Context
"As part of the new Fair Consumer Contracts Act,[1] Germany will soon require specific cancellation/termination mechanisms for consumer subscriptions. These mechanisms come on top of the updated EU-wide consumer contract rules under the EU Directives on Contracts for Digital Services and Content and on Contracts for the Consumer Sale of Goods and will take effect on July 1, 2022."
Businesses offering subscriptions to German consumers will have to provide a specifically labeled button for their online retail channels that leads to a contact form through which consumers must be enabled to cancel existing subscriptions with the click of only one further button. If sufficient data to identify the subscription to be canceled is entered by the consumer, the submission of the form will itself be a valid cancellation, the effect of which cannot be made subject to further steps such as logins or second factor (e.g., email, app) confirmations.
The solution, therefore, requires the following;
- Certain online channels through which consumers can enter into subscriptions will have to prominently feature an omnipresent button labeled “Terminate contracts here” (Verträge hier kündigen).
- Operating the “Terminate contracts here” button must lead directly to a form where the consumer can enter (i) identifying information on the person of the consumer and the contract that they intend to terminate (e.g., consumer name, contract/customer number etc.), (ii) information as to the type of termination that is sought (i.e., for cause or for convenience), (iii) an intended subscription end date, as well as (iv) an address for the provider to send an electronic submission receipt to.
- The page with the aforementioned form must contain a second button labeled “terminate now” (jetzt kündigen). Operating this button must directly submit the form content.
- Provided that sufficient data was entered, the submission will be a valid termination, which cannot be made dependent on further steps such as logins or second factor (e.g., email, app) confirmations.
- The provider will also have to immediately confirm the submission electronically to the address provided for such confirmation in the form.
(https://www.mofo.com/, May 2022)
Actions
The product team proposes that the Customer Success agents manage the change in the following way;
- Inform the customers about the required actions
- Customer should choose a preferable way of publishing the form provider tool that provides the following functionality (Wordpress forms, etc)
- Customization of the fields in the web form available for public access
- Provides ability to (re)name the submissions button to “Jetzt kündigen”
- Automatically sends the email to “submitter” as a confirmation that the termination request was received
- Include the “Verträge hier kündigen” link to her ticketshop footer
Customers institutional website manager should include “Verträge hier kündigen” link (can be in the footer) of the institutional page – usually not a Secutix provided website, but we imagine they might want to go live with the same link on the ticketshop and institutional page at the same time
