Regulator and Mobile Operator Requirements for DCB

Adverts and flows must:

• Clearly state the service name
• Include a clear description and/or portrayal of the service
• Include the service price (and payment frequency where applicable) in the following territories:
  • Bahrain (Zain)
  • KSA (all)
  • Kuwait (all)
  • Nigeria (all)
  • Oman (all)
  • Singapore (all)
  • UK (all)
• Advertise via direct media buying from Google, Social Media services or similar direct owners of inventory, not affiliate networks (subject to any carrier or territory-specific rules below).
• Take action within 24 hours to any report from Carriers or Infomedia (or one of Infomedia approved compliance partners) of non-compliant advertising.
• Document advertising control processes and provide this to Infomedia on request in case of a regulatory or carrier audit or request.

Adverts and flows must not:

• Use affiliate networks
• Promote products and services in a misleading or deceptive manner
• Use ‘Download’ text and imagery where the service does not include downloadable elements or where the advertmay be confused with actual download functionality on a webpage
• Hijack links for unrelatedservices or products to direct users to service flows
• Use ‘Content-locking’ - enticingusers to complete subscription/payment flows to gain access to non-existentcontent, offers or prizes.
• Insert malicious code in any partof adverts or flows
• Use Click training, i-framing orsimilar methods which may cause a customer to click a CTA buttonunintentionally
• Posting false or misleading URLlinks on social networking websites or in instant messaging service to misleadusers
• Entice users to non-existentcontent via social network
• Entice users to download orinstall spoof applications hiding subscription/payment flows
• Take unfair advantage of anyvulnerable customer or group of customers
• Target advertising at children(under the age of 18)
• State opinions as facts
• Use malicious software to ransom users’ device functionality until payment is made or subscriptions joined in order to unlock browsers.
• Fail to state the identity, status and relevant professional qualifications of any person or entity dispensing professional advice (e.g. medical, financial etc.…)
• Be unable to supply evidence to substantiate claims made in advertising

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

Tablet Devices: Targeting orfailing 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.

‍

Price Display: All adverts must display the price and billing frequency of a service

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.

Styles: Adverts must avoid any risk of misleading customers into believing they are connected with or a functional element of the placement location or source. This includes use of phrases such as 'Download', 'Your content is ready', 'Verify Now', Start here'. The advert must clearly identify the service name and type of service.

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 (e.g. Google, social media).

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

‍

Banner and Advertisements: Ads must not use any sort of styles that could be misinterpreted as a functional part of a webpage or app (e.g. ‘download’ ‘start now’ button appearance and similar).

To comply with Etisalat’s policy on advertising, all adverts for services must:

1. clearly identify the service they are advertising by name;

2. be relevant to the service content; and

3. include a statement of the cost of the service to the end user and free period

4. be designed to ensure the advert is clearly distinct from placement locations, for example by using a border and unambiguous wording, and not use the word 'download' or associated download imagery; and

5. make all reasonable efforts to exclude the display of Ads in irrelevant apps and websites, for example games services promoted in children's/educational apps unless with Infomedia's consent where the service being advertised is itself primarily educational or aimed at children.

Service Content: Services must not contain unsecured files for download including apk files other than via authorised provider store e.g. Google Play Store or Apple Store.

Advertising Sources: Notwithstanding the general prohibition on affiliates, use of the following advertising networks/content providers in any capacity is specifically prohibited by carriers:

• Propeller Ads
• MediaM Performance
• Headway
• Adsimilis (WDGNB)
• Vykonia
• Avazu
• MobilityApp
• InMobi
• Spirox
• YeahMobi
• MobiAds
• Collect Cent
• Mobipium
• Mobpartner
• Adcamie
• Traffic Company
• Mobiclicks

Landing/Checkout Pages: All landing pages need to be approved by the Carrier before starting the additional channel promotions.

User Flow: The existing user flow must always remain unchanged.

Anti-Fraud Measures: Mandatory for all markets:

·       BH & KSA → Empello must be onboarded.

·       IQ, JO & KW → Evina integration is mandatory.

Social Media: Zain restricts advertising on social media to the following channels/requirements:

·       KSA: Facebook, Instagram, TikTok, Snapchat, WhatsApp, and Telegram

·       Bahrain: subject to prior approval from carrier: Facebook, Instagram, TikTok,Snapchat, WhatsApp, and Telegram

·       Kuwait: Facebook & Instagram only

·       Jordan: Facebook, Instagram, Snapchat, WhatsApp, and Telegram

Breach & Liability: Any breach and customer complaints will be the merchant's liability and may result in penalties.

• Services must not be made live without explicit authorisation from Infomedia comnfirming that the service has been approved and licensed by the regulator(s).
• Services must not be promoted via SMS campaigns without explicit consent from Infomedia and must only be operated via the Infomedia SMS platform to ensure full compliance with the NCC 'Do Not DIsturb' list (users who have opted out of marketing messages at a carrier level). Breaches of the DND list or any other unathorised SMS marketing messages may attract a fine of up to £3000 per day together with service suspension.
• Attempting to subscribe users to a service not via the approved flow may result in immediate expulsion from the market, base deletion with full refunds to end users and regulatory penalties.
• Failure to comply with customer support policies may result in suspension of services and regulatory penalties.
• Failure to provide service/content may result in forfeiture of service revenue for the month in which non-compliance ocurred.

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.

• 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.

• Service Registration: Before a service can be submitted to a carrfier for approval, service providers and services must be registered online with the regulator OfCom (Infomedia can provide support with this process)
• 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

• 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.

• Prohibited service types: Cloud storage / religion based / health related (which provide or recommend treatments) / Job related / VOIP based services
• 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.

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