

services associated with that short-code, then this will be treated as a ‘STOP

ALL’ request against the short-code.

There will also be a master un-subscription option where the customer will be

able to send any of the following commands to cancel their subscription:

o Unsub

o STOP

o STOP ALL

o END

o DEACT

o ST

o NOMORE

o CLOSE

o FINISH

o Deactivate

o Unsubscribe

These will not be case sensitive. A subscription exit SMS must be sent after a user unsubscribes from a service

whichever method is used (e.g. by sending ‘stop’, by calling customer services, or

by using the portal). No further billing should take place after the user requests to

stop, unless they subscribe to the service again. The messages must contain:

• A clear indication that the deactivation is successful

• The product/service name

• Cut-off date of access

• Support details

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10.5 INCORRECT UNSUBSCRIPTION REQUEST

MESSAGES

When customers send cancellation request messages (identified by any MO with the

keyword STOP in the text) in the wrong format e.g. they text STOP GHUV instead of

STOP GHUB the Merchant must respond with an SMS with information to help them

unsubscribe correctly which must include the product name and all the different

unsubscription options:

• STOP command with correct keyword(s)

• CS email address

• Statement that unsubscription can be from in the service portal

10.6 SPEND LIMIT MESSAGES

Where an end user spends 40 AED in a 24 hour period on one service they should

be blocked from that service until the next day when billing can recommence, and an

SMS message should be sent informing them of this.

See section on Spend Limits for more information

10.7 STEP CHARGING MESSAGE

For Etisalat customers only. If step charging is successfully applied, a notification

message shall be sent to the customers with the following info:

• Product service/name

• Reduced price and the reduced period

• How to cancel the product/service using and SMS command

10.8 USER INACTIVITY MESSAGE

ETISALAT ONLY

If an end-user has not been active on a service for a certain period of time their

subscription should be deactivated and they should be sent an exit message (see

‘User Inactivity’ section for more information).

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10.9 MARKETING MESSAGES

The Merchant must have a legitimate basis to target an end user directly with SMS

advertising and be able, when requested, to provide proof of customer consent.

NOTE: Spam is illegal in the UAE.

The Merchant should not use a different short-code to send these messages from

those used for existing services.

An end user must be able to opt out of marketing messages at any time. An end user

who has opted out of receiving marketing messages must not receive further

messages.

Marketing messages must only be sent to end users subject to the following

condition:

o The end user has provided informed explicit consent to receive marketing at

the point of opt-in services and has not opted out of receiving such marketing

material.

The exception to this rule is ‘soft opt-in’. ‘Soft opt-in’ applies where:

o The end user’s details are obtained during a sale, or during the negotiation of

the sale with that person;

o The messages are marketing similar products or services;

o The end user is given an opportunity to refuse the marketing when their

details are collected and, if they do not opt out they must be given a simple

way to do so in every message received thereafter.

Best practice is for the end user to be able to reply to the message to opt out. If this

is not possible due to the way in which the message has been delivered to the end

user, it must be explicit in the message how the end user can opt out by sending

STOP to a short-code.

Marketing messages must be free to receive and must clearly be marked as such

with the prefix ‘FreeMsg’.

An end user must be charged no more than their standard rate for sending a

message to opt-out of receiving marketing messages. Web URLs and/or premium

rate numbers are not acceptable means for the end user to opt-out.

The same customer must not be contacted more than once a week by the same

Merchant.

The message body should be clear and concise. It should contain the Service Name, Price and Billing Frequency including any free trial period.

NOTE: Marketing messages must not be sent between 9.00pm and 9.00am

UAE time.

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11 CUSTOMER SUPPORT

The following section details the requirements of customer support

11.1 CUSTOMER CARE

The carriers expect the Merchants to take primary responsibility for all Customer

Support activities on the services. Customer Support messaging and support should

be set up to make this clear to users.

LANGUAGE

All support must be available in both English and Arabic.

EMAIL

There must be 24/7 customer support options available through email.

Direct email must always be available and publicised to the customer in the service

terms and the user acquisition flows.

Merchants may additionally offer service portals (embedded email or messaging

functionality within service of web pages).

Where an end-user contacts the Merchant by email or service portal an automated

receipt of the request must be sent. This should include a timeline for a full

response.

TELEPHONE

It is recommended that Merchants provide a consumer care telephone line for any

person to make enquiries or complaints about a purchase.

Any telephone support line must be a toll-free number and available from 9am to

5pm Sunday to Thursday, with voicemail support outside of those hours (all

messages to be returned within 1 working day).

INFOMEDIA reserves the right to mandate that a merchant provides support via a

telephone number in addition to email where a carrier deems that customer

complaints or query rates are unacceptably high.

CS SCRIPTS/ IVR’s

It’s recommended that scripts used on customer calls use a friendly tone of voice

and are in the local language and use a local accent

MERCHANTS COMPLAINTS HANDLING PROCESS

Where complaints are referred to the Merchant by INFOMEDIA, a regulator or the

carrier, either as a result of a call/email from an end user, a referral from the

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regulator, or as a result of monitoring and testing, it is the Merchant’s responsibility

to ensure this is logged and an automated response sent immediately. As a

minimum this must contain acknowledgement of receiving the complaint and a

timeframe for the subsequent full and detailed response.

CARRIERS COMPLAINTS HANDLING PROCESS

Customers contacting the carrier’s customer support will be referred to the relevant

Merchant’s customer support email address or telephone number. Where

customers directly contact INFOMEDIA, INFOMEDIA will escalate it to the relevant

Merchant through CS Lite.

Where a customer query has been escalated by INFOMEDIA or the carrier, the

Merchant will receive an email containing the customer’s MSISDN, the service they

are querying, their contact email address, and the reason the Customer Support

agent is escalating their query.

The Merchant must respond directly to the provided customer email address with a

resolution within 24 hours of receiving the request. A confirmation receipt must also

be sent to INFOMEDIA in order to track the progress of the query, once the query

has been processed. Please note that the format of the email from INFOMEDIA

may change from time to time.

CS REPORTING ON ETISALAT

Etisalat may from time to time request ‘Support Reports’. These must contain::

1. MSISDN

2. Mobile device type

3. IP address

4. Dates/times of user interacting with product/service

5. Details of specific content accessed on product/service

6. Acquisition method and from where (e.g. banner within x website)?

7. Total charges

8. Customer received confirmation/renewal messages

INFOMEDIA shall generate the reports including the elements required however

Merchants must support INFOMEDIA with the details for (4) and (5) within the

required timeframe and have in place the relevant support.

RESPONSE TIMEFRAMES

• Etisalat Support Report detail requests should be responded to on the same

day as the request (as managed by INFOMEDIA, this will be Monday to

Friday) and in any event within 1 working day of the original request to

Infomedia.

• Deactivation and Refund requests should be executed within 1 working day.

• Service/Product Issues should be executed within 2 working days from the

time the issue is reported.

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11.2 CUSTOMER SUPPORT KEY PERFORMANCE

INDICATOR

Where possible INFOMEDIA will monitor customer reaction to merchants’ products

by use of the following CS KPI:

Of the customers that experienced the product in the last 8 weeks, what percentage

of those end users made a query into CS?

The calculation is:

𝑇𝑜𝑡𝑎𝑙 𝑈𝑛𝑖𝑞𝑢𝑒 𝐶𝑎𝑙𝑙𝑒𝑟𝑠

𝑃𝑟𝑜𝑝𝑒𝑛𝑠𝑖𝑡𝑦 𝑇𝑜 𝐶𝑎𝑙𝑙 𝑈𝑛𝑖𝑞𝑢𝑒 𝑈𝑠𝑒𝑟𝑠= 𝑥%

o Total Unique Callers – the number of views of a merchant product in the CS

database. This indicates that a CS agent has reviewed that product and

MSISDN as part of a CS Call.

o PTC Unique Users – total number of unique users attempted to bill 8 weeks

before the end date of the selected report period.

This KPI gives context to the CS call volume relative to the size of the users on a

service and not a call volume alone. This is a requirement encouraged by

INFOMEDIA and its business partners to give context to the level of calls and a

metric that they understand.

The KPI is calculated on a weekly and monthly basis. Initially the KPI shall be set at

2% per week (for indicator purposes) and 5% per month, however this may change

and merchants will be notified of their individual KPIs directly.

The weekly reports provide ongoing indications of performance to highlight any

emerging risk trends (allowing for remedial activity), however due to the nature of the

sample periods for weekly reporting do not provide a precise result.

The monthly report is the final outcome by which merchants’ performance will be

measured.

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11.3 REFUNDS

REFUND SITUTATIONS

An end-user always has the right to request a refund and refunds must be given in

AED however can be by way of PayPal, Western Union or a similarly reputable

money transfer service. In the following circumstances a refund must always be

given:

o The end-user was over-charged, charged back-dated, or charged before the

renewal date of their subscription;

o The service was not working or never provided;

o The end-user was charged for a subscription service after they initiated a stop

request;

o The end-user was charged after complaining a service did not work;

o The end-user was charged after the maximum time period for user inactivity.

o The end-user stating they are unhappy with the service, don't know how they

subscribed

o A TRA complaint

Note: customers who contact CS requesting to unsubscribe only/ unsubscribe and

require more information on the service should not be automatically offered a refund,

unless the operator requests otherwise.

If a merchant also offers a refund where the user not satisfied with the content, the

merchant must ensure that their CS script clearly informs those users that the user

had subscribed to the service and that the refund is pursuant to the ‘unsatisfied’ term

of the contract. Merchants shall provide a copy of their refund policy to INFOMEDIA.

ADMINISTERING A REFUND

All refund transactions should include the same Content Name as indicated in the

original charge transaction and be given in AED. The customer should receive an

SMS of the refund details, including:

o Refund amount;

o Service name related to the refund;

o Support details.

REFUND REPORT

It is a requirement that a report is provided on the first of every month of all refunds

issued to Etisalat customers be sent to Etisalat. Merchants must provide this

information to INFOMEDIA in the below format:

Date/Time TransactionID MSISDN Content Name

Original Charge

Refund Amount

Reason

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11.4 UNSUBSCRIPTION FUNCTIONALITY

STOP COMMANDS

Merchants shall support the SMS STOP command function. Merchants shall supply

a keyword for STOP commands (e.g. STOP GHUB).

An end user must be charged no more than their standard rate (including VAT) for

sending a message to opt-out.

Upon receipt of a "STOP" command, the service operating on that short-code

should be terminated with immediate effect and no further billable messages related

to that service should be sent to the end user, unless they subscribe to the service

again.

REGOGNISED STOP COMMANDS

o FORMAT – The following stop commands must be recognized and processed:

o Mixtures of lower and upper case letters, as they should not be case sensitive;

o Followed by a full stop; o Followed by a space; o Followed by no further character; o ‘STOP’; o ‘STOP ALL’; o ‘STOP followed by [keyword]’.

SPECIFING WHICH SERVICE NEEDS TO BE UNSUBSCRIBED

o MULTIPLE SERVICE ON ONE SHORTCODE - If a user sends only the keyword ‘STOP’ to a short-code that has multiple services associated with that short-code, then the last service the user was contacted from that contained that short-code should be stopped.

o STOP ALL - Where “STOP ALL” is sent, all services in operation using a shared short-code must cease.

AMBIGUOUS STOP COMMANDS

o If a message has been received which is identified as a stop command but is ambiguous then the user can be sent the INCORRECT UNSUBSCRIPTION message (see ‘Customer Messaging’ above) to clarify their request before a service is stopped.

CS LITE

Merchants who run their own subscription engines must provide INFOMEDIA with

an unsubscribe function for the customer support tool CS Lite. To do this

INFOMEDIA require a URL which we will submit unsubscribe instructions to. To

ensure that we can capture all successful unsubscription actions, the Merchants

application will need to unsubscribe the user in real time and respond with an HTTP

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200 OK status. If any other status is received INFOMEDIA’s system will assume

that the user has not been unsubscribed and the customer will be referred to the

Merchant. We have put together a format for the URL below:

https://www.example.com/?msisdn={MSISDN}&bpid={BPID}

The Merchant must provide an HTTPS URL in the above format so we can

configure this in CS Lite for the Merchants services.

SELF HELP SITE

To limit online exposure to negative publicity all merchants shall offer a ‘Self-Help’

portal enabling a further un-subscription mechanism for consumers, which will be

online and accessible through Google search terms for the product and/or

merchant. An unsubscribe option or link should also appear reasonably prominently

on product or merchant main pages, where such pages exist and in text which is

clear and easily legible to the average reader.

INFOMEDIA recommends that Google search ranking management is used to

ensure that the portal shall appear first or second place (where first place is the

product or service main page) in such searches.

This will help ensure that dissatisfied customers’ primary online contact is with the

merchant who is best placed to assist.

Any unsubcription site or service must be clear and unambiguous in how a user can

unsubscribe.

EXAMPLES

Do not use:

1. Reversed Yes/No: ‘Are you sure you want to unsubscribe? Yes / No’; then

‘Do you want to stay with the service? Yes / No’

2. Double Negative: ‘Do you not want to unsubscribe? Yes / No’

3. Ambiguity: ‘Are you sure you want to unsubscribe? You will miss out on all

the fun – Yes / No’

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12 DATA

CUSTOMER CARE DATA

The Merchant must send data to INFOMEDIA on their customer support on a weekly

basis by COP Monday. This data should be based on the Monday to Sunday that

has just occurred i.e. the data will be shared 24 hours after the week the data is

related to has ended.

This should detail the following for each customer care interaction:

• MSISDN;

• INFOMEDIA BPID;

• Service/ product name;

• Date and time of call;

• Call duration (optional);

• Care interaction type (call, email, web form, letter, fax, other);

• Reason for call;

• Call outcome (e.g. information of service, stop, stop and refund, refund only,

etc.);

• Call closed (yes, no);

• Source of this call (direct from the customer, referral from the network, referral

from INFOMEDIA, a request from the regulator);

• Users unsubscribed as a result of inactivity.

STORAGE

All:

• Calls,

• Emails,

• Conversations

• Messages,

• Accessed IP’s

• User agent profiles

• Visited pages

• Advertisements

Shall be stored for a full year. In a new full page, original layer on top of the same

page.

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ENGAGEMENT DATA

The Merchant must hold and be able to send data on their customer engagement at

the request of INFOMEDIA. INFOMEDIA may provide a template and/or API to

specify the data they require as part of this. An example of some of the information

that would be requested for the MSISDN is below:

• Banner click, URL, date and time (destination and screenshot if possible)

• Landing page URL, date and time (destination and screenshot if possible)

• Time clicked call to action

• User engagement with service (Duration of session, T&Cs accessed, FAQs

accessed)

• Message logs (Description of the messages sent to customer, type, delivery

status, cost)

AFFLIATE NETWORK DATA

The Merchant must hold and be able to send data on their affiliate networks at the

request of INFOMEDIA. INFOMEDIA may provide a template and/or API to specify

the data they require as part of this. An example of some of the information that

would be requested for the MSISDN is below:

o Number of calls v acquisitions per affiliate