Strex Merchant Code of Conduct

Transcription

1 Strex Merchant Code of Conduct 1 General Marketing Requirements Based on the Marketing Control Act Information Required Before a Payment Transaction is Completed Entering Into and Completion of an Agreement Processing of Payment Transactions General Requirements Customer s Age Re-use of Mobile Phone Number Use of the Send SMS Function Specific Terms for the Strex SMS Payment Product General Receipt Specific Terms for All Subscription Services Specific Terms for Fixed Subscription Services Specific Terms for Chat and Other Variable Subscription Services Specific Terms for the Direct Payment Product Restriction for Certain Business Model Authorization of Payments General Single Payment Pre-Authorized Payment Subscription Payment Receipt Check of Validity of the Strex Payment Service for a Customer Customer s Right of Cancellation Customer Service Other Guidelines Version 1.2 Page 1 of 10

2 1 General The Merchant is obliged to comply with all applicable Norwegian laws and regulations in connection with the Merchant s use of the Payment Service. This includes any relevant legislation regarding consumer protection. General rules regarding consumer purchases are, i.a., set out in the following statutes: the Consumer Purchases Act of 21 June 2002 (forbrukerkjøpsloven), the Marketing Control Act of 9 January 2009 (markedsføringsloven), the Right of Cancellation Act of 20 June 2014 (angrerettsloven), the Personal Data Act of 14 April 2000 (personopplysningsloven), the E- Commerce Act 23 March 2003 (e-handelsloven) and the Guardianship Act of 22 April 1927 (vergemålsloven). 2 Marketing Requirements Based on the Marketing Control Act 2.1 Active Consent Merchants can as a general rule only distribute marketing material via SMS, etc. to Customers that have actively consented to receive such marketing messages. Consent can only be obtained by the Customer actively providing it after having been informed what such consent entails. This applies irrespective of whether an attempt is made to obtain consent from children or adults, cf. the guidelines on obtaining and using personal data 1. If the consent to marketing is obtained through written registration (for instance on the internet), the Customer must be informed directly on the screen about what he is consenting to. It is not sufficient that the information is provided by a link for the Customer to access. Furthermore the Customer actively has to tick off in a box or similar to signal that he is consenting to receive marketing information. When asking whether a Customer wishes to consent to receive marketing, e.g. by SMS, it is important to be aware of the fact that children and young people themselves cannot consent to receive direct marketing by , SMS, MMS etc. before the age of 15. Merchants cannot transfer their right to send marketing information to Customers to other tradesmen without the Customer having freely given an informed and explicit consent to the transfer. The Customer must be able to withdraw his or hers consent at any time by sending the text message STOPP REKLAME to the short number that is distributing the marketing or product information material. All receipts sent to a Customer who has used the STOPP REKLAME command shall be free of charge. The purchase of goods or services may not be conditional on the Customer consenting to receiving advertising by SMS, MMS, etc. Luring Customers with access to free goods or services in exchange for consenting to receiving advertising messages can be illegal in certain cases. Each concept/marketing measure must be assessed specifically to determine whether such an approach can be allowed. 2.2 Established Customer Relationship If a Merchant wants to distribute marketing material via SMS or MMS without obtaining the Customer s active consent to receive such marketing messages, a Customer relationship between the Customer and the Merchant must have been established. The following applies to marketing of goods or services based on a Customer relationship: Establishing Customer relationship A Customer relationship can only be established when payable purchases/transactions are made from the same Strex SMS Short Number or mobile service portal in accordance with the following criteria: One-time-use services: Three single purchases must be made within a period of 30 days for a Customer relationship to be established. Fixed subscription services: A Customer must subscribe to a service for 30 consecutive days in order for a Customer relationship to be established. Chat and other variable subscription service: The Customer must have made purchases on two separate, discontinuous days within a 30-day period before a Customer relationship is established. 1 Lov om behandling av personopplysninger (Nr. 31 av 14. april 2000): Version 1.2 Page 2 of 10

3 Notification of the establishment of a Customer relationship Before a Customer relationship is established and before any marketing or product information can be distributed, the Customer must be notified via SMS that a Customer relationship has been established, what such relationship entails and information on how to give notice if the marketing or product information is not wanted. Duration of a Customer relationship A Customer relationship should last no longer than 60 days after the final payable transaction. If the Customer has not been active for 60 days, the Customer must be automatically removed from any address lists and should receive no further marketing or product information thereafter. Discontinued marketing in an established Customer relationship A Customer in an established Customer relationship should be able to stop any marketing material received by sending a STOPP REKLAME message to the short number that is distributing the marketing or product information. All distribution of marketing messages shall then immediately cease, and before another Customer relationship can be established, the Customer s telephone number shall be quarantined for a period of at least 6 months. All receipts sent to the Customer after using the STOPP REKLAME command shall be free of charge. Marketing in connection with a Customer relationship When distributing marketing based on an established Customer relationship, only marketing messages for products/services similar to those the Customer has previously purchased can be delivered. Goods or services with an age limit shall never be considered similar to goods or services without an age limit. If the marketing is of an erotic nature, the Customer must meet the requirements for a Customer relationship involving the purchase of erotic goods or services. Price on text messages All advertising messages, newsletters, information and receipts related to marketing shall be free of charge for the Customer. 3 Information Required Before a Payment Transaction is Completed 3.1 General All marketing directed towards Customers must be drawn up in a clear manner, so that it is not misleading or provides insufficient information. The marketing must give the Customer the information the Customer has a reason to expect to receive. This means that the Customer must be informed of all important terms and conditions that are linked to the purchase before the Customer decides to enter into the agreement. Goods or services shall not be marketed towards children and young people if they are unsuitable for this age group. This applies, for example, to services with frightening, violent, erotic/pornographic content etc. 3.2 Information to be Provided in the Marketing In all marketing of goods or services, including advertisement in magazines, , SMS, TV, internet and boards, the following information must at a minimum be provided in a clear and precise manner: 1. The price of the service. 2. The name of the Merchant. 3. If it is a subscription service, the following information shall be provided in a clear and precise manner: that the service is a subscription, by using the word abonnement. The service must not be marketed as a one-off service if it in fact is a subscription service 2. that delivery of the services will be on a continuous basis whether the agreement is for a limited period of time or for no determined period whether the subscription is e.g. per day or per month, and whether the subscription is renewed automatically whether the right to use services that the Customer has paid for but not used will expire when the subscription is renewed if the price is per message received, the number of messages the Customer can expect to receive. If this is not possible, the expected number of messages must be given. This applies for instance to chat services, alert services, quiz or similar. the price of the goods or services that are delivered pursuant to the subscription 2 The marketing should not focus on the Customers choice to e.g. buy one single Ringtone, when the service in fact is a subscription service. Version 1.2 Page 3 of 10

4 4. Any age limit on use of the service. 5. The contact details and phone number to the Merchant s Customer service or of the company responsible for handling questions regarding the service. 6. Which phone and, if relevant, which configuration, is required for the Customer to receive the correct content. 7. If tracking of the position of the Customer is part of the Merchant s service, the Customer must be informed of this in the marketing material. In addition, the Merchant of the tracking service is required to obtain the Customer s consent for the use of positioning services and comply with the terms of the Personal Data Act. 3.3 Requirements regarding Presentation of Information In all marketing the information in section 3.2 must be horizontal, clear and easy to read when it comes to size, colour and location. All major terms for the service, including price and subscription terms must always be notified with equal or similar communicative effect as the short number. The same requirements apply if the Customer has to fill in his mobile telephone number to order the service. On TV, text-tv, internet and other similar marketing channels, the price information must be presented for at least as long as the short number or the area for the filling in the mobile number, and in direct relation to it. The pricing details must be presented on the same screen as the short number or the area for filling in the mobile number. Such information must not be hidden between other terms etc. On radio, on the phone and similar marketing channels, the information mentioned in section 3.2 must be given clearly when providing information about, or referring to, a good or service. TV and radio advertising may not specifically target children, cf. 3-1 of the Broadcasting Act. 4 Entering Into and Completion of an Agreement For an agreement of delivery of goods or services to be valid, the Customer must have received the information listed in section 3 in a clear and precise manner prior to delivery of the good or service in connection with the purchase order process. 5 Processing of Payment Transactions 5.1 General Requirements The Merchant shall use the relevant Service Code parameter that applies to the particular good or service in question when executing a Sell request by use of the Payment Service, cf. the guidelines set out in the Implementation Guide. A Merchant cannot charge for delivery of a good or service through several transactions. The Merchant must therefore only charge the Customer once. For example, Merchants cannot use several transactions to exceed the maximum amount limit, ref. Merchant Agreement Appendix 1. In situations where the Merchant charges the Customer a fee for paying with the Payment Service in addition to the purchase price of the good or service, this fee shall not be given a name that can be correlated with Strex, the Strex Payment Service or the Customer s MNO. The fee can for example be named service fee (serviceavgift) or administration fee (administrasjonsavgift). If the mobile prepaid account connected to the Strex account of the Customer is empty or the mobile phone subscription has been temporarily barred, the Merchant must cancel the payment transaction and not attempt to conduct a payment transaction or redelivery until the Customer has ordered a new service. However, where subscription services are concerned, the Merchant may make several attempts while the subscription is active, but only one attempt per day per Customer. If the Merchant has not been able to charge the Customer for a service when a subscription period expires, the Merchant cannot transfer any outstanding charges from the previous period. If the Merchant is unable to charge the Customer for a service within a period of two months after the initial attempt, the Customer must be removed from the service, see section 5.3. If the subscription is permanently barred the Customer must be removed from all services, see section 5.3. Version 1.2 Page 4 of 10

5 The Merchant must inform the Customer of the price for help and error messages if they are not free of charge for the Customer. The maximum price for an SMS containing help or error messages or other general information shall be NOK Customer s Age The Merchant shall classify the good or service according to minimum age and make checks with Strex to control the age of the Customer. If the age control shows that the Customer is under the required age for the service, the payment transaction will be stopped by Strex and the good or service shall not be delivered to the Customer. The Customer shall receive an information message with reference to the Customer s age as a reason for rejected delivery. For example: You are not old enough to use this service or your mobile operator does not have information about your age. Contact your mobile operator for registration of correct age. The Merchant shall ensure that goods or services unsuitable for the Customer s age are not sold. This applies to e.g. frightening, violent, erotic/pornographic services. The Merchant shall classify the good or service paid for according to the applicable minimum age using the Age parameter in the payment transaction. For further details, please refer to the Implementation Guide. If the age control shows that the Customer is under the required age for the relevant service, the payment transaction will be stopped by Strex. The minimum age requirement for payment of subscriptions is 18 years. 5.3 Re-use of Mobile Phone Number To prevent sending new Customers messages targeted to previous owners of a phone number, the Merchant must terminate all subscriptions and delete all Customer information if feedback from Strex indicates that the Customer has been permanently barred, or if the Merchant has unsuccessfully attempted to fulfil a payment transaction to the Customer over a period of 60 days. Of this reason the Merchant cannot charge a Customer or distribute subscription or marketing messages to a Customer if the Merchant has not had a successful payment transaction or message delivery in the past 60 days. 6 Use of the Send SMS Function The Merchant shall ensure that the Merchant s use of the Send SMS function on the Strex platform (i.e., to send SMS messages to mobile phones) is in compliance with applicable Norwegian laws and regulations, in particular the Marketing Control Act of 9 January 2009 (markedsføringsloven) and the Electronic Communications Act of 4 July 2003 (ekomloven). 7 Specific Terms for the Strex SMS Payment Product 7.1 General When a Customer orders a good or service from a Strex SMS Short Number, the good or service and all related messages must be delivered via the same Strex SMS Short Number. The Merchant can only transfer the Customer from one Strex SMS Short Number to another or use multiple Strex SMS Short Numbers if the Customer has been informed in advance, and as long as there will be no consequences to the Customer. 7.2 Receipt The Merchant shall upon successful processing of the payment transaction from Strex, issue a receipt to the Customer for the purchase. The receipt shall at a minimum contain the following information: The company name of the Merchant A description of the good or service purchased The purchase amount in NOK (incl. VAT) The Customer support telephone number of the Merchant The receipt shall be delivered via the Strex SMS Short number used to process the payment transaction. Version 1.2 Page 5 of 10

6 The Merchant shall upon request from the Customer issue a receipt with the information above and send to the Customer by SMS, or postal mail. 7.3 Specific Terms for All Subscription Services Information messages Customers ordering subscription services shall immediately receive an information message beginning with the word Abonnement (Subscription). All necessary information linked to the service and all key terms must be included in the information message, including the following information: The service can be stopped at any time by sending an SMS with the code word STOPP. The duration of the subscription. The price of the service. How often the subscription is charged (daily, weekly or monthly). Whether the subscription is renewed automatically or not. The phone number to the Merchant s Customer service. Other key terms and conditions must also be mentioned. A link to another information source that is not automatically available from the mobile phone, e.g. Internet or text-tv, is not sufficient, but may be added to the information above. Example: Welcome to ABC film service. NOK 50,- per month. The subscription is renewed each month until termination notice is given. Send STOPP to 2438 to stop this service. Customer service Stop command The Customer must be notified that the service can be stopped by sending the message STOPP to the same short number that the service was ordered from 3. The code word STOPP must be used in all marketing for information about how to stop a subscription service. The Customer must be able to stop any subscription service by sending the message STOPP to the Strex SMS Short Number the service has been delivered from. It shall be irrelevant whether the Customer uses upper or lower case letters in the stop message. When the Merchant has received such STOPP command, the Merchant must immediately stop the subscription. If several subscriptions are active, the Merchant must send the Customer an SMS listing the active subscriptions and information about how the Customer can stop each service by SMS. Customers who terminate a subscription must receive confirmation of such termination. If the Merchant receives the code word STOPPALLE, STOPALL, STOPP ALLE or STOP ALL, the Merchant must immediately stop all subscriptions for the Customer that sent the message, without further discussion with the Customer. Confirmation of order SMS and delivery (applicable to the Strex SMS Product only) The Customer shall first receive the information SMS with terms and conditions (as defined). The Customer must then send a confirmation of order SMS to the short number that is used for charging/service delivery. If the Customer does not send the confirmation of order SMS, the subscription service shall not be started/activated and no further messages shall be sent to the Customer before he/she makes a new order (new order requires same procedure with information SMS and confirmation of order SMS). Failure of delivery If the Merchant has not had any successful delivery of message or payment transaction within the last 60 days, the Merchant must not send marketing or subscription messages to the Customer. In such cases, the Merchant shall erase all Customer information and stop all existing subscriptions of the Customer. Age limit on use/buying of subscriptions is 18 years old Specific Terms for Fixed Subscription Services Examples of fixed subscription services are subscriptions on digital content or a physical service where the Customer pays a fixed amount per week or per month. 3 See the Ecom Regulation 5a-2 third paragraph Version 1.2 Page 6 of 10

7 At each automatic subscription renewal point, the Customer shall be given information about: The service The Merchant s customer service How to terminate the service How often the subscription is charged (daily, weekly or monthly) Whether the subscription is automatically renewed or not The price for the good or service A fixed subscription service is renewed automatically every time the Customer receives a message from the Merchant that the Customer is charged for. The Customer may terminate the service after every message received Specific Terms for Chat and Other Variable Subscription Services Examples of variable subscription services are for example chat, notifications or competition services where the number of messages the Customer receives can vary. When the Customer has received 20 messages since the last information message was sent, the Merchant must send a new message with the same information, cf. the requirements set out in section 7.3. A chat service cannot cost more than NOK 30 per message. Scope Only a limited amount of messages can be sent to a Customer within a short interval (e.g. no more than 4 messages received per minute). To prevent this, the Merchant must be able to offer services where the Customers receive a limited number of messages within a specific period of time. Automatic stopping of the service If a Customer has received more than 20 messages since the Customer last sent a message, the Merchant must stop the service immediately. The Customer must then enter into a new purchase agreement if he or she wants to continue using the service. If there is a variable subscription service with a limited number of messages, e.g messages per week, it is not necessary to terminate the service after 20 messages. 8 Specific Terms for the Direct Payment Product 8.1 Restriction for Certain Business Model The Direct Payment product cannot be used for processing of payments using the business model Mobile Content Services Authorization of Payments General Before the Merchant executes a payment transaction using the Payment Service, the Merchant is obliged to check that the Customer is in possession of the mobile terminal that is connected to the mobile subscription being charged, by performing the SMS verification process described in sections to The SMS verification shall be performed using a 4-digit Strex SMS Short Number using the Send SMS function of the Strex platform. There are specific requirements for the different payment types single payment, pre-authorized payment and subscription payment, described in the following chapters. Strex plans to replace the SMS verification process as set out herein with a simplified integrated authorization method. The Merchant will be informed with two (2) months prior written notice before such new authorization method is launched under new terms and conditions which shall replace these terms from such point in time Single Payment Single payment transactions are payments that are processed as an independent payment transaction for a single purchase. Version 1.2 Page 7 of 10

8 The single payment transaction shall follow the flow described below: 1. The information about the Merchant s goods or services is displayed to the Customer on the Merchant s web site or in the Merchant s app, and the Customer actively accepts the terms and conditions. 2. The Customer enters his mobile phone number and clicks «pay» or similar. 3. The Merchant shall send the customer an SMS with a 4-digit code (one-time password) to verify that the Customer possesses the mobile terminal that is connected to the mobile subscription being charged. The text shall include the following text: «[XXXX] er din kode for å bekrefte betaling til [Merchant name].» The Merchant shall replace [XXXX] with the 4-digit code and [Merchant Name] with the name of the Merchant. The message shall be sent from a Strex SMS Short Number. 4. The Merchant shall request the Customer to enter the 4-digit code from the SMS message in the app or the web page of the Merchant and shall inform the Customer that he hereby confirms that the payment to the Merchant will be processed by Strex AS and will be charged the mobile invoice («Norwegian: mobilfaktura») of the Customer. 5. The Customer enters the 4-digit code in the Merchant app or webpage. 6. The Merchant shall send a sell request towards the Strex platform. 7. Strex processes the payment and gives the Merchant a reply from the Payment Service. 8. The Merchant displays a receipt for the payment to the Customer in the app or web page Pre-Authorized Payment Pre-authorized payment transactions (in Norwegian: forhåndsgodkjente betalinger) are multiple payment transactions that are processed on the basis of an earlier authorization given from the Customer to the Merchant to allow the Merchant to charge for future delivery of a particular type of goods or services from the Merchant without a specific verification for each payment. The Merchant is obliged to document the earlier authorization given from the Customer to the Merchant upon written request from Strex. The pre-authorized payment transaction shall follow the flow described below: 1. The information about the Merchant s goods or services is displayed to the Customer on the Merchant s web site or in the Merchant s app, and the Customer actively accepts the terms and conditions. 2. The Customer registers with the Merchant by entering his mobile phone number. 3. The Merchant shall send the Customer an SMS with a 4-digit code (one-time password) to verify that the Customer possesses the mobile terminal that is connected to the mobile subscription being charged. The text shall include: «[XXXX] er din kode for å bekrefte fremtidige betalinger til [Merchant name].» The Merchant shall replace [XXXX] with the 4-digit code and [Merchant Name] with the name of the Merchant. The message shall be sent from a Strex SMS Short Number. 4. The Merchant shall request the Customer to enter the 4-digit code from the SMS message in the app or the web page of the Merchant and shall inform the Customer that he hereby confirms that future payments to the Merchant will be processed by Strex AS and will be charged the mobile invoice («mobilfaktura») of the Customer. 5. The Customer enters the 4-digit code in the Merchant app or webpage. 6. The first and subsequent payment transactions are processed by the Merchant by sending a sell request to the Strex platform. 7. The Merchant gives the Customer a receipt in a channel the Merchant prefers, e.g. web page, app, or SMS. If the time since last successful payment transaction is over 60 days, the Customer phone number must be verified by the Merchant using a one-time SMS password as described above in this chapter, before any new payment request can be sent to Strex Subscription Payment Subscription payment transactions (in Norwegian: abonnementsbetalinger) are multiple payment transactions that are processed on the basis of an earlier authorization given from the Customer to the Merchant to allow the Merchant to charge for future delivery of a particular type of goods or services from the Merchant without a specific verification for each payment. The Merchant is obliged to document the earlier authorization given from the Customer to the Merchant upon written request from Strex. The subscription payment transaction shall follow the flow described below: 1. The information about the Merchant s goods or services is displayed to the Customer on the Merchant s web site or in the Merchant s app, and the Customer actively accepts the terms and conditions. 2. The Customer registers with the Merchant by entering his mobile phone number. 3. The Merchant shall send the Customer an SMS with a 4-digit code (one-time password) to verify that the Customer possesses the mobile terminal that is connected to the mobile subscription being charged. The text shall include: «[XXXX] er din kode for å bekrefte abonnementsbetalinger til [Merchant name].» The Merchant shall replace Version 1.2 Page 8 of 10

9 [XXXX] with the 4-digit code and [Merchant Name] with the name of the Merchant. The message shall be sent from a Strex SMS Short Number. 4. The Merchant shall request the Customer to enter the 4-digit code from the SMS message in the app or the web page of the Merchant and shall inform the Customer that he hereby confirms that future subscription payments to the Merchant will be processed by Strex AS and will be charged the mobile invoice («mobilfaktura») of the Customer. 5. The Customer enters the 4-digit code in the Merchant app or webpage. 6. The first and subsequent payment transactions are processed by the Merchant by sending a sell request to the Strex platform. 7. The Merchant gives the Customer a receipt in a channel the Merchant prefers, e.g. app, web page, or SMS. The Merchant shall provide the Customer with an easy method to stop the subscription (and consequently, any future payments) to the Merchant, in the app or web page where the subscription agreement was entered into by the Customer. If the time since last successful payment transaction is over 60 days, the Customer phone number must be verified by the Merchant using a one-time SMS password as described above in this chapter, before any new payment request can be sent to Strex. 8.3 Receipt The Merchant shall upon successful processing of the payment transaction from Strex, issue a receipt to the Customer for the purchase. The receipt shall at a minimum contain the following information: 1. The company name of the Merchant 2. The date of the purchase 3. The mobile telephone number of the Customer (MSISDN), or another reference identifying that the payment is made by use of Strex Payment Service 4. A description of the good or service purchased 5. The purchase amount in NOK (incl. VAT) 6. The Customer support telephone number of the Merchant If the receipt is sent by SMS immediately after the payment to the mobile phone number charged, the information in number 2 and 3 above can be omitted, as this is integrated in the SMS message. 8.4 Check of Validity of the Strex Payment Service for a Customer If the Merchant wants to check the validity of the Strex Payment Service for a particular Customer (e.g., check that the Customer is not barred from using the Payment Service), the Merchant shall initiate a sell transaction of NOK 1,00 and immediately thereafter reverse the same transaction. The Merchant shall inform the Customer about this charge and that this is done to validate the Payment Service account of the Customer and that the charge will be reversed. 9 Customer s Right of Cancellation The Merchant shall at all times comply with the Act of 20 June 2014 relating to Right of Cancellation (the Right of Cancellation Act) in connection with the marketing and supply of its goods and services to Customers. This includes providing Customers with adequate information regarding their statutory cancellation right in connection with purchase orders as well as granting the Customers such rights as are prescribed to them by such law. 10 Customer Service The Merchant is obligated to provide Customer service for all goods and services offered via the Strex Merchant agreement, including questions related to marketing, ordering, delivery and payment, cf. the Agreement clause 8.5. Customers must be able to reach Customer service for all goods and services delivered via the same Strex SMS Short Number at one shared phone number. The Merchant must handle Customer service directly and cannot forward Customer service calls. Complaints must be processed within a reasonable period of time after the complaint is received. All complaints must be processed individually based on the particular facts in the relevant case. If the complaint is rejected, a minimum requirement is that the grounds for the decision is explained, and that the complainant s arguments are answered as fully as possible. Version 1.2 Page 9 of 10

10 Reference is moreover made to the Agreement clause 8 regarding the Merchant s responsibility in connection with Customer complaints. Customer service must communicate in Norwegian. This language requirement applies to the communication with the Customers as well as to any communication with Strex or the MNOs in relation to inquires or complaints from Customers, cf. the Agreement clause 8.8. In the latter event, Strex or the MNO may require that the Merchant s Customer service at its own cost prepares a draft response to the inquiry or the complaint from a Customer, for Strex or the MNO s review. It is however understood and agreed that any verbal communication between the Merchant and Strex or the MNO directly, and any written communication between the Merchant and Strex or the MNO directly which does not concern a Customer request or a Customer complaint, can be in English. The customer service centre s opening hours must be at least from (local time) on weekdays. Information about the opening hours must be given to Customers when Customers call the number outside the customer service centre s opening hours. For example: Kundeservice: , åpent ukedager If the Merchant receives the SMS code words HJELP, HELP, KUNDESERVICE, CUSTOMERSUPPORT, CUSTOMER SUPPORT or SUPPORT sent to Strex SMS Short Numbers used by the Merchant, the Customer must receive an information message with information about the Merchant s Customer service including address, phone number and opening hours. The price of the information message must be maximum NOK 1. The Customers costs associated with contacting customer service shall not exceed the national regular mobile network call rate in Norway at any time. 11 Other Guidelines Strex recommends the Merchant to comply with the relevant current guidelines of the Norwegian Consumer Ombudsman (Forbrukerombudet) at any time. Strex can upon reasonable written notice to the Merchant demand that the Merchant takes immediate measures to ensure compliance with particular relevant guidelines of the Norwegian Consumer Ombudsman. Please find additional information on the following web sites: Version 1.2 Page 10 of 10