Engagement outcomes

Where it appears that a breach of the Code has occurred or is likely to occur, the PSA may choose to use its Engagement procedure, rather than proceed to place the matter before a Tribunal. This may result in the PSA issuing a Warning Letter to the relevant PRS provider and, where corrective actions are required, an accompanying Action Plan.

Once concluded, the PSA may decide to publish the outcome of the case where it considers it to be in the public interest to do so, including, for example, if it may help improve market behaviour and raise consumer awareness.

Publication date
16 August 2023

Reference number
CAS-194690-X1B7Y0

Service category/case type
Information, Connection, and Signposting Services (ICSS)

Service subcategory
Call connection

Engagement Outcome - Warning Letter and Action plan

Background:
Since September 2022 Bounce Tech Ltd have provided an ICSS call connection service to consumers in the phone-paid services market. The service operates on 09 premium rate numbers, connecting consumers to a variety of organisations including HMRC and O2. The service costs £3.60 per minute plus the phone company’s access charge.

Warning Letter and Action Plan:
On 4 July 2023, the PSA issued a Warning Letter and Action Plan to Bounce Tech Ltd. The letter explained that it had obtained evidence to suggest that Bounce Tech Ltd may be in breach of the Code and that it had decided to commence an Engagement procedure to ensure any apparent breaches are addressed. The apparent breaches identified by the PSA and set out in the Warning Letter of 4 July and in its follow-up letter on 4 August included:

’Pricing Information – Paragraph 3.2.1 of the Code makes it clear that the cost of the service must be provided before any purchase is made and must be prominent, clear, legible, visible and proximate to the means by which a charge may be triggered.’

‘Misleading – Paragraph 3.2.2 of Code 15 state that that PRS services must not mislead or be likely to mislead in any way’.

Undue Delay – 'Once a consumer has chosen to engage with any type of phone-paid service, the service should either offer prompt engagement with the service itself, or the service content purchased should be promptly delivered' (Code Requirement 3.3.4).

With regard to pricing information, the Warning Letter noted:

with regards to the promotional material that: When the PSA viewed the service landing page material on www.customer-call-connection.com, www.tax-contact.net and www.fastcustomerhelp.com on a mobile handset the PSA found that call cost information could be missed due the ‘Click to Call’ and Premium rate number (PRN) buttons being significantly more prominent than any pricing information provided on the page. The ‘Click to Call’ and PRN buttons are in large bold font, while the pricing information is less prominent, contained within other information and not standalone; and that
with regards to the IVR message: In all cases the announcement was played at high-speed making it more difficult for consumers to catch all the information contained within the message. …. we are concerned that the message does not clearly state the cost for continuing the call and being connected as required by the Code.
with regards to misleading, the letter set out that: The language used in the promotion may have the potential to mislead consumers into believing they are calling the company they are looking for directly and not via a call connection service.

On 4 August 2023 the PSA wrote to Bounce Tech to say that it had subsequently identified an additional concern relating to potential for undue delay. PSA monitoring had found that: “after the IVR states pricing information and that it is connecting the caller to the end company (“…We are now connecting you to [name of end company])” it appears to first go through to Bounce Tech’s own menu system. This menu has the same intro “Hi and welcome, if you would like to speak to a customer service agent please press one” regardless of the organisation sought. Additionally, after this step there was waiting music before connection. It appears to the PSA that both these issues prolong the call before connecting consumers to the end company.”

Since issuing the Warning Letter, the PSA has published a set of Code amendments relevant to the way in which ICSS operate. Given the concerns identified relating the clarity of the information relayed through the IVR message used and the need to connect to the end organisation without delay we also consider that the requirements coming into force on 18 September 2023 are of relevance. The PSA therefore noted, in the 4 August letter, that: Following the amendments to the Code 15 relating to ICSS services that was announced on 24 July 2023 all providers, including Bounce Tech Limited, are required to come into compliance with the changes by 18 September 2023.

Bounce Tech Ltd has agreed to the action plan to resolve the issues identified in PSA's Warning Letter on 10 July 2023 and the follow-up letter of 4 August 2023 and has confirmed that they will, by 18 September 2023, ensure that their services are compliant with the ICSS Code amendments announced by the PSA in July 2023.

The agreed action plan included requirements to:

improve the prominence and proximity of pricing information
amend the promotional material to ensure consumers are aware they are using an ICSS call connection service and not contacting the end organisation directly
ensure the required information remain clearly audible throughout the IVR message and that, once the IVR has completed, consumers are connected through to the organisation sought without any delay
refund complainants who request a refund.

Therefore, any consumer who has been charged via their phone bill for the ICSS Call connection service operating on 09 premium rate numbers who wishes to seek a refund should contact Bounce Tech Ltd directly, on their contact details:

Phone: 0333 030 9900
Email: help@bounce-tech.com (please state ‘Bounce Tech Refund’ in the email subject line)
Postal address: Bounce Tech Ltd, Kemp House, 152-160 City Road, London, EC1V 2NX, United Kingdom

Publication date
15 October 2024

Reference number
CAS-196366-P0W8F4

Service category/case type
Information, Connection, and Signposting Services (ICSS)

Service subcategory
Call connection service

Engagement Outcome - Warning Letter and Action plan

Background
Since 27 November 2023 Caller Centre Ltd have provided an ICSS Call connection service to consumers in the phone-paid services market. The Service operates on a range of 09 premium rate numbers, which connect consumers to a variety of public and commercial organisations including, DPD, Sky, Evri, O2, TV Licence and Thames Water. The Service cost £6.00 per call plus the phone company’s access charge. On 12 December 2023, the PSA notified Caller Centre Ltd that we had decided to commence an Engagement procedure and sent an enquiry letter seeking further information on the Service.

Having reviewed its responses the PSA issued a Warning letter and Action plan on 24 April 2024 setting out its concerns and explaining that the engagement action was initiated based on consumer complaints and PSA monitoring. On 9 July 2024 the PSA issued a further update to the action plan. Together these letters set out the apparent breaches identified relating to transparency of pricing/service information, misleading promotion and the IVR used by Caller Centre Ltd. On 22 July 2024 Caller Centre Ltd agreed to the Action plan to resolve the issues identified.

The agreed Action plan included requirements to:

improve the prominence and proximity of pricing information
ensure that it is abundantly clear that the service is an ICSS on the promotional and landing pages for the service
ensure that the misleading aspects of the promotion material are corrected
improve the format and content of the IVR message for the service.

Caller Centre Ltd provided evidence to demonstrate and confirm that they had actioned the corrective measures.

Extracts from the Warning Letters issued:

The Warning letters set out details of the apparent breaches which included:

Transparency - Insufficient prominence of Pricing and Service Information

Paragraph 3.2.1 of the Code makes it clear that the cost of the service must be provided before any purchase is made and must be prominent, clear, legible, visible and proximate to the means by which a charge may be triggered.’

Paragraph 3.2.2 the Code states that, Before making their purchase or incurring any charges, consumers must be fully and clearly informed of all information that would reasonably be likely to influence their decision to purchase, including (a) clear description of what the service is and/or does.

Paragraph 3.2.3 of the Code states that, All written information provided in accordance with Requirement 3.2.2 of the Code must be accessible, legible, and clearly presented.

With regards to the above, the Warning letters noted that:

when the PSA viewed the promotional material for the Service on a mobile handset and a desktop the PSA observed “the pricing information on the landing pages was significantly less prominent than the PRN and “click to call” action buttons on the page and is easily missed. The PRN and the words “click to call” on the page stand out more, due to their font size, boldness and bright ... colour compared to the pricing information” and “that the way the pricing information currently appears on the promotion is likely to be overlooked by consumers as it is placed within a bulk of text. Having the pricing information appear standalone ensures it is prominent, proximate and clear, and is more likely to be seen by consumers”, and that,
within the promotional material “information informing consumers that the Service is an ICSS is not presented in a, legible, or clear way” and that key information regarding the service was presented on the landing page in a way that is likely to be overlooked and missed by consumers and will prevent them from knowing the true nature of the service. The key information has been presented in a way that the size and boldness of the text font is less clear and legible compared with the other information on the page. This included information that the sought after organisation could be contacted at a lower or no cost.

Misleading

Paragraph 3.3.2 of Code 15 state that PRS services must not mislead or be likely to mislead in any way’ and Paragraph 3.3.3 of the Code states that PRS providers must not use any marketing technique, language or imagery which misleads or has potential to mislead the consumer into believing the service on offer is associated with or provided by another PRS provider or any other public or commercial organisation when it is not.

The Warning letters noted that the promotional material and landing page for the Service was misleading for the following reasons:

the placement and the increased prominence of the end organisations name on the promotional material, coupled with the organisations postal address, gives the impression that the Service is being provided by the sought after organisation and is not an ICSS provided by a separate Merchant,
the use of lots of different names for the provider of the Service within the landing pages is likely to confuse consumers when seeking to identify the Service and/or obtain details of the Service provider... the name and/or trading names used in promotional material should be consistent with the name of the Merchant and Service as registered with the PSA as per Paragraph 3.2.2 (e) of the Code,
the references to Caller Centre at the top corner of the page does not state the full name of the company and therefore does not make it clear to consumers that Caller Centre is a company. This is because the Ltd part of the company name has not been included,
the branding colours on an example promotion was similar to that of the organisation Caller Centre Ltd was connecting to, which had the potential to mislead consumers into believing that the Service is related to and/or provided by the end organisation,
information within the promotion relaying the Service information had the potential to confuse consumers into believing Caller Centre Ltd was the name of the Service rather than the Merchant.

The Warning letters noted that the IVR for the service was misleading for the following reasons:

in stating that ‘there are no further charges for the remainder of the call’, consumers could be misled to believe that they will only be charged £6 for the call, when in fact consumers receive further charges for using the Service in the form of access charges from their Network providers. If a consumer were to press 1 to be connected to the end organisation, prior to listening to the information about the phone companies access charge, as prompted to do so initially within the IVR, they would be under the mistaken assumption that the call would cost no more than £6,
the repeated use of the phrase “customer services”, in the context of the current message as a whole with no mention of it being a call connection service, has the potential to mislead consumers into believing it is an in-house call connection or that the actual service is the end organisation’s customer service rather than a separate service connecting to an external end organisation, and,
the IVR states they will send the ‘customer services number via free SMS. The PSA consider that the phrase does not make it clear as to whose customer services number it will be sending to the consumer.

Transparency - Use of Service

Paragraph 3.2.10 of the Code states that, where a voice service connects the consumer to another organisation, the cost of continuing the call, including information about access charges and any additional chargeable element of the service such as a premium SMS, must be clearly stated in an alert before onward connection. Where the service is an Information, Connection, and Signposting Service the alert upon connection must:

State the cost of the call per minute and/or per call
state that the organisation to which the service connects can be contacted directly for no or lower cost and provide the organisation’s direct contact number
state the maximum call charge
obtain positive opt-in from the consumer to
1. continue the call; and
2. connect to the organisation referred to in ii) above or referred to within the alert
where the service provides any additional chargeable element, such as a premium SMS, obtain separate positive opt-in from the consumer for that element of the service.

The Warning letters noted that:

the IVR message for the PRNs used for the Service breaches the requirement of the Code because consumers are provided with the option for onward connection without first being made aware of the charges associated with using the Service. Furthermore, consumers can press 1 to be connected to the end organisation at any time during the IVR recording, for instance without listening to key information including the full cost of the call, that they can contact the end organisation at a lower or no cost elsewhere and the maximum service charge for the call before it is disconnected. Due to this, consumers are not able to make a fully informed decision before using the Service and the IVR did not provide the direct contact number beside the phrase that the end organisation can be contacted elsewhere at no or lower cost and,
within the promotional material for the Service, CCL has stated that the call will be disconnected once 180 minutes has been reached, however there is no mention of this within the IVR message. The PSA consider that the fact the call will be disconnected at a certain point is key information and should be mentioned within the IVR of the Service PRN’s.

Publication date
6 July 2023

Reference number
CAS-194417-Q8J1F5

Service category/case type
Information, Connection, and Signposting Services (ICSS)

Service subcategory
Call connection

Engagement Outcome - Warning Letter and Action plan

Background:

Since November 2022 Data Central (Services) Ltd have provided an ICSS Call connection service to consumers in the phone-paid services market. This is a call connection service www.isearchonline.org operating on 09 premium rate numbers, connecting consumers to a variety of organisations including NOW TV, DPD, Three and SKY. The service costs £3.60 per call + £3.60 per minute plus the phone company’s access charge. On 8 February 2023, the PSA notified Data Central (Services) Ltd that it had decided to commence an Engagement procedure and sent an enquiry letter seeking further information on the service. .

Warning Letter and Action plan:

On 18 April 2023, the PSA issued a Warning Letter and Action Plan to Data Central (Services) Ltd setting out its concerns and explaining that the investigation was initiated based on a consumer complaint and PSA monitoring. The apparent breaches identified by the PSA and set out in the warning letter included:

‘’Pricing Information – Paragraph 3.2.1 of the Code makes it clear that the cost of the service must be provided before any purchase is made and must be prominent, clear, legible, visible and proximate to the means by which a charge may be triggered.’

‘Misleading – Paragraph 3.2.2 of Code 15 state that that PRS services must not mislead or be likely to mislead in any way’

With regard to Pricing Information the warning letter noted that: When the PSA viewed the promotional material www.isearchonline.org on a mobile handset the PSA found that call cost information could be missed due the ‘Click to Call’ and Premium rate number (PRN) buttons being significantly more prominent than any pricing information provided on the page. The ‘Click to Call’ and PRN buttons are in large bold font in white text on a blue background, while the pricing information is less prominent.

With regards to Misleading the warning letter set out that: The language used in the promotion such as the heading “NOW TV Customer Services Call Connection Service” gives the impression that the service is provided by NOW TV. It has the potential to mislead consumers into believing they are calling the company they are looking for directly and not via a call connection service.

On 18 April 2023 Data Central (Services) Ltd agreed to the action plan to resolve the issues identified.
The agreed action plan included requirements to:

improve the prominence and proximity of pricing information
amend the promotional material to ensure consumers are aware they are using an ICSS call connection service and not contacting the end organisation directly
refund complainants who request a refund.

Therefore, any consumer who has been charged via their phone bill for the ICSS Call connection service www.isearchonline.org operating on 09 premium rate numbers who wishes to seek a refund should contact Data Central (Services) Ltd directly, on their contact details:

Email: info@datacentral.co.uk
Phone: 0333 030 9110
Website: www.isearchonline.org/refund/

Publication date
22 November 2023

Reference number
CAS-194809-F2H4M7

Service category/case type
Information, Connection, and Signposting Services (ICSS)

Service subcategory
Call Connection

Consumer refunds
Any consumer who has been charged via their phone bill for the ICSS Call connection service operating on 09 premium rate numbers who wishes to seek a refund should contact Jayne Sage Ltd directly, on their contact details:

Phone: 01785747238

Email: enquiries@contact-number.uk (please state ‘Jayne Sage Refund’ in the email subject line)

Postal address: Jayne Sage Limited, Little Acre, Woodcock Heath, Kingstone, Uttoxeter, ST14 8QR, United Kingdom

Engagement Outcome - Warning Letter and Action plan

Background:

Since 13 October 2022 Jayne Sage Ltd have provided an ICSS Call connection service to consumers in the phone-paid services market. The service operates on 09 premium rate numbers, connecting consumers to a variety of organisations including delivery services Evri and DPD. The service costs £6 per minute plus the phone company’s access charge.

Warning Letter and Action plan:

On 10 August 2023, the PSA issued a Warning Letter and Action Plan to Jayne Sage Ltd. The letter explained that it had obtained evidence to suggest that Jayne Sage Ltd may be in breach of the Code and that it had decided to commence an Engagement procedure to ensure any apparent breaches are addressed. The apparent breaches identified by the PSA and set out in the warning letter of 10 August 2023 included:

‘Misleading – Paragraph 3.2.2 of Code 15 state that that PRS services must not mislead or be likely to mislead in any way’

‘Customer care – Paragraph 3.4.1 of Code 15 states that Intermediary providers and merchant providers must ensure that consumer enquiries and complaints that they have primary responsibility for handling are responded to and resolved promptly, easily and fairly, at no more than basic rate cost to the consumer…’

With regard to pricing information the warning letter noted that “when the PSA viewed the promotional material www.contactinformation.uk on a mobile handset the PSA found that call cost information could be missed due the ‘Click to Call’ and Premium rate number (PRN) buttons being significantly more prominent than any pricing information provided on the page” and that “The ‘Click to Call’ and PRN buttons are in large bold font in white text on a blue background, while the pricing information is less prominent in small grey text on a white background below the call to action.”

With regards to misleading the letter set out that:

“The language used in the promotional Google search engine ad such as the heading “Evri Customer Service – Evri contact Number” and “DPD Customer Service – DPD contact Number” on the Google Ad; and “Evri Customer Service” and “DPD Customer Service” on the landing page gives the impression that the service is provided by Evri and DPD. It has the potential to mislead consumers into believing they are calling the company they are looking for directly and not via a call connection service.”

With regard to customer care the letter noted that “The PSA has received complaints from consumers stating that they were unable to contact your customer service.”

The PSA also noted that following the amendments to Code 15, relating to ICSS services, that was announced on 24 July 2023, all providers, including Jayne Sage Limited, were required to come into compliance with the changes by 18 September 2023.

Jayne Sage Ltd agreed to the action plan to resolve the issues identified in PSAs warning letter and confirmed that they would ensure that their services are compliant with the ICSS Code amendments coming into effect on 18 September 2023.

The agreed action plan included requirements to:

improve the prominence and proximity of pricing information
amend the promotional material to ensure consumers are aware they are using an ICSS call connection service and not contacting the end organisation directly
ensure consumer enquiries and complaints are being responded to and resolved promptly, easily and fairly
refund complainants who request a refund.

Publication date
20 June 2023

Reference number
CAS-189094-L5S8C8

Service category/case type
Information, news and education

Service subcategory
Alerts

Engagement Outcome - Warning Letter and Action plan

Background:

During the period August 2020 – January 2022, 4130 Kinetic Ltd ‘Kinetic’ provided the Alerts for You service to consumers in the phone-paid services market. This was a subscription service where consumers received SMS messages costing £1.50 (up to a max £4.50 per week) from shortcode 88222. In January 2022, 4130 Kinetic Ltd ceased marketing the service but existing subscribers continued to be billed. The PSA commenced initial enquiries into the service on 1 June 2021 and on 25 August 2021 it notified Kinetic that it had opened a formal investigation.

Warning Letter and Action plan:

On 15 May 2023, the PSA issued a Warning Letter and Action Plan to Kinetic setting out its concerns and explaining that the investigation was initiated based on consumer complaints and PSA monitoring. The apparent breaches identified by the PSA and set out in the warning letter included:

‘Transparency – Code 14 rule 2.2.1 requires that consumers of PRS must be fully and clearly informed of all information likely to influence the decision to purchase, including the cost, before any purchase is made….’

‘Pricing information – Code 14 rule 2.2.7 requires that for any PRS promotion the cost must be included before any purchase is made and must be prominent, clearly legible, visible and proximate to the premium rate telephone number, shortcode or other means of access to the service….’

‘Misleading – Code 14 rule 2.3.2 requires that PRS must not mislead or be likely to mislead in any way…’

The letter went on to say that ‘Kinetic still maintain an active registration with the PSA and although the apparent breaches set out above are now mostly historic in nature, we are aware that it continues to bill existing subscribers. Given this, the PSA wishes to ensure that, should Kinetic decide to operate within the phone-paid services market again at any point in the future, issues such as those set out in this letter do not recur. Kinetic should be aware we remain concerned that consumers who subscribed during the operation of this service, may have been misled into signing up and that some degree of consumer harm is still occurring.’

Given the concerns set out above the PSA enclosed an action plan setting out what corrective action we consider is required to address our remaining concerns identified in the letter.

On 26 May 2023, Kinetic confirmed that although it agreed to implement the action plan it did not fully agree with all the apparent breaches set out in the warning letter.

Transparency – Code 14 rule 2.2.1

The PSA considered there was a lack of clarity in the way the promotion was designed by using ambiguous wording such as ‘JOIN NOW’ on the call-to-action button rather than clearer wording such as ‘Buy’, ‘Pay’ or ‘Subscribe Now’. Kinetic did not agree, it provided the PSA with advice provided by Buckingham and Surrey Trading Standards Service which was issued on 18 August 2016 and valid until 17 August 2017. Kinetic queried whether there is any further advice to review should it decide to operate in the UK mobile payments market in the future, the PSA responded providing its most recent transparency guidance (April 2022).

‘Pricing information – Code 14 rule 2.2.7

The PSA considered that pricing information had not been insufficiently prominent when compared with the call to action, the pricing was within a paragraph of text and in a significantly smaller font. Additionally, pricing was obscured when consumers entered a pin to join the service.

Kinetic agreed that a breach had temporarily occurred relating to an update to a mobile handset’s operating system which affected the formatting of pages. This resulted in the cost of the service being covered by the keyboard during the second stage of the double opt-in when a customer confirms a charge to their mobile phone.

Although Kinetic did not agree with PSA's other concerns with pricing proximity it did agree to obtain compliance advice from the PSA in the event that it decides to re-enter the market to help ensure concerns of this nature do not recur in future.

Misleading – Code 14 rule 2.3.2

The PSA considered that the consumer journey which led to them signing up to the service was misleading. The consumer journey would begin with an offer to claim a reward/prize/gift from a well-known household brand. To claim the reward/prize gift the consumer would have to go through a series of surveys and questions. After these various steps were taken, the consumer would then reach Kinetic’s landing page. At this point, consumers may still have been under the impression that they were interacting in order to claim the prize or reward from the brand in question and it would not have been clear that they were entering a purchasing environment for a premium rate service.

Kinetic partially agreed to this breach as it agreed that one particular email marketed consumer journey the PSA provided as an example was misleading. The PSA however believed that all of these types of consumer journey were misleading to consumers.

The agreed action plan included requirements to:

'Continue to send monthly subscription reminders to all subscribers’;
‘Provide a full refund within 10 days of receipt of a refund request’, and to
‘Seek compliance advice ahead of recommencing operation in the phone- paid services market’.

Therefore, any consumer who has been charged via their phone bill for the Alerts for You service operating on shortcode 88222 who wishes to seek a refund should contact 4130 Kinetic Ltd directly, on their dedicated e-mail address for consumers to use when contacting them for a refund - psacontact@4130kinetic.com.

Publication date
06 April 2023

Reference number
CAS- 191994-W0Z4S1

Service category/case type
Information, news and education

Service subcategory
Alerts

Engagement Outcome - Warning Letter and Action plan

Background:

During the period November 2018 – April 2022 Modo Mobi Ltd provided the Modo Alerts service to consumers in the phone-paid services market. This was a subscription service where consumers received SMS messages costing £1.50 (up to a max £4.50 per week) from shortcode 85222. In April 2022 Modo Mobi Ltd ceased marketing the service but existing subscribers continued to be billed. The PSA commenced initial enquiries into the service on 7 July 2021 and on 23 May 2022 it notified Modo Mobi Ltd that it had opened a formal investigation.

Warning Letter and Action plan:

On 27 February 2023 the PSA issued a Warning Letter and Action Plan to Modo Mobi Ltd setting out its concerns and explaining that the investigation was initiated based on consumer complaints and PSA monitoring. The apparent breaches identified by the PSA and set out in the warning letter included:

‘Misleading – Code 14 rule 2.3.2 requires that PRS must not mislead or be likely to mislead in any way…’

The letter went on to say that ‘Although the apparent breaches set out above are now by and large historic in nature we note that you have renewed your registration and are continuing to bill existing subscribers. Given this we wish to ensure that, should you in future decide to re-enter the phone-paid services market, issues such as those set out in this letter do not re-occur. We also remain concerned that consumers who subscribed during the operation of this service, may have been misled into signing up and that some measure of consumer harm is still occurring’ and that ‘Given the concerns set out above we have attached at annex 1 an action plan setting out what corrective action we consider is required to address our remaining concerns identified in this letter’.

On 15 March 2023 Modo Mobi confirmed that although it agreed to implement the action plan and that a potential breach of ‘Pricing information’ and ‘Misleading’ may have occurred, it did not agree all the apparent breaches set out in the warning letter.

With regards to ‘Pricing information’, where the PSA considered that pricing information had been insufficiently prominent when compared with the call to action, Modo Mobi Ltd agreed that a breach had temporarily occurred relating to an update to a mobile handset’s operating system which affected the formatting of pages. This resulted in the cost of the service being covered by the keyboard during the second stage of the double opt-in when a customer confirms a charge to their mobile phone. It has also acknowledged that it is important that service monitoring is regularly carried out and that it includes considering the impact of device software updates that are outside its immediate control.

The agreed action plan included requirements to:

Continue to send monthly subscription reminders to all subscribers’;
‘Provide a full refund within 10 days of receipt of a refund request’, and to
‘Seek compliance advice ahead of recommencing operation in the phone- paid services market’.

Therefore, any consumer who has been charged via their phone bill for the Modo Alerts service operating on shortcode 85222 who wishes to seek a refund should contact Modo Mobi Ltd. Modo Mobi Ltd has set up a dedicated e-mail address for consumers to use when contacting them for a refund - psacontact@modomobi.com.