Embill Services Limited (Case reference: 187522)
| Case Number | 187522 |
| Published date | 02 February 2022 |
| Adjudicated Party | Embill Services Limited |
| Procedure Type | Track 2 (Phone-Paid Services Authority) |
1
Tribunal meeting number 291
Case reference: 187522
Level 2 provider: Embill Services Limited
Type of service: Fixed line 09 service
Network operator: Telecom 2 Limited, TalkTalk Business and Square 1 Communications
Limited
This case was brought against Embill Services Limited (“the Level 2 provider”) under Paragraph
4.5 of the 14th Edition of the Code of Practice (“the Code”).
Background and investigation
1. This case concerned a sexual entertainment service provided by the Level 2 provider.
The Service was registered and operated under the brand name “Girls Next Door”. The
Service provided pre-recorded adult audio content to consumers.
2. The Service operated via fixed line 09 number ranges across two separate value chains.
Value chain 1 operated across number ranges 09826520910 – 098265290919 and
09826521300 – 09826521309. The terminating network operator for value chain 1
was Telecom 2 Limited. Value chain 2 operated across number ranges 09095560000 –
09095569790. The network operator for value chain 2 was Square1 Communications
Limited and the terminating network operator was TalkTalk Business. The Service
operated identically across both value chains. Each call cost £6 on connection plus the
standard network operator charges.
Service operation and value chains
Value chain 1
3. Number ranges 09826520910 – 09826520919 and 09826521300 – 0982652130
operated across value chain 1. On 19 June 2020 the Level 2 provider registered the
Service with the Executive for number range 09826520910 – 09826520919. The Level
2 provider and Telecom 2 confirmed that traffic first began to flow through the
premium rate numbers (“PRNs”) on 23 June 2020. On 5 October 2020, number ranges
09826521300 – 0982652130 were registered with the Executive. The number ranges
were disconnected on 15 December 2020.
Value chain 2
4. Number ranges 09095560000 – 09095560006 and 09095569790 – 09095569799
operated across value chain 2. The Level 2 provider stated the Service started on 23
2
June 2020. However, Square1 Communications Limited confirmed payable call traffic
commenced on 11 June 2020. There was a delay in registering the Service with the
Executive due to Square 1 Communications Limited’s new working process. The Service
was registered on 26 June 2020.
Service promotion
5. The Level 2 provider stated that the service was promoted through the following
journey:
“Consumer receives free marketing message,
a. clicks to call the premium rate number.
b. Consumer clicks on advert, links to one of the URL 's below, clicks to call the
premium rate number.”
6. Telecom 2 explained that the Service was promoted through online banner advertising
through an affiliate marketing company. The banner allowed for the consumers to call
and connect to pre-recorded messages that were of an adult/ sexual nature. It
transpired that the Service was also promoted via SMS marketing, but Telecom 2
stated that they were not made aware prior to the live launch that this form of
promotion was being used.
7. The Level 2 provider used affiliate marketing partners, UAB Velar Digital and Mobile Ads
Prvt Ltd “Adzmedia” on both value chains.
Previous relevant cases
8. The Level 2 provider had not previously been the subject of a Track 1 or Track 2
investigation by the Executive.
The investigation
9. The Executive received 25 complaints regarding the Service, 24 from members of the
public and one from a Phone-Paid Services Authority (“PSA”) employee between June
2020 and December 2020. The first complaint was received on 28 June 2020.
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