Regulator and Mobile Operator Requirements for DCB

VIOLENCE

• Presentation of violence or the results of violence must not be excessive, gratuitous, humiliating or instructional.
• Presentation of sexual violence is prohibited.
• Appropriate warnings must be given before content containing violence is presented, including reasonable steps being taken to prevent children accessing content containing inappropriate violent material.
• Violence must not appear in advertising material nor in services targeted at users under the age of 18.

SEXUAL CONTENT

• Nudity, pornographic or sexually explicit content is not permitted
• Sexual content must not be presented in advertising or services accessible to children.
• Services should not be advertised on adult (e.g. pornographic) sites or apps.

OTHER PROHIBITED CONTENT

• Content which incites, promotes, or encourages crime or hatred.
• Offensive language, including:
• Disparaging or abusive words calculated to offend an individual or group of persons;
• Obscenity and foul language;
• Hate speech against a person or group or people based on race, ethnicity, religion, nationality, gender, sexual orientation or disability;
• Graphic descriptions of violence and/or sexual acts.
• Biased portrayals based on gender;
• Portrayal of the consumption of controlled substances (e.g. tobacco, alcohol, drugs) or any other products for which advertising is prohibited.
• Material that is harassing, defamatory, libellous, abusive, threatening, obscene, or coercive;
• 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;
• 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;
• Unlawful (i.e. without consent) gathering, processing, distributing or use of personal data

COMPETITIONS AND PORNOGRAPHY

• Pornographic, gambling and prize competition services may not be operated on the INFOMEDIA platform.
• Competitions within services may be permitted where the competition is directly linked to an existing established brand or media, such as television show link-ups. This will be considered by INFOMEDIA on a case by case basis and is no guarantee a service will be accepted.

ADDITIONAL MENA TERRITORY RULES

The following material is prohibited in MENA Territories:

• Material that violates the principles of Islamic Law and Principles (Islamic Shari’a) and/or conflict with the customs, traditions and customs of the GCC and Arabian societies, are sexually explicit or suggestive, nudes, underwear or bikini, or show uncovered portions of female bodies except hands.
• Material that relates to tobacco, recreational drugs, alcohol,
• Material that relates to horoscopes, tarot or similar.

The following practices are not permitted by merchants in advertising, checkout flow or service content:

• Promoting products and services in a misleading manner including use of ‘Download’ text and imagery not accompanied by clear description or portrayal of actual product and product name;
• Failing to clearly state the service name and price on checkout flow pages;
• Promoting unrelated content based on popular search terms among natural search results;
• Redirecting users to unrelated third party websites to promote unrelated content;
• Hijacking clicks to redirect users to unrelated third party websites to promote unrelated content;
• Misleading users into liking webpages they did not intend to like;
• Inserting malicious code within advertisements;
• Click training, i-framing or similar methods which may cause a customer to click a CTA button unintentionally
• Posting false URL links on social networking websites to mislead users;
• Sending deceptive email or SMS spam;
• Entice users to non-existent content via social network ‘liking’;
• Sending advertisements that might be perceived as official notifications;
• Using misleading advertisements, including banners, pop-ups, and pop-unders;
• Misleading users into completing PRS offers to unlock content;
• Use of Malicious Software or Trojans to lock users’ internet browsers until payment is made or subscriptions joined in order to unlock browsers.
• Taking unfair advantage of any vulnerable customer or group of customers
• Targeting advertising at children (under the age of 18)
• Stating opinion as facts
• Failing to state the identity, current status and relevant professional qualifications of any person or entity dispensing advice (where a user may have a reasonable expectation that such advice would only come from a professional person e.g. medical advice, financial advice etc.…)
• Be unable to supply evidence to substantiate claims made in advertising

Additionally, targeting or failing to exclude advertising directed at the users of tablet devices unable to receive SMS messages in their default state (including but not limited to iPads) is prohibited without express permission from Infomedia. Any tablet users who are subscribed via a device incapable (in its standard form) of receiving operational messaging will be automatically entitled to a full refund regardless of service usage.

Merchants are required to document their advertising control processes and may be required to provide this documentation to Infomedia on request in case of a regulatory or carrier audit or request.

Advertising Sources: Affiliate marketing networks, where individuals promote services for third-party companies in exchange for commissions, must not be used without explicit consent on a case by case basis. All service advertising must be via direct media buying from Google, Social Media services or similar direct owners of inventory.

Calls To Action: It must be shown that customers have made purchasing decisions with fully informed consent. CTA buttons must therefore be unambiguously labelled to indicate that the customer is entering into an obligation to make payment, typically  ‘Subscribe’>’Confirm’ or ‘Buy’>’Confirm’. ‘Request PIN’>’Subscribe’/’Buy’ also acceptable. Any other wording must be approved by Infomedia before use.

Price Display: All adverts must display the price and billing frequency of a service together with the unsubscription instructions (e.g. send STOP SERVICE to 1234 to cancel)

Advertising Sources: Affiliate marketing networks must not be used in any circumstances in Singapore, all service advertising must be via direct media buying where the merchant or their directly contracted party is in full control of all aspects of the advertising process.

Price Display: All adverts for subscription services that lead directly to a checkout experience must clearly state the service name, price and payment frequency.

Advertising Sources: Affiliate marketing networks must not be used in any circumstances in the UK, all service advertising must be via direct media buying.

Advertising to Children: It is strictly prohibited to target advertising to anyone under the age of 18 (‘children’) or permit advertising to appear on sites and in apps or any other locations likely to be frequented by children such as children’s websites (such as www.tinypop.com) or apps or games which are likely to be attractive to, or have a main audience of, children (such as TalkingTom). Care should also be taken when setting negative targeting advertising in mixed content websites such as YouTube to ensure that all possible steps are taken to prevent adverts appearing alongside children’s content. The exposure of children to online advertising is a highly sensitive issue in the UK DCB industry and carriers and the regulator reserve the right to suspend services breaching this requirement without warning.

ASA: Ads must comply with the relevant sections of the CAP Code (The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing) – https://www.asa.org.uk/codes-and-rulings/advertising-codes/non-broadcast-code.html‍

Video Teaser Frames: It is not permitted to use video player/teaser frames on landing pages.

Accurate Content Portrayal: All advertising and landing pages (including Text-only ads) must clearly describe, or portray accurately with imagery, the content and type of content (in addition to featuring the service name) available from the service, and content described or portrayed in the advertising must be demonstrably available in the service.

Advertising Sources: Affiliate marketing networks must not be used in any circumstances in the UK, all service advertising must be via direct media buying.

• Service Registration: In addition to service providers being registered, all individual services must be registered with the regulator via regulator website
• Unsubscription: Unsubscription functionality must be available from within subscription services. Infomedia provide an API and URL for this purpose which will be set up during your integration with us.
• Data Reporting: UK carriers require the following data to be captured monthly reported at least every 6 months and also on request:
• Customer service rate (number of CS queries as a % of base),
• Churn Rate calculated as as [Number of users unsubscribing] / ([Base at start of reporting period] + [New acquisitions in reporting period]),
• % of new users each month who interact with the product/service at least twice in the first week of subscription and a further additional time within the first month.
• EE UK also maintain a rule which requires any user who has not interacted with a service after (and not including) the first 24 hours of a subscription and for a further 120 days shall be automatically entitled to a full refund if requested

• Retries: Subscription Retries limited to once per day, no retries on single purchase.
• Age Restrictions: Only over 18s can purchase subscription services, all services must have an age appropriateness defined (e.g. 12+, 15+, 18+)
• Subscription timeout: Where a subscription customer has not had a successful bill or a successful message delivery for 60 consecutive days, their subscription will be cancelled automatically.

• Online Portal & SEO: All services shall provide an online portal for their service which will display FAQs regarding the service, instructions on how to access/login to the service and allow a user to unsubscribe from a service by inputting their MSISDN. The online portal must be easily discoverable through a Google search, with appropriate SEO and keywords matching the service name. The service itself must also be easily discoverable through a google search, and must not be able to be accessed for free.
• Anti-fraud/Compliance Monitoring: Merchant must enter into a third party compliance monitoring and anti-fraud agreement with our supplier MCP Insights, or Infomedia can provide as a service.
• Refunds: Use of Refund to Bill is mandatory for all refunds unless a customer explicitly requests a different method. This can either be via integration with our Refund API or using our CS web portal ‘CSLite’ to process refunds.

• Churn: Users must be churned after 14 days of unsuccessful billing.

• Retries: Billing & Retries must be between the hours of 8am and 7pm local time
• Step Charging: Step charging only operates between billing frequency, e.g. a weekly billed user may be stepped down to become a daily billed user. Once a step down happens it is not possible to revert to the original billing frequency.
• Exit SMS after churn: Exit SMS must be sent to users after they have been unsubscribed due to 45 days failed payment.

• Anti-fraud/Compliance Monitoring: Merchant must enter into a third party compliance monitoring and anti-fraud agreement with our supplier Evina and implement their products DCBProtect, BrandProtect and Eyewitness.
• Billing Suspended During Complaints: During the investigation of a customer complaint, all service billing must be suspended until the investigation is completed.
• Subscription Hosting: Subscription service must have their subscription/billing base hosted by Infomedia
• Zero-rated MO: Inbound SMS from customers to cancel services are zero-rated for customers with the cost charged to service providers.

• Unless specified differently above, users whose bill fails due to ‘out of credit’ or similar error may be retried 3 times on day 1, twice on day 2 and once per day for every day until the end of the billing cycle (up to 45 days). The policy resets on the commencement of a new billing cycle. Expired billing cycles must not be retried (this should be taken into account when setting grace periods below). Users who have failed to bill for 45 consecutive days must be automatically unsubscribed however a merchant may set a shorter period if they wish.
• Users whose bill fails due to closed, barred or suspended MNO account may be retried 3 times on day 1, twice on day 2 and once on day 3, then the subscription must be cancelled.
• Other MNO technical errors will be automatically retried for 45 days. Users who have failed to bill for 45 consecutive days must be automatically unsubscribed however a merchant may set a shorter period if they wish.
• A merchant may choose a grace period during which a user whose bill has failed retains access to their service. It is recommended a grace period of 7 days is implemented to account for MNO technical errors however we appreciate this will not be viable in all cases.
• Split billing is not permitted (e.g. splitting a £5 charging into 2x £2.50 on the first attempt). Step charging after first bill failure is permitted on some carriers, please ask your account manager for details.