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)
User's journey
| 1 | 2 | 3 | 4 | 5 | 6 |
Internet users will choose | Institution landing page
Managed by SecuTix client | Click on the link opens a form in a new tab | The user will fill in the form with relevant data. An example of a form. The forms can be set by different tools including; CRM forms, WordPress forms, 3rd party tools for surveys, etc. The form needs to allow renaming the submission button to "Terminate now" at the end.
(For example; Google Forms - is not suggested to use as a form provider. Here only for demonstration purposes). | The form needs to send an email to the internet user with confirmation that the submission of the request has been successfully sent. The form functionality will record the request and the SecuTix Operator should be informed. | The SecuTix operator will open the SecuTix backoffice and find the contact in the Contacts CRM based on the information provided. The Operator will then set the criteria for "Stop renewal season ticket" to "yes". Click on the image below to see the user flow on how to set the criteria.
With this action, the contact's subscription will not be part of the renewal batch. |
Ticketshop landing page
Managed by SecuTix client with | Click on the link opens a form in a new tab |
Today it is not possible to set the same criteria mentioned above for membership renewals. This possibility will be provided in one of the Weisshorn V3 releases delivered between Avg - Nov 2022 with the earliest date possible.
Among about 10-12 clients only 1 is currently using memberships (PBS) according to our data.
In case any of the clients (including PBS) receive any termination requests for membership, we recommend they manage them in a separate list and use the criteria "Stop renewal memberships" when it becomes available.
Another possibility is to immediately terminate the membership (or season tickets) by deleting the file from the back office. With this action, the membership validity is disabled immediately. In such a scenario, the renewal for that particular contact will not happen when running the batch for the membership/season ticket subscription renewal.
Actions (TODOs)
The product team proposes that the Customer Success agents manage the change in the following way;
- Inform all German customers about the law requirements, timeline, and the impact of the required change.
- The form: Customers should choose a preferable way of publishing the form
- The Footer Link: Include the “Verträge hier kündigen” link to her ticketshop footer
2. The form
The client needs to use the type of form that enables the following functionality;
- Customization of the fields (type of data entered, e.g. text input, checkboxes, ...)
- Provides the ability to not make fields mandatory to fill
- Provides the ability to (re)name the submissions button to “Jetzt kündigen” (Google form does not allow that by default, however, it can be achieved with additional tools).
- Automatically sends the email to “submitter” as a confirmation that the termination request was received
- The listed information must be in the confirmation message
- Collects the submitted requests
The recommended form fields
- Name and Address
- Electronic contact address
- Description of a contract to be terminated
- Type of termination and justification
- Date of termination
Scroll to the end to see the example of the form or click here.
3. The Footer Link - "Verträge hier kündigen" (Service team)
Note: In case the customer success team is not comfortable applying the following changes by themselves or they face potential difficulties, this task can be transferred to the service team.
Current SecuTix functionality does not yet provide a dedicated label to enable "Verträge hier kündigen" in the footer of the ticket shop. Therefore we temporarily recommend using one of the existing labels, that is potentially not yet used by the client and renaming it to "Verträge hier kündigen".
This is not a sustainable way of achieving the goal but is necessary to comply with the law by the date 1st of July 2022. The product team will provide a dedicated label in one of the Weisshorn V3 releases delivered between Avg - Nov 2022. After that point, the client can choose to switch to new functionality or keep the one we are proposing as a temporary solution.
The wanted results in the image below;
How to rename existing labels to "Verträge hier kündigen"?
- Find the relevant Point of sale under the Organizations Sales channel
- Select Internet parameters
3. Choose one unused label that you will rename to "Verträge hier kündigen" in the next step - example: If unused, you can choose "Site map" label - and add the URL linking to a form for termination of the subscription
4. The Last step is to rename the "Site map" label to "Verträge hier kündigen"
- First, you need to find the respective internet theme settings for the ticket shop. (Organization > Sales channel > Ticket Shop > Point of sale > Internet theme > Advanced)
- example; visit https://play.int1-shop.secutix.com/content
- Then add "" to the end of the URL and you will see that the label changed to "GRAVITY.TSFOOTER.SITEMAP"
- You will have to make sure to distinguish between capitals and normal letters of the label. If you enter them incorrectly the translation will not work. To make sure that you use the accurate input you'll have to inspect the page (F12) and hover over the label to find its syntax in the code.
- Use the label "gravity.TsFooter.siteMap" and add it as a new key with a translation "Verträge hier kündigen"
- You accomplish that by clicking on "New". The new popup will require you to enter the key (gravity.TsFooter.siteMap) and the wanted translation for that label ("Verträge hier kündigen")
- Make sure you distinguish between capitals and normal letters. If you enter them incorrectly the translation will not work. To make sure that you use the accurate input you'll have to inspect the page (F12) and hover over the label to find its syntax in the code
- Make sure you distinguish between capitals and normal letters. If you enter them incorrectly the translation will not work. To make sure that you use the accurate input you'll have to inspect the page (F12) and hover over the label to find its syntax in the code
- You accomplish that by clicking on "New". The new popup will require you to enter the key (gravity.TsFooter.siteMap) and the wanted translation for that label ("Verträge hier kündigen")
There could be a scenario where the landing page and other pages use different labels example;
- Landing page: "gravity.TsFooter.siteMap"
Other pages: "label.footer.sitemap"
In that case, make sure that you add two separate key entries for each label and translate both to "Verträge hier kündigen".
Example of the form
We used this Google form for demonstration purposes only! Please make sure that clients choose forms that provide full flexibility of customization.
Attachment from Legal dep: