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Supervision of Marketing and Contract terms

Subscription traps continued to keep the FCCA busy

In 2017, the Consumer Ombudsman continued the previous active work against subscription traps. In a subscription trap, a consumer typically receives an invoice from an online store or a telemarketer for a product they were unaware of having ordered.

The Consumer Ombudsman examined the websites of the Estonian companies Vitaelife Pharma Oü and Regimen Oü, which sell dietary supplements, to assess whether they provide consumers with information on the products’ main properties, total price, and other possible costs as well as the duration of the contract. This information must be presented clearly and immediately before the placement of an order. On the websites inspected, the information was placed either directly above the order button or in the body text on the same page. The Consumer Ombudsman closed the case in December 2016 but drew the companies’ attention to the problems found in their customer service. Monitoring of the companies’ marketing was continued in early 2017.

The Consumer Ombudsman also issued a warning about the Autonhintaarvio.fi website, through which consumers had ordered car valuation services without realising that they were subject to a charge. Nordea was reminded of the fact that a creditor and payment services provider is responsible for returning unjustified credit card charges to consumers, if the consumer has not given consent to them, and they have been incurred from subscription traps in which the company has deliberately misled the consumer. Operators carry a similar responsibility for unjustified purchases invoiced via subscription bills in subscription trap cases. The Consumer Ombudsman also assisted several consumers in court, in whose cases collection agencies had begun to recover debts, related to subscription traps, by legal means.

Subscription traps were also discussed in the counter-fraud working group of the National Council for Crime Prevention, of which the FCCA was a member. In December 2017, the working group published a review (in Finnish) on fraud offences and their prevention, and recommendations (in Finnish) for fraud prevention. Actions related to subscription traps will be continued in 2018.