We are the UK regulator for content, goods and services charged to a phone bill.

Stripey Giraffe Limited

Publication date 25 November 2024
Case reference CAS-194493-X5H9D6
Procedure Settlement
Adjudicated party Stripey Giraffe Limited
Service type Virtual Gifts
Tribunal's final assessment Serious
Sanctions Code 15 - 5.8.5 (d)
Code 15 - 5.8.5 (e)
Code 15 - 5.8.5 (i)
Breaches raised Code 14 - 2.2.7 Rules relating to pricing
Code 15 - 3.2.1
Code 15 - 3.3.2
Summary

The investigation into Stripey Giraffe concerned a number of potential breaches of Code 15. The period of the breaches commenced when the 14th Edition of the Code of Practice ("Code 14") was in force and continued after Code 15 (collectively the "Code") came into force. 

Stripey Giraffe is a Merchant Provider based in the UK and provides the "Stripey Offers" service ("Service") to UK consumers using short code 88222. Stripey Giraffe first registered with the PSA on 17 July 2018, and the Service itself was registered with the Executive on 22 October 2018.

The "Stripey Offers" service was charged at £1.50 per message received, with a maximum of three messages received per week. The Respondent contracted with SB7 Mobile Ltd (the "Intermediary Provider") who in turn, during the period under investigation, contracted with Dynamic Mobile Billing Limited. 

The Service is promoted predominantly through Google Display Network Advertising, and to a lesser extent through co-registration site partners. 

The PSA became aware of potential breaches of the Code through complaints received from consumers. Following initial service monitoring the PSA considered it necessary to take Enforcement Action against Stripey Giraffe. 

During the investigation, the PSA relied on evidence from monitoring the service, information supplied by Stripey Giraffe and its intermediary SB7 and consumer complaints. To date the PSA has received 503 complaints from consumers relating to this service. The issues identified in these complaints were reflected in reviews observed on an external review website.

Having considered this evidence, an Enforcement Notice was issued to Stripey Giraffe in December 2023.

The parties agreed that the case severity is overall “serious”, and that the following sanctions should be imposed:

  • total fine of £275,000
  • refunds to all consumers who apply, for the full amount spent by them for the service
  • compliance advice on future promotions to be sought and implemented to the satisfaction of either the PSA or Ofcom prior to re-starting the service.

The Parties also agreed that Stripey Giraffe will pay a fixed amount towards the PSA's administrative charge in the sum of £100,000 inclusive of VAT, and that both the total fine and the administrative charge will be paid within 30 days of publication of the consent order and this statement.

PSA v Stripey Giraffe Consent Order
 

Download adjudication decision