[JP] Indicate Cancellation Fee on Consumer Portal During the Purchase Process
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Misayo Hara
Request: During the purchase process, when selecting a plan, the presence or absence of a cancellation fee and its details must be clearly shown.
The consumers need to be notified about the cancellation fee before comfirming subscription contracts, however with the current system this information appears only after the consumer select the termination on the portal.
The legal team advised that the customers cannot charge the consumers for cancellation fee as the system did not clearly indicate this penalty before the consumers contracted subscriptions. Before this being fixed, the cancellation fee feature cannot be used for a pilot launch.
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Tian Marchand
updated the status to
complete
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Tanya Siraa
Confirming the requirements for Italy are the same as for Japan:
Under EU/Italian consumer law, all foreseeable charges must be disclosed before the consumer is bound by the subscription and—where the flow is online—before placing the order. Hence:
1) The Early Termination Fee cannot be dynamic, as ECPs may change the level at any time. The Early Termination Fee that applies must be the one that was in force at the time the Patient initiated the Subscription, not at the time they cancel.
2) The Early Termination Fee set by the ECP must be made available to the Patient prior to them entering into the Subscription (i.e. in the offer/summary materials as well as in the ECP T&Cs) and also be displayed during the termination process.
3) The Fee does not apply if termination is due to any of the following objective circumstances not attributable to the Patient: (i) product unavailability; (ii) correction changes that make the product no longer suitable; (iii) mandatory changes required by law or competent authorities. The ECP may handle such exceptions off platform, including waivers or refunds where applicable.
Question: Are there currently any circumstances whereby the Early Termination Fee is not charged automatically (where it would otherwise be due), e.g. product unavailability?
I will revert with one additional requirement around length of time the Early Termination Fee is applicable (currently 5 days before end of Subscription).
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Tian Marchand
Tanya Siraa:
1) ok, we will look into locking the termination fee, same as price for smart subscription
2) we will display in the ordering/checkout process. For T&Cs, can you confirm if you mean displaying the exact termination fee for each patient? 'Termination process', I guess you mean the cancellation process. If yes, it is already there (you can check on the platform)
3) (i) termination fee only applies if there is one, and if the user is proactively cancelling a smart subscription before it ends. OOS triggers another journey, which you can check on Confluence.
(ii) what does that mean, that the 'product is no longer suitable'? We have a scenario whereby if the ECP replaces CL/adds CLC and a subscription is active, there will be an option for the patient to choose if they want to continue or cancel at no fee. That is also in Confluence, please check.
(iii) what does that mean exactly? I understand this would be handled offline.
Answer to your question: I don't think so.
Your last point on the 5 days before the end of the subscription: this is already detailed in this table https://alconprod.atlassian.net/wiki/spaces/DHVCMS/pages/6167069003/MARLO+Int+l+B2B2C+Subscriptions#Termination-fee-Lock.
CC Priya Dayal
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Tian Marchand
Tanya Siraa please clarify the above when you are back.
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Tanya Siraa
Tian Marchand For Point 2) I can confirm that the exact Early Termination Fee must appear for each patient in the offer screen. This fee should also appear in the T&Cs. For Point 3ii) Yes, that is fine. For Point 3iii) this is just to leave open the possibility of any future legal changes. As mentioned, the remedy can also take place offline.
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Tian Marchand
Tanya Siraa thank you. 2) it'll appear on the ordering & checkout flows. But I understood from the last IT weekly meeting that the exact amount will not appear on the T&Cs. Please confirm.
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Tian Marchand
updated the status to
planned
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Tian Marchand
Misayo Hara Asami Inatomi FYI Tanya confirmed today she will confirm the requirements for JP and IT about this
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Tian Marchand
Also, I've just double checked, the ECP could update the termination fee anytime, and whatever amount is the latest before a cancellation, that amount will be charged to confirm the cancellation. So in theory, displaying the termination fee will not be accurate, since this can be a dynamic value.
How about we say something like 'Fixed plans can incur a cancellation fee, please check the Terms of Use for more details'?
The thing is that they will see the exact amount when they request a cancellation, and before confirming.
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Tian Marchand
Misayo Hara, currently, when a user selects a fixed 6-12 months / smart subscription, see below what they will see. This is before clicking on 'Pay & subscribe'. So you are requesting to say instead the exact amount if a termination fee is set up, and remove that sentence if there is none?
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Misayo Hara
Tian Marchand Legal team see "The thing is that they will see the exact amount when they request a cancellation, and before confirming." as an issue, and the legal requirement is to show the exact value before confirming to begin this contract.
Also the point you mentioned that this is a dynamic value is an issue, as the contracted price is fixed which should be the same case for the cancellation fee.
Already communicated to Ashish that dynamic value for cancellation is an issue and should be fixed during the contract period.
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Tian Marchand
Misayo Hara ok I see. Right now, the termination fee is dynamic indeed. If you want to lock it for smart 6/12 (same as product/subs discount price). Let us know the requirement.
CC Priya Dayal Sristy
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Tian Marchand
Misayo Hara also messaged you, and in case, kind reminder on the above pleae. Thank you
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Misayo Hara
Tian Marchand Same logic as the product price being locked during the contracted period for the Smart 6/12, please set the cancellation fee locked during the contract period as well.
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Tian Marchand
Misayo Hara: thanks, termination fee lock + display in ordering/checkout planned.