Campaign Guidance - Switzerland

Switzerland Campaign Guidance

Please take note of the regulator in Switzerland - The Federal Department of Environment, Transport, Energy and Communications (DETEC)

Campaign

When creating a campaign in Switzerland, you should:

  • Be clear and transparent about the product or service the consumer is about to purchase.
  • Ensure all promotional material, messages and content are displayed in the local language.
  • Be upfront and clear about the costs to the consumer before they make a purchase. The price will need to be displayed with the total and the per message cost breakdown, for example:

“15 CHF per week, which is sent as 3 messages x 5 CHF”

Please note that you cannot bill more than 15 CHF on Sunrise, so this will need to be displayed on your campaign as well, for example:

"15 CHF per week on Sunrise, billed via 1 message"

  • Make consumers aware of exactly how and by what means they will receive the product or service.
  • Be very clear about how the consumer can opt-out or otherwise cancel the service. The word STOPP must be displayed in capitals.
  • Include the name of the service provider on the landing page.
  • Include a Full Terms and Conditions link, which is visible on the web page. 
  • Include a customer care phone number .
  • Clearly state if it is a subscription service.

Please note that the billing is slightly different, depending on which network the user is on:

  • Swisscom & Salt - Max billing is 15 CHF a week, billed as 3 separate messages (3 messages x 5 CHF).
  • Sunrise - Max charge of 15 CHF. Only allows billing once per period; daily, weekly or monthly subscriptions.


Marketing

There are several different marketing methods available in Switzerland, however you must ensure that you do not mis-lead consumers, advertise a service using an unrelated banner or state that something is free, when that is not the case. You will need to provide our Compliance Team with information on your marketing plans, along with copies of any banners that you intend to use.

If you plan to use the customer's details to market to them in the future, you must gain permission from the user and ensure that you provide them with a clear and simple method to opt-out. 


Opt-in Flows

There are two options that you can use in Switzerland, therefore you need to review them and think about the flow that best suits your service.  Details for the two flows are below:

Option 1: The most popular flow to use is the MSISDN web entry:

  1. A MSISDN entry box is displayed on the landing page, along with the price and regulatory information mentioned above.
  2. The consumer enters their phone number (MSISDN).
  3. A new page is displayed, known as the Confirmation page. This includes the keyword and short code instructions. This should look the same as the first page (include the price, terms and regulatory information etc) but the keyword and short code are in place of the MSISDN entry box.
  4. The user must be sent the double opt-in/confirmation message, this also includes the keyword and short code.
  5. The consumer sends the required keyword “START ABO” in reply to the message received.
  6. The free welcome message can then be sent, followed by the billed messages.

Option 2: The other flow is the MO opt-in, however this requires the consumer to send two MOs:

  1. The landing page is displayed which includes the required regulatory information along with the keyword {chosen by you} and short code.
  2. The consumer  follows the instructions on screen and sends your chosen keyword to the required short code.
  3. In reply to the above, the user must be sent the double opt-in/confirmation message, which includes a second keyword that must be sent to the short code.
  4. The consumer sends the second, required keyword “START ABO” in reply to the double opt-in/confirmation message received.
  5. The free welcome message can then be sent, followed by the billed messages.


Message Flow

There are strict rules regarding the messages that will be sent to the customer during the subscription process. On Sunrise you can only send one message per billing period, for example in a weekly subscription you can only send one billed message per month. However, on Salt and Swisscom you can send multiple messages per week.

Double opt-in: Before the activation of the subscription, the customer must be sent a free notification — or double opt-in request, with the following information. The user must receive and respond to this message.

Keyword "JA" for SALT & SUNRISE

Keyword "START ABO" for SWISSCOM - For convenience, we would suggest using START ABO [keyword] for all networks

  • DE - Bitte bestätige das Abo mit START ABO {keyword} an {shortcode}. {Price} CHF + GPRS Geb. {number of SMS} SMS / Woche. Abmelden: STOPP an {shortcode}. Hotline: 08********
  • EN - Please confirm the subscription with START ABO {keyword} an {shortcode}. {Price} CHF + GPRS fee. {number of SMS} SMS / Week. Log out: STOP to {shortcode}. Hotline: 08********

Welcome: The user must receive the welcome message in the below format to confirm that the subscription is now activated.

  • DE - Wilkommen im {service name} SMS Abo! {Amount of messages} mal pro Woche bekommst du SMS mit {description}. Abmelden mit STOPP an {shortcode}. {Price} CHF / woche.
  • EN - Welcome to the {service name} SMS subscription! {Amount of messages} times a week you get SMS with {description}. Log out with STOP to {shortcode}. {Price} CHF / week. 

Billing: There is no set format, however you must ensure that you include the service name and end the message with instructions informing the customer how they can stop / opt out of the service. For example:

  • EN - Service name. {Content here}. STOP: {shortcode}
  • Alternatively, you can send a separate free message to the customer with stop / opt out details.

Reminder:

  • These are not required.

Stop (STOPP): A confirmation message must be sent when the consumer cancels the service.

  • DE - Du bist vom SMS Abo jetzt abgemeldet {service name}. {You can include instructions on how to opt back in here, if you wish. The price must be included}
  • EN - You are now logged out of the SMS subscription {service name}.

Customer care / Refund Policy

All service providers must have a detailed Customer Care Process and Refund Policy in place.
You need to ensure that the process is in place for consumers to gain help should they require it, along with a refund policy for those that require one or are eligible for one.

This will be discussed in detail, to ensure that our customer care team can resolve any queries that are received from the networks or regulator.

Question? Speak with our Compliance Team for any advice for this or any other market.