Charge to Mobile Egypt Framework - infomedia.co.uk · This document applies to premium rate...

Charge to Mobile Egypt Framework

Version 2.2

May 2018

© 2018 InfoMedia Services Limited, All Rights Reserved

Charge to Mobile Egypt Framework/ 2

Table of

contents

1 INTRODUCTION ....................................................................................................................................................... 4

2 CONTACT ................................................................................................................................................................. 4

3 BREACHES ............................................................................................................................................................... 4

4 SPEND LIMITS .......................................................................................................................................................... 5

4.1 PRE-PAY USERS ................................................................................................................................................... 5

4.2 POST-PAY USERS ................................................................................................................................................. 5

5 CONSENT TO CHARGE .......................................................................................................................................... 5

5.1 MSISDN SECURITY ............................................................................................................................................... 5

5.2 URL SUBMISSION .................................................................................................................................................. 5

6 COMMENCEMENT OF A SERVICE ......................................................................................................................... 6

7 CULTURAL POLICY ................................................................................................................................................. 7

7.1 TRUTHFULNESS .................................................................................................................................................... 7

7.2 LEGALITY ............................................................................................................................................................... 7

7.3 PRIVACY ................................................................................................................................................................. 7

7.4 HARM AND OFFENCE ........................................................................................................................................... 7

8 SUBSCRIPTION SERVICES .................................................................................................................................... 8

8.1 ACTIVATING AND DEACTIVATING SUBSCRIPTION SERVICES ....................................................................... 8

8.2 'FREE TRIAL' PERIODS: ........................................................................................................................................ 8

8.3 GROWTH CAPS ..................................................................................................................................................... 8

9 BILLING ..................................................................................................................................................................... 9

9.1 SUBSCRIPTION RENEWAL................................................................................................................................... 9

9.2 RETRY POLICY ...................................................................................................................................................... 9

10 ADVERTISING & MARKETING .............................................................................................................................. 10

10.1 MARKETING REQUIREMENTS ......................................................................................................................... 10

10.2 ADVERTISING TO CHILDREN .......................................................................................................................... 10

10.3 AFFILIATE MARKETERS ................................................................................................................................... 11

10.4 ADVERTISING COPY ......................................................................................................................................... 11

11 SUBSCRIPTION FLOWS ........................................................................................................................................ 12

11.1 LANDING PAGE LAYOUT AND CONTENT ....................................................................................................... 12

11.2 PIN FLOW (MERCHANT HOSTED OPTION) .................................................................................................... 13

11.3 TERMS & CONDITIONS ..................................................................................................................................... 14

11.4 SUCCESSFUL SUBSCRIPTION ........................................................................................................................ 17

11.5 SINGLE PURCHASES ........................................................................................................................................ 18



TEXT: ...................................................................................................................................................................... 18

12 CUSTOMER MESSAGING ..................................................................................................................................... 20

12.1 GENERAL RULES .............................................................................................................................................. 20

12.2 PIN MESSAGE .................................................................................................................................................... 21

12.3 PRESCRIBED MESSAGES ................................................................................................................................ 21

12.4 PURCHASE CONFIRMATION MESSAGE ......................................................................................................... 21

13 CUSTOMER SUPPORT ......................................................................................................................................... 22

13.1 CUSTOMER SUPPORT PROCESS ................................................................................................................... 22

EMAIL ...................................................................................................................................................................... 22

TELEPHONE ........................................................................................................................................................... 22

MERCHANTS COMPLAINTS HANDLING PROCESS ........................................................................................... 22

CARRIERS COMPLAINTS HANDLING PROCESS ............................................................................................... 22

TIMEFRAMES ......................................................................................................................................................... 22

13.2 CUSTOMER SUPPORT KEY PERFORMANCE INDICATOR ........................................................................... 23

13.3 REFUNDS ........................................................................................................................................................... 24

REFUND SITUTATIONS ......................................................................................................................................... 24

ADMINISTERING A REFUND ................................................................................................................................ 24

REFUND REPORT.................................................................................................................................................. 24

14 UNSUBSCRIPTION FUNCTIONALITY................................................................................................................... 25

14.1 UNSUBSCRIPTION BY SMS.............................................................................................................................. 25

14.2 SELF HELP SITE ................................................................................................................................................ 25

14.3 CS LITE ............................................................................................................................................................... 25

15 DATA ....................................................................................................................................................................... 26

15.1 CUSTOMER CARE DATA .................................................................................................................................. 26

15.2 STORAGE ........................................................................................................................................................... 26

15.3 ENGAGEMENT DATA ........................................................................................................................................ 26

15.4 AFFLIATE NETWORK DATA .............................................................................................................................. 26



1 INTRODUCTION

This document applies to premium rate services (PRS) that run billing via INFOMEDIA in the Arab Republic of Egypt.

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 requirements of Telecommunications Regulatory Authority at all times.

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.

3 BREACHES

If a breach of this framework or the Mondia CoP 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.

Where breaches of this framework result in penalty or other charges to be levied on INFOMEDIA by any third party such as a carrier or regulatory body these charges shall be deducted from the Merchant’s revenue share.

mailto:[email protected]



4 SPEND LIMITS

4.1 PRE-PAY USERS

Pre-pay users in Egypt are subject to a maximum price point of 500 EGP.

4.2 POST-PAY USERS

Post-pay users in Egypt are restricted by their tariffs, usually at the price points 50, 75 or 125 EGP. It will not be possible to identify the limit for any given user.

Where a tariff-based price point limit is exceeded the transaction shall fail.

5 CONSENT TO CHARGE

It is a requirement to be able to evidence users’ consent to being charged for any service or product provided, or receiving marketing material.

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.

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.

All services must have in place INFOMEDIA’s Consent To Charge technology which captures key data such as images of the landing screen the customer sees, user agent, IP address and x-y coordinates of landing page clicks. Where evidence cannot be gathered to verify the authenticity of the subscription billing may not proceed.

Details of the technology and how to implement it can be found in the CTC Engagement Capture Implementation Guide (available from your INFOMEDIA Account Manager).

The merchant is required to co-operate with INFOMEDIA in the acquisition of the necessary data to ensure evidence of consent to charge has been obtained.

Some services, such as Higher Cost Services, require the above evidence to be provided by a robust 3rd party organisation (who does not receive financial gain from the generation and/or conversion of leads) verifying the merchant’s services.

5.1 MSISDN SECURITY

All user acquisition flows and pages must have in place technology to prevent plain text MSISDN injection and only correctly encrypted MSISDNs must be submitted to the INFMEDIA platform in accordance with the requirements of the WBG In-app Billing API documentation. Failure to ensure that users are prevented from harm with the correct security will result in the immediate suspension of acquisition and/or billing at INFOMEDIA’s discretion.

5.2 URL SUBMISSION

• All partners must submit the full URLs of all subscription or purchase flow pages to INFOMEDIA prior to those

URLs being made available to consumers. This applies at all times, not only during service set up.

• Landing pages/flows which are not part of a live advertising campaign must be deactivated to mitigate the risk

of consumers or other parties being able to access those pages by either direct navigation or links from

advertising still available even after a campaign has been withdrawn.

• Failure to provide to INFOMEDIA the URL for pages or flows which are available to consumers by any route

will be grounds for immediate suspension of acquisition for the entire service, regardless of whether the pages

are in and of itself compliant with the advertising and acquisition rules of this Framework.



• Additional contractual penalties for breach may apply.

6 COMMENCEMENT OF A SERVICE

All products must be approved by INFOMEDIA and our partner. The following information is required at least 30 days 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 Egyptian Pounds (EGP). This must include details on any in-life price changes e.g.

promotions such as 20 EGP for the first week then 40 EGP per week thereafter;

o The Merchant’s customer care email address and service details (note: this must be free to access, available

in English and Arabic and comply with the requirements of 13 CUSTOMER SUPPORT);

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 & Advertising for launch complying with 10 ADVERTISING & MARKETING;

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

o Confirmation of the pricing models used (if not subscription or if in addition to a subscription model).

Any changes to a service must be submitted for approval at least 30 days before the change is implemented. This

includes changes to price point, customer service details or any aspect of the terms and conditions.



7 CULTURAL POLICY

7.1 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).

7.2 LEGALITY

Marketing communications shall comply with the laws, heritage and the religious, moral, cultural, and social norms of the Arab Republic of Egypt and not encourage any unlawful or immoral behaviour.

7.3 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

7.4 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.

VIOLENCE

• Torture and violence including all forms of practices that could result in injury or serious damage to health;

• Any weapons, weapon accessories and/or explosives or inducement of sale of such materials;

• Self-harm, suicide and bullying;

• Terrorist activities;

• Genocide;

• ‘Hate speech’ or any content which contains images that are offensive, profane, threatening, harmful,

harassing or discriminatory content that is racially or ethnically offensive or encourage such conduct;

• Criminal offences such as murder, taking somebody as hostage etc.

SEXUAL MATERIALS

• Any sexually explicit content;

• Nudity or transparent clothing (non-transparent bikinis are permitted in a sporting or fashion context where

the obvious focus is not on the woman);

• Any pornographic content;

• Any display of genitals or topless or naked people (whether the genitals are visible or not e.g. from behind)

except in the case of a naked male torso in a sporting context such as swimming;

• Promotion or inducement of human trafficking.

POLITICAL AND CULTURAL

• Any type of content regarding the persons ruling any country e.g. the president, king or queen etc;

• Any content with political sponsorship, political views, religious views (including any materially which may

be religiously offensive) or anything politically sensitive or controversial;

• Any content proposing, inducing or alluding to betting or gambling;



• Any content promoting, or instructing the use of, illegal drugs or alcohol

OTHER LIABILITIES

• Offensive language;

• Software piracy or hacking;

• Use of proxy sites;

• Bulk SMS;

• Multiple billing;

• Trivia quizzes;

• Donations, lotteries, gambling, betting tips;

• Content that infringes the intellectual property rights of a third party;

• Any content unlawful or in violation of any applicable law, regulation or directive;

• Transmission of any messages which are improper, immoral, unlawful, racial, discriminating, harassing,

embarrassing, libellous, abusive, threatening, harmful or obscene;

• Sending, or facilitating the sending of, unsolicited material (spam), unsolicited advertising, promotional

materials, or any form of solicitation to any person in a way that could be expected to adversely impact

any network or facilities;

• Violate any other person’s rights, or interfere with another person’s use of the service.

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.

8 SUBSCRIPTION SERVICES

8.1 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 and deacativation.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.

All subscription and/or onetime payment services should be in English and Arabic

All subscription and/or onetime payment services should include Wi-Fi flow

8.2 'FREE TRIAL' PERIODS:

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.

8.3 GROWTH CAPS

New merchants launching services through INFOMEDIA shall be subject to revenue-based growth caps during the first 3-6 months of operation.

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.



9 BILLING

This section details billing policies on retries, subscription renewal, step charging, activity limits etc.

The DCB platform must be running at 99.9% availability 24 hours a day 7 days a week.

9.1 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.

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.

9.2 RETRY POLICY

Where a bill fails, retry attempts may be made however must be restricted to within the same billing period.

Any subscriber who is not successfully billed for 30 consecutive days will be automatically unsubscribed.

Retry attempts can only be made at specific intervals as set out below:

For Daily Subscription Renewal:

o Retry attempts may be submitted no sooner than 8 hours after the previous daily billing attempt, so that a

maximum of 2 retry attempt is allowed per day (if 1st attempt fails in the morning).

o Retry attempts are restricted to that current day; no retries for past unbilled days are allowed.

For Weekly Subscription Renewal:

o Retry attempts may be submitted no sooner than 2 days after the previous weekly billing attempt, so that a

maximum of 3 retry attempts is allowed per week.

o Retry attempts are restricted to that current week; no retries for past unbilled weeks are allowed

For Monthly Subscription Renewal:

o Retry attempts may be submitted no sooner than 2 days after the previous monthly billing attempt, so that a

maximum of 15 retry attempts is allowed per month depending on the length of that month.

o Retry attempts are restricted to that current month; no retries for past unbilled months are allowed

Step Charging is not permitted.



10 ADVERTISING & MARKETING

10.1 MARKETING REQUIREMENTS

All advertising and services shall be offered in the Arabic language primarily, if the service is only available in English this must be clearly stated.

INFOMEDIA advise that all advertising be targeted, contextual and in appropriate media.

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 marketing (including ay conducted by affiliates, subcontractors or any other third parties) periodically regardless of activity to ensure that is both effective and compliant. INFOMEDIA require this documentation to be sent monthly as part of our ongoing compliance checks.

The following practices are not permitted by Merchants or their affiliate marketer in advertising or service content:

• Promoting products and services in a misleading manner;

• Promoting unrelated content based on popular search terms among natural search results;

• Using intellectual property without permission, such as brand logos;

• Redirecting users to unrelated third party websites to promote unrelated content;

• Hijacking clicks to either subscribe users unknowingly or 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, whether or not locked content is delivered;

• 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

• 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.

Merchants must provide INFOMEDIA with a documented process that demonstrates the steps they take in which they protect against this type of advertising. Merchants are required to document this process using the Advertising Control Template in the product packs that have to be submitted to INFOMEDIA. We recommend that Merchants have an advertising whitelisting process and contractual steps with their advertising partners to add in these reassurances.

Where inappropriately placed marketing is found or reported to Merchants by INFOMEDIA, carriers, monitoring services, customers or any other party such marketing shall be removed within 24 hours of such notification.

10.2 ADVERTISING TO CHILDREN

It is strictly prohibited to target advertising to anyone under the age of 16 (‘children’) or permit advertising to appear on sites and in apps or any other locations likely to be frequented by children such as childrens 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

http://www.tinypop.com/



TalkingTom). Care should also be taken when advertising in mixed content websites such as YouTube to ensure that all possible steps are taken to prevent adverts appearing alongside children’s content.

10.3 AFFILIATE MARKETERS

Merchants that use affiliate marketers are responsible for ensuring, regardless of whether this activity is sub-contracted, that promotions are compliant with the requirements of this Framework and all applicable law and regulations relating to advertising for the territory.

Clear expectations must be placed on affiliate marketers around compliance with the requirements of this Framework and Merchants must obtain a clear commitment to this end as part of any contract signed. INFOMEDIA may reasonably request sight of such written commitments.

INFOMEDIA reserves the right to require Merchants to use only direct-buy advertising (e.g. Google AdWords) or

mandate the use of cost-per-click purchasing rather than (cost-per-acquisition).

PROHIBITED AFFILIATES LIST

Orange and Vodafone Egypt maintain and issue from time to time a list of prohibited affiliate marketing companies. For ease of delivery and assurance, Merchants shall not advertise services via any company on the list in Egypt for any carrier:

Adjomo Hilltop Ads Slimspots

Avazu Horny Hotspots Spiroox

Bitter Strawberry Kimia Traffic Junky

Brokerbabe Mobifreak Yang Zeta

Buzzcity Mobipium Yeah Mobi

Eroadvertising Mobusi ExoClick Msales GasMobi Reporo

Note: Updates to this list may be issued by email as Infomedia is notified by the carriers without updates to this Framework. Merchants are advised to keep an internal list.

10.4 ADVERTISING COPY

INFOMEDIA’s requirements for all advertising copy are as follows:

Advertisements must:

• State the name of the service, or a clear written description of the service. INFOMEDIA recommends that the

text size for the service name cover at least 50% of a thin banner

• Be directly relevant to the service content.

• State the service price and billing frequency

• State the above requirements in a text size and format that is legible to the average consumer



11 SUBSCRIPTION FLOWS

User can subscribe via a header enriched double click flow with the second click page hosted by the Egyptian carrier’s billing aggregator or, if a user is not detected or fails the double click flow, via a PIN flow which can be hosted by either the merchant or the billing aggregator.

Header enriched user detection is always carried out after the user has seen an initial Landing Page from an advertising click, therefore both PIN and Double Click flows start with the same Landing Page, detailed below.

The full flow experience is set out as a flowchart in the supporting Flow Layout documentation which should be read alongside this section.

NOTE: HEADER ENRICHED FLOWS TEMPORARILY SUSPENDED FOR VODAFONE EGYPT FROM 10TH AUGUST 2017

11.1 LANDING PAGE LAYOUT AND CONTENT

TEXT:

o In addition to specific rules for specific page sections below, all text elements, including text in images, must

be clear and legible to the average reader and in a colour clearly contrasting to the background.

LANGUAGE:

o Flow pages shall primarily be presented in Arabic. An option to switch to English may be presented.

PRICING:

o The price and frequency must be stated in a stand-alone line, directly above/below the CTA button.

o VODAFONE Only: In a font size that the average reader can clearly see at a glance and larger than any other

font on the page.

o All prices shall be presented in Egyptian Pounds in the format ‘## EGP’

NAME OF SERVICE:

o The name of the service must be clearly displayed on the page above the fold.

o INFOMEDIA recommends font to be 50% of the CTA button.

SERVICE DETAILS o The following prescribed phrase should be reasonably proximate to the CTA button:

‘[Service Name] is a [service description] subscription service for [price point] [billing frequency] [details of any

trial period]. Additional network data charges may apply. [User confirmation of age or bill payer’s permission]’

o EXAMPLE: Latest Game 2 is a games subscription service for 30 EGP per week. Try now free for 24

hours. Additional network data charges may apply. By clicking ‘Subscribe’ you confirm you are at least

18 years old or have permission of the bill payer.

o The text “Charges added to this mobile’s bill” need to be displayed directly above or below the CTA

o Where applicable, any limitations to accessing the service must also be stated, for example ‘This service is

only available on devices running Android 4.2.2 or higher’ or ‘Not available on Windows phones’.

o If the service content is only available in English language version this must also be stated.

o Unsubscription and customer service details must be shown on the page.



CALL TO ACTION BUTTON

o Must contain text covering at least 50% of the button which clearly and unambiguously informs the user that

they are entering into an obligation to pay.

Acceptable examples, when taken in conjunction with pricing information on the CTA, include:

o SUBSCRIBE

o SUBSCRIBE NOW

o JOIN FOR (where the pricing information is the same font size)

Unacceptable examples include:

o PLAY

o ENTER

o CONTINUE

o AGREE

o YES

o JOIN

o SIGN IN

o The price, frequency and details of any free period must be in the bottom 50% of the CTA button with the text

size scaled appropriately to be clear and legible

o All copy should be consistent, for example in terms of all capitals or all bold. The colour of the text must be

clearly distinguishable from the button colour. INFOMEDIA recommend a contrast ratio of 4.5:1 in accordance

with the Web Content Accessibility Guidelines (WCAG) 2.0. Contract of colours can be checked at

http://www.msfw.com/Services/ContrastRatioCalculator

o The CTA button and text within must be legible, unobstructed, visible and static at all times.

TERMS & CONDITIONS

o Links must be available to the terms and conditions and then those Terms must be available from within the

service after joining, see section TERMS & CONDITIONS.

COUNTDOWN TIMER

o No countdown timer should be used to rush the customers decision to subscribe.

PAGE GRAPHICS

o Specific rules relating to the creative graphical content:

o Free trials must not be referred to in the graphics, only in the service details copy

o Graphics content must not purport to be personalised to the customer

o Graphics must not purport to be a download or download link

11.2 PIN FLOW (MERCHANT HOSTED OPTION)

PIN Flow

o The PIN flow shall be two stages, MSISDN Entry and PIN Entry. Both pages shall follow the requirements

below

page layout

o The PIN flow pages shall follow the same rules as the Landing Page above save for the items detailed below.

MSISDN ENTRY PAGE

o There shall be a box for the user to enter their MSISDN, clearly labelled as such.



o The CTA Button must state REQUEST PIN or similar clear statement of the function of the button.


PIN ENTRY PAGE

o There shall be a box for the user to enter their PIN, clearly labelled as such, on the PIN Entry page.

o The CTA Button must state CONFIRM SUBSCRIPTION or SUBSCRIPTION CONFIRMATION, CONFIRM

PURCHASE for single payments.


11.3 TERMS & CONDITIONS

The Terms & Conditions of subscription linked to from the landing page must clearly state the user is entering into a reoccurring subscription service. There needs to be clear guidance on the cost to the service and how the user can unsubscribe from the service. The required information is set out in the table below with format examples. The full terms for each service must be provided as part of the product packs submitted to INFOMEDIA. The terms must clearly start at the top of the linked page and be in a font size easily legible to the average reader. Best practice would be to allow zooming/enlargement.

Note - For the terms contained within Terms and Conditions Table 1 the wording is prescribed.

Terms and Conditions Table 1

Required Information Prescribed Wording

Rules of Access to (Site URL) subscription service

This is a mobile content subscription service which will provide access to [Site URL]. This service is applicable to [Operator Name] Egypt users. As part of the Subscription, the Subscriber is able to access the Private sections and/or additional functionality of the [Service Name] site (hereinafter “Site”) for the entire duration period of the Subscription.

Subscription Information To begin the Subscription, give consent by pressing the “Subscribe” button. The beginning of the Subscription is confirmed by sending a free informational SMS to the Subscriber. Subscribers will receive a free SMS with a reminder of the active Subscription once a week.

Your Phone number will be automatically detected if you’re connected to [Operator Name] 3G/4G to ease the subscription verification process.

Cost of subscription The service is provided on a paid basis with daily payments throughout the duration period of the Subscription. The Cost amounts to [price/frequency]for [Operator Name] Subscribers

Unsubscription details To cancel the Subscription, click on the “Cancel subscription” link on the site and follow the instructions. After pressing the “STOP” button, the Subscription will be stopped and the Subscriber will receive a free SMS with confirmation.



To cancel the Subscription by sending SMS, it is required for:

• [Operator Name] Subscribers to send an SMS with the text “STOP” to the free number [shortcode]

• For Orange: click the below URL (please insert your service ID to the highlighted part) http://sso.orange.com/mondiamedia_subscription/?method=unsubscribe&serviceId=$[SERVICE_ID]$

Liability Waiver – Statement of age and account holder consent

The Subscriber shall be fully responsible for any consequences resulting from viewing, reading or copying materials and/or use of the Site’s services. You also confirm that you are 18 years or older and are the mobile account holder or you have consent from the mobile account holder. For help please send an email to Help desk [FAQ page/ merchant company mail address]

Terms and Conditions Table 2

Required information Format example

Type of Service e.g. games/apps/sports/music subscription

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

Name of merchant and/or brand if part of merchant name

…provided by [name of merchant and/or brand if part of merchant name].

Statement that renewal will be automatic. your subscription will be renewed automatically.

Statement as to when billing will take place (considering both pre-pay and pay monthly customers)

These charges will be due from your pre-pay balance [24 hours after the start of your subscription and then (daily/weekly/monthly) thereafter]/[every (weekday)] or added to your monthly mobile bill for this phone.

Statement that network data charges may apply

Operator data charges may apply as per your plan.

Statement confirming residency and agreement to full terms and conditions and link to the full terms of service (if presented separately) and privacy policy.

By signing up for and/or using the service you acknowledge and confirm that you are a resident of the Arab Republic of Egypt and 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],

If applicable: Statement setting out any specific handset capabilities are required to access a service.

This service is not available on devices running the Windows operating system.

http://sso.orange.com/mondiamedia_subscription/?method=unsubscribe&serviceId=$%5bSERVICE_ID%5d$

http://sso.orange.com/mondiamedia_subscription/?method=unsubscribe&serviceId=$%5bSERVICE_ID%5d$



If applicable: Statement setting out any restrictions on when the service is available.

The “Live Consultation” part of the service is only available between 8am and 6pm Monday to Saturday.

EXAMPLE:

This is a mobile content subscription service which will provide Access to www.gameshub.com. This service is applicable to Orange Egypt users. To begin the Subscription, give consent by pressing the “Subscribe” button. The beginning of the Subscription is confirmed by sending a free informational SMS to the Subscriber. Subscribers will receive a free SMS with a reminder of the active Subscription once a week. Your Phone number will be automatically detected if you’re connected to Orange 3G/4G to ease the subscription verification process. The service is provided on a paid basis with daily payments throughout the duration period of the Subscription. The Cost amounts to 2 EGP per week for Orange Subscribers and your subscription will be renewed automatically. These charges will be due from your pre-pay balance 24 hours after the start of your subscription and daily thereafter or added to your monthly mobile bill for this phone. To cancel the Subscription, click on the “Cancel subscription” link on the site and follow the instructions. After pressing the “STOP” button, the Subscription will be stopped and the Subscriber will receive a free SMS with confirmation. To cancel the Subscription by sending SMS, it is required for [Operator Name] Subscribers to send an SMS with the text “STOP” to the free number 1234 For Orange: click the below URL http://sso.orange.com/mondiamedia_subscription/?method=unsubscribe&serviceId=$117548. Operator data charges may apply as per your plan. By signing up for and/or using the service you acknowledge and confirm that you are a resident of the Arab Republic of Egypt and you have read the Terms & Conditions and Privacy Policy.

.

http://sso.orange.com/mondiamedia_subscription/?method=unsubscribe&serviceId=$117548.



11.4 SUCCESSFUL SUBSCRIPTION

The 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 service cannot be activated immediately then the customer’s subscription must be cancelled and the customer directed to either:

o a failed subscription page before being returned to the landing page; or

o directly back to the place where the user first clicked the banner.

In a successful subscription the user should be directed to a confirmation page. It is also acceptable for the user to be taken directly to the service page from the Confirmation button click with a pop-up or information banner confirmation of subscription message which must be visible for no less than 5 seconds or until the user closes the message. If a banner is used it cannot be at the very top or bottom of the page.

If a confirmation page is used this should provide a link to access service and if the customer does not click the link they should be automatically redirected to the service within a minimum of 5 seconds.

The confirmation details on the page, banner or pop-up should set out:

o Confirmation of successful subscription

o Price & billing frequency

o Name of service

EXAMPLE TEXT:

o You have subscribed to Games Hub for 30 EGP per week until you cancel.



11.5 SINGLE PURCHASES

Where a user purchases an item or service for a one-off fee (for example in-app purchases or pay-per view) the purchase shall use the following PIN flow:

o User clicks on a PIN Request Button associated with the item/service being purchased

o User is sent a message containing PIN (see 12.2 PIN MESSAGE)

o User enters PIN on PIN Entry page

o User clicks Call to Action button

o Purchase is completed

o User has access to item/service

o User is sent ‘Purchase Confirmation’ message (see 12.4 PURCHASE CONFIRMATION MESSAGE)

The following requirements must be followed on the page from which the user is making the purchase:

TEXT:

o In addition to specific rules for specific page sections below, all text elements, including text in images, must

be clear and legible to the average reader and in a colour clearly contrasting to the background. White text on

black background is not permitted.

DESCRIPTION:

o The item or service must be clearly and unambiguously named, described and priced.

o The text “Charges added to this mobile’s bill” need to be displayed directly above or below the PIN Request

and CTA Buttons.

MSISDN/PIN ENTRY

o There shall be a box for the user to enter their MSISDN, clearly labelled as such.

o That box shall switch to a box to enter the PIN

PIN REQUEST BUTTON

o Must state clearly and unambiguously that the function of the button is to send an PIN text, e.g. “SEND PIN

TEXT”. It must not suggest that the button has any other function.

o The price must be in the bottom 50% of the CTA button with the text size scaled appropriately to be clear and

legible

o All copy must be consistent – either all in capitals or all in sentence case and all bold or not. The colour of the

text must be clearly distinguishable from the button colour. INFOMEDIA recommend a contrast ratio of 4.5:1 in

accordance with the Web Content Accessibility Guidelines (WCAG) 2.0. Contract of colours can be checked at



CALL TO ACTION BUTTON

o Must contain text covering at least 50% of the button which clearly and unambiguously informs the user that

they are making a purchase. Acceptable examples, when taken in conjunction with pricing information on the

CTA, include:

o PAY

o PAY NOW

o BUY

o Unacceptable examples include:



o PLAY

o VIEW

o CONTINUE

o YES

o SIGN IN

o AGREE

o The price must be in the bottom 50% of the CTA button with the text size scaled appropriately to be clear and

legible

o All copy must be consistent – either all in capitals or all in sentence case and all bold or not. The colour of the

text must be clearly distinguishable from the button colour. INFOMEDIA recommend a contrast ratio of 4.5:1 in

accordance with the Web Content Accessibility Guidelines (WCAG) 2.0. Contract of colours can be checked at



TERMS & CONDITIONS

o There shall be a link to the terms and conditions of the purchase and/or service or item use.



12 CUSTOMER MESSAGING

During a user’s time in a service they will be sent messages confirming purchases or providing them with the agreed information as detailed in the below sections. Some messages are prescribed and others must follow the requirements set out below. 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. If no language option is given all messages must be sent in Arabic. Where applicable INFOMEDIA shall monitor messaging by way of alarms triggered by missing or incorrect messaging.

12.1 GENERAL RULES

The following rules apply to all messages unless specifically excluded in the message type details in sections 0 to 12.4 below.

IDENTITY:

o Instructional and/or operational messages must notify the consumer the identity of the sender. This can be via

the Short Code or an Alpha-Numeric description.

o INFOMEDIA recommend that the short code/ MSISDN used to send these SMS’s to the customer display the

name of the service, as known by the user e.g. “GamesHub”.

o Messages should not contain the carrier’s name as part of the identity

FREE:

o Instructional and/or operational messages must be free to receive

o Additionally, consumers must be clearly informed within the message there is no charge to receive this type of

message. E.g. with “Free Msg”, “Freemsg”, “Free Message” or “Free Msg” as the originator.

PRODUCT OR SERVICE NAME:

o The product name or name of service, if this is a URL it must be clear what the service is.

PROMOTIONS:

o The prescribed service messages must not contain any promotional material unless otherwise specified

below.

MISLEADING:

o The message should not mislead the end user in any way.

CUSTOMER SERVICE:

o The customer service email address shall be displayed.

PREMIUM RATE SMS:

o Premium Rate SMS messages are not permitted.

LANGUAGE:

o All messages shall be in the same language as the flow through which a user purchased or subscribed to a

service.



12.2 PIN MESSAGE

The PIN Message is sent when requested by a user in the PIN Flow.

CONTENT:

In addition to the General Rules the message must contain:

o PIN

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

EXAMPLE: FreeMsg: Please enter the following PIN: 1234 to access Games Hub for 30 EGP per week. This service is free for your first 24hrs. Help? Email [email protected]

12.3 PRESCRIBED MESSAGES

The following messages are prescribed and sent by carriers and as such do not require drafting:

o Welcome Messages (upon subscribing to a service)

o Exit Messages (upon unsubscribing from a service)

o Renewal Messages (sent weekly for daily or weekly subscriptions and monthly for monthly subscriptions,

triggered by a successful payment)

For these messages the following information is required:

o Product/service name

o Price & Frequency

o Trial period (if applicable)

o Access URL

o STOP keywords

o Support details (email address)

12.4 PURCHASE CONFIRMATION MESSAGE

For SINGLE PURCHASES this message confirms customer’s purchases and acts as a receipt. In addition to the General Rules (other than the rule on Stopping A Service) the message must contain:

o Indication of successful transaction;

o Price paid.



13 CUSTOMER SUPPORT

The following section details the requirements of customer support

13.1 CUSTOMER SUPPORT PROCESS

EMAIL

o Merchants shall provide customer support via email available 24 hours a day.

o Support should be available both English and Arabic languages.

o Email queries should be responded to within 48 hours

o INFOMEDIA recommends emails are automatically acknowledged upon receipt and the acknowledgment set

out that a response will be provided within 48 hours.

o INFOMEDIA expects that most queries should be closed within 48 hours, however if a final response cannot

be provided within this timeframe an interim response should be sent to the customer, and then updates every

48 hours until the query is fully resolved.

o 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.

TELEPHONE

o INFOMEDIA recommend Merchants provide customer support via telephone available in local office hours.

This is due to the direct financial penalties for excessive CS calls to carriers; Merchants should consider

whether it is more commercially viable to meet the costs of these charges, which may vary, or the more

predictable cost of a call centre function.

o Support should available in Arabic, and it is recommended English is also available.

o Out of hours should be provided with a recorded message giving the opening times and email options.

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 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. TIMEFRAMES

• Deactivation and refund requests should be execute within 1 Working Day.

• Service/Product Issues should be executed within 2 working days from the time the issue is reported.



13.2 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.



13.3 REFUNDS

REFUND SITUTATIONS

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

However for those 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 EGP. 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

Merchants shall provide monthly reports on refunds to INFOMEDIA in the below format:

Date/Time TransactionID MSISDN Content Name

Original Charge

Refund Amount

Reason

This must be sent on the first of the month every month.



14 UNSUBSCRIPTION FUNCTIONALITY

14.1 UNSUBSCRIPTION BY SMS

User must be able to unsubscribe from a service by sending ‘STOP [KEYWORD]’ to a shortcode (English language ‘STOP’ is used).

Unsubscription by SMS will be handled by INFOMEDIA’s territory partner and INFOMEDIA will inform Merchants of unsubscribed users.

.UNSUBSCRIPTION VIA IN-SERVICE OPTIONS

An unsubscribe option or link shall appear prominently on product or merchant main pages in text which is clear and legible to the average reader and in a colour clearly contrasting to the background. The option or link must be permanently available to the user. The language of the link text must match the language chosen by the user in the subscription flow.

The user must be able to unsubscribe in no more than two clicks, so for example the link can direct the user to an Unsubscription page or pop-up on which there is a link or button which directly triggers unsubscription. All text on that page or pop-up must be is clear and legible to the average reader and in a colour clearly contrasting to the background. The unsubscription link must be legible, unobstructed, visible and static at all times.

The Unsubscription copy must be clear and unambiguous in how a user can unsubscribe. Do not use double negatives (e.g. ‘Do you not want to unsubscribe? Yes / No’) or ambiguous statements or options (e.g. ‘Are you sure you want to unsubscribe? Yes / Cancel’). The copy shall include the customer service email address.

It is permitted for there to be non-direct advertising on the unsubscription page complying with all the ADVERTISING & MARKETING rules. All marketing must be in the bottom 50% of the page and clearly separated from the Unsubscription copy and link.

Merchants shall ensure that all unsubscription requests received through in-service or online options are immediately passed to INFOMEDIA to action.

14.2 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.

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.

The self-help site must follow the requirements set out in 0 UNSUBSCRIPTION VIA IN-SERVICE OPTIONS.

14.3 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 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.

https://www.example.com/?msisdn=%7bMSISDN%7d&bpid=%7bBPID%7d



15 DATA

15.1 CUSTOMER CARE DATA

Where CS Lite is not used, 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.

15.2 STORAGE

All

• Calls,

• Emails,

• Conversations

• Messages,

• Accessed IP’s

• User agent profiles

• Visited pages

• Advertisements

shall be stored for a full year. Consent To Charge data shall be stored by INFOMEDIA for two full years.

15.3 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)

15.4 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

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