Campaign Guidance - Slovenia

Slovenia Campaign Guidance

The regulation is done by AKOS (Agencija za komiunikacijska omrežja in storitve Republike Slovenije) the Agency for Communication Networks and Services. Mobile value added services (VAS) are regulated by mobile network operators.

Campaign

When creating a campaign in Slovenia, you should:

• Be clear and transparent about the product or service the consumer is about to purchase. The service name must be clearly displayed.
• Be upfront and clear about the costs to the consumer in Euro (€), before they make a purchase. Clearly state if it is a subscription service.
• Ensure all promotional material, messages and content are displayed in the local language - Slovenian.
• Ensure that there is a clear contrast between the font and the background colour, for example, black text on white background.
• 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 a service. The word STOP must be displayed in capitals.
• Include the name of the Service Provider and the headquarters address in the disclaimer on the landing page.
• Include a Full Terms and Conditions (Splosni pogoji) link, which is visible on all web pages. The consumer actively agrees to the Terms and Conditions when they make a payment.
• Include a customer care phone number and email address, as well as the working hours.
• You must state that we (MessageCloud) are the "Ponudnik storitve" while you, our merchants are "Izvajalec". You will need to include the company addresses for both as well. 
  
  • Ponudnik stortive = Service provider. For example;
    • Ponudnik storitve: txtNation Limited (Trading as MessageCloud), 15 Billacombe Road, Plymouth, PL9 7HX Devon, UK, ki storitve ponuja in za storitve odgovarja
  • Izvajalec = Contract/Performer 
• When networks are listed in the Terms and Conditions, you must ensure that you use their full names -
  • Telekom Slovenije
  • A1 Slovenija
  • Telemach

Specific Services

• Competitions/Quizzes/Skill Games are allowed, but only on the condition that the winning mechanism is skill based.
• Consumers must have an impact on their winning possibilities; for example, no chance or games of luck. 
• Prize-winning and other games must be according to the regulation and the Rules of the Slovenian Office for Gaming Supervision

Adult Services and Age Verification - Please note that adult services are not available for the following users:

• A1 - Adult services are blocked for all pre-paid users and for all post-paid users under 18 years of age (no activation possible)
• Telekom Slovenije - Adult services are not supported for pre-paid users, but by identifying at the point of sale (POS), the pre- paid account can be activated for adult services. Post-paid users under 18 years of age are blocked for adult services (no activation possible)
• For adult services either a dedicated Short Code, or the pre-defined tariffs have to be used
• Telekom Slovenija - Soft erotic/bikini content can be set-up on standard billing codes, all other adult services have to be set-up on special billing codes. Adult services running on those special billing codes will be unavailable for the above mentioned end-users at Telekom Slovenije.

Marketing

There are several different marketing methods available in Slovenia, 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 and all banners that you intend to use.

Opt-in Flows

• MO opt-in
• PIN opt-in: This can only be used for the network A1 Slovenija and Telemach; for online purchases and with a required tick box confirmation. PIN is not possible on Telekom Slovenija.
• Web opt-in requiring a reply: This is possible, where the consumer enters their mobile number online, into your campaign, this triggers an SMS to be sent to the consumer which contains the regulatory information and keyword, the user will need to send the keyword back to complete the subscription and start the billing. 

Mandatory keywords

• DA (YES) - this is the opt-in confirmation keyword.
• INFO - This is an information keyword, for example;

SI: Na stevilki [Short Code] ste prijavljeni na SMS-vsebin: [Klub 1] - odjava [KLUB]1 STOP; [Klub 2] – odjava [KLUB2] STOP;…, [Podjetje d.o.o], Info: [041XXXXXX]

EN: You are subscribed to SMS-texting content on [Short Code].;[Club 1] – subscribed [CLUB1] STOP; [Club 2] – subscribed [CLUB2] STOP,…. ; [Compay d.o.o]., Info [041XXXXXX]

• POMOC - Free answer MT;

SI: Ponudnik: [Podjetje d.o.o.], e-posta: [info@abc.si], Reklamacijska in kontaktna stevilka: [123456]; Delovnik: [8:00 do 17:00]

EN: Service provider: [Company d.o.o]., [Headquarters]; email: [info@abc.s]i ; Contact phone number: [123456]; Working hours: [8:00 – 17:00]

• STOP - Opt-out of any subscription services

Opt-in Flow

The service and opt-in flow can vary slightly depending on the network that the consumer is on. Please note that you do not receive a MO notification for each network.

A1

1. The consumer enters their mobile number on the landing page
2. You call the API to start the web flow process
3. A1 sends the double opt-in confirmation message, which includes the instructions for the consumer to complete the opt-in, e.g. send DA to the short code.
4. Consumer sends DA  to the required short code
5. A network notification is received from A1, which is forwarded to you
6. You can then proceed with the subscription by sending the welcome message, followed by the billed message.

Telemach

1. Consumer enters their mobile number on the landing page
2. You send the free double opt-in message
3. Consumer receives the double opt-in message, which includes the keyword DA and the required short code
4. Consumer sends DA to the short code displayed in the previous message
5. A network notification is received, which is forwarded to you.
6. You can then proceed with the subscription by sending the welcome message, followed by the billed message. 

Telekom Slovenije 

1. Consumer enters their mobile number on the landing page
2. You send the free double opt-in message
3. Consumer receives the double opt-in message, which includes the keyword DA and the required short code
4. Consumer sends DA to the short code displayed in the previous message
5. We receive DA as an MO and pass this onto you
6. You can then proceed with the subscription by sending the welcome message, followed by the billed message. 

Please remember to include a 24 hour delay between billed messages for Telekom users.

Message Flow

Double opt-in: This is required for subscription services and must contain the price, service name, service provider name, link to Terms and Conditions, instructions on how to stop the service and help information. The DA (Yes) keyword must be displayed at the end of the message. For example:

• EN: You have ordered a subscription to [service name]. Offered by [Service provider name] for  xx EUR / week. To cancel send STOP to xxxxx. [Terms link] [Helpine number] To confirm the order send DA to xxxxx.

Please note that A1 sends the double opt-in confirmation message..

PIN: A1 Slovenija and Telemach only. You must provide the PIN code via a non-premium short code. The PIN must be displayed at the end of the message, it must be the last piece of infomation displayed.

Welcome: This free message must be sent free of charge, confirming the service name, service provider name, the price, payment frequency of the service, how to opt-out and helpine number. For example:

• SL: S sodelovanjem ste se prijavili na [name of service], strosek n x [price] EUR/tedensko z DDV. Odjava: STOP [keyword] na [short code]. T: [helpline], [service provider name].
• EN: You have subscribed to {name of service} for €X per week. To cancel send STOP to XXXXX. {Company name}. Help? XXXXXXX

Billing: After each purchase the consumer must receive a payment confirmation message.

• SI: Hvala za nakup [Service name]. [Service provider]
• EN: Thank you for the purchase of [Service name]. [Service provider] 

There is no set format for subscription billed messages, however you must ensure that you include the service name, content and support information, please make multiple billed messages different, so that consumes know they are meant to receive two. For example:

• EN: Message1of2. Service name. {Content here}. Help?
• EN: Message2of2. Service name. {Content here}. Help?

Reminder: This applies to A1 consumers. This is now sent by the network. For subscription services that offer online content delivery. A reminder message / bill warning must be sent to consumers that are charged more than €10 per month.

• EN: You have spent €X this month for your subscription to Club {sevice name} from {service provider}. To leave, send STOP to XXXX. Helpline XXXXXX

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

• SI: Odjavljeni ste od vseh naročenih vsebin na [Short Code]. [Provider]
• EN: You are opted-out from all services on [Short Code]. [ Provider]

On request you must be able to provide proof of opt-in to the subscription or consent for a particular user or MSISDN. You are not allowed to enter a mobile number into a service's web form more than twice within a 2 hour period. This rule must be followed even if the access to the service is enabled from different points or websites (if a service has different banners and different landing pages, this rule still applies).

Customer care / Refund Policy

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.

Slovenia Terms and Conditions

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