Mobivate's Customer Care Policy

1. In accordance with the PSA’s Code, 1 Mobivate has developed this policy to ensure that its processes and procedures regarding customer care are clearly set out for the benefit of consumers/end users, Mobivate’s employees and its customers.

2. Mobivate is keen to ensure that end users do not have to expend undue time, effort or money when submitting enquiries, pursuing complaints and/or seeking refunds from providers of premium rate services (i.e., merchant/service providers).

3. This policy sets out Mobivate’s approach to the management of: a) Customer care and complaint handling; b) The provision of information regarding merchant providers to end users; c) The processing of refunds; d) The tracking of complaints and refunds; and, e) Ongoing assessments of risk.

4. Failure to comply with this policy by Mobivate staff is a disciplinary offence.

A. Customer care and Complaints handling

5. Mobivate is committed to ensuring that end users are treated fairly and with respect, which – as outlined above - includes Mobivate ensuring that their enquiries and complaints are dealt with promptly and efficiently.

6. Mobivate can receive enquiries or a complaints via the following mechanisms: a) Direct contact from end users via phone call or email; or b) From the network carrier or intermediary that provides services to Mobivate.

7. Where an end user contacts Mobivate, and we suspect that we may be speaking with a vulnerable user, we will ensure that the end user is treated in accordance with the Vulnerable Persons policy.

8. Where an end user contacts Mobivate in accordance with paragraph 6a), Mobivate will take a record of the customer’s name, contact details and a summary of the enquiry or complaint which will be logged on our systems for monitoring purposes, and we will provide the end user with the information outlined in the section B below either via the phone, or in writing using email or SMS. The method of sharing this information will be agreed with the end user in advance.

9. Where Mobivate receives information regarding an enquiry or complaint from an end user via an intermediary provider or network operator as set out at paragraph 6b), Mobivate will record the contact details and complaint information provided, send the relevant information to the user via email or SMS, and also advise the end user that the merchant provider will be in touch. Mobivate will then pass on the relevant contact details to the merchant provider for them to manage the enquiry/complaint4 and any associated refund.

10. Mobivate is committed to ensuring that its processes relating to customer care and complaints do not cost the end user any more than the basic rate of a call or text.

11. The processes outlined at paragraphs 8 and 9 above will be undertaken in a timely manner. In the first instance, Mobivate will provide the information to the end user and pass on the relevant information (where needed) to the merchant provider within 24 hours of receipt, which will ensure that the merchant provider can provide an initial response to the end user within five working days5 of the enquiry or complaint being made. It will be the merchant provider’s duty to ensure that the end user is kept up to date with regards to the status of any complaint, and any associated refund requests.

12. Once this information has been passed onto the merchant provider, Mobivate will engage with the merchant provider to obtain updates and to ensure that any complaints are resolved promptly and in any case within 30 working days of the initial contact.

13. In the event that the complaint is not resolved to the end users’ satisfaction and they get in contact with Mobivate again, Mobivate will follow the refund process set out in section C below.

14. For the avoidance of doubt, Mobivate’s contact centre is open 24 hours a day, 7 days a week, 365 days a year.

B. Providing information to end users regarding merchant providers

15. Mobivate, where required, will provide end users with clear information which will assist them with contacting their service (i.e. merchant) provider that has provided the PRS to the end user.

16. The information that Mobivate will provide includes the merchant provider’s: a) name as registered with the PSA and details of the service the consumer has been charged for (where such details can be reasonably obtained); and b) contact details and hours of operation (including customer care details and website) noting that the PSA requires that customers be able to contact providers during normal business hours of 9am-5pm MondayFriday (excluding bank holidays) as a minimum.

17. To ensure that this information sharing happens smoothly, Mobivate will have a template ready for each customer that Mobivate contracts with the required information already populated. Upon receiving contact from an end user(s) Mobivate will share the required information with end users via: a) free to user SMS; b) email; and/or c) phone call, depending on how the end user’s issue has been referred to Mobivate (i.e., whether via an intermediary, network carrier or the end user directly) and the end user’s preference for receipt of the information.

C. Managing Refunds

18. Mobivate is committed to ensuring that end users who pursue a refund are not required to expend undue time, effort and money in doing so.11 Accordingly, in the event that an end user has been referred to the merchant provider and gets back in contact with Mobivate to advise that the issue has been unresolved, we will issue that end user with a refund, and then reclaim the money from the merchant provider by off-setting it against the revenues it is due to be paid.12 Mobivate will also remind the end user that they can contact the PSA (and supply the PSA’s contact details again) in the event that the end user wants to pursue a complaint with the regulator.

19. Mobivate will ensure that all refunds are processed (once agreed) within 14 working days, and that they use the preferred refund method of the customer when issuing it.1

D. Records of complaints and refundsS

20. Mobivate will keep records of all complaints it receives for 2 years in accordance with the PSA’s guidance on data retention.

21. Upon any request from the PSA, or other regulators with the requisite authority, Mobivate will provide all information that allows an examination of how it has handled customer care, any consumer enquiry or complaint.

E. Ongoing assessments of risk

22. As part of its compliance with the wider DDRAC requirements of the PSA’s Code, Mobivate will undertake an ongoing review of the volumes of complaints it receives, the nature of such complaints and resolution times.

23. Mobivate will review this data on a 2-weekly basis. In the event that Mobivate determines issues with the resolution of complaints or refunds in relation to a particular merchant provider, we will seek to engage with that provider to try to resolve the issue and ensure ongoing compliance with the Code

24. In the event that the merchant does not resolve the issue identified, Mobivate will use the information we have collected to update its risk assessment relating to that company. This may, in turn, lead to a decision by us to suspend or terminate services in accordance with the DDRAC policy.

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25. Mobivate’s Customer Care Department will ensure that this policy is reviewed on an annual basis.