Interact2media Pte Ltd (Case reference: 158463)
| Case Number | 158463 |
| Year | 2020 |
| Published date | 11 March 2020 |
| Adjudicated Party | Interact2media Pte Ltd |
| Procedure Type | Adjudication by consent (Phone-Paid Services Authority) |
1
Case Report
Background
The Parties
The Level 2 provider in this case was Interact2media Pte Ltd (the “Level 2 provider”), who
were based in Singapore and have been registered with the Phone-paid Services Authority (the
“PSA”) since the 3 September 2015. They also operated another service called Mobsfun.
The Level 1 provider in this case was Daotec Ltd (Daotec), who were based in London in the
United Kingdom. Daotec have been registered with the PSA since the 12 August 2011.
The Service
This case concerned a fixed line, non-scratch card competition service called “Dial4Fun”
operating on premium rate numbers (PRN(s)); 09117523698, 09115628671, 09115628679
and 09115620784 (the “Service”). It was charged at £1.10p per minute for PRN 09115628671
and 99p per minute for the other PRN(s), plus network access charges with a cap of £30
applied on it. The Service offered entry into a non-scratch card competition, where consumers
called a PRN and answered multiple choice quiz questions.
The Service was said to have started operating from October 2015 according to the Level 2
provider, however Daotec advised the Executive that the Service began operation on the 6
November 2015.
The Level 2 provider stated that the numbers under investigation were no longer in use and
that the current status of the Service was inactive. Daotec confirmed that on the Level 2
provider's request, incoming calls were blocked to the Service on 7 December 2018.
Level 2 provider’s account of the operation of the Service
The Level 2 provider was asked to supply a summary of the way in which the Service was
intended to operate, and it responded by stating:
“The service operates by calling the 0911- number. Previous t o calling the 0911- number the
participant above has indicated his/her interests as he/she seems to have participated to a different
service by means of a free prize draw and receiving txt messages. Howev er, the 0911- number service
does not generate a free prize draw or any text message. The performance of the 0911-number go es
via one online page as shown in the information as attached, see ‘xx xxxxxxxxx’. The further
performance goes completely manual directly via the mobile tel ephone of the end-user. This means
that the end-user participates to a multiple-choice knowledge question wit h four possible answer
options A, B, C, D by tapping in the rights answer. A cap of £30 applies. Th e service number is tariffed
with 99p per minute, plus phone company's access charges.
Please see attachment ‘User terms’”.
The Executive also asked the Level 2 provider to describe how the Service is promoted, to
which it responded with the following:
2
“Since 2017 the Dial4fun service was promoted via a service part ner sms after a participant was
validated/registered as participant to a media buy channel wit h data capture points, privacy policies
and data protection statements. Media owners often use th is method when advertising services and
products of partners (such as Interact2Media) without pass ing on the phone number at the start of
the data capture. When the participant calls the number the D ial4fun service commences. To
participate to the Dial4fun servic e the service partner sms was sent 30 minutes after the participant
validated his/her registration. In summary: partic ipant enters the service, finalises his/her
participation and receives the service partner sms.
Interact2Media | Dial4fun is service partner and does not have ac cess to personal data which is
processed during the data capture. The service partner sms is sent after participation.
The standard example of sent service partner sms is:
+-+ Sent 23-sep-2017 2:05:23:
FREE MSG: Hi {First name]! Your number has been selected for the final ro und to win an IPHONE X!
Call now: 09115628671 (99p/min) Good luck!
+-+
See also answer under question 5”.
Question 5 referred to by the Level 2 provider above, is where the Executive directed the
Level 2 provider to provide a clear description of the consumer user flow regarding the
Service: from promotion through to answering the quiz question stage. The Level 2 provider
said the following in response to the question:
“Please see attached the standard consumer user flow used to prom ote the service: ‘Consumer
journey Surfeyo’ and ‘Consumer journey Amazando’. See also th e renewed questions and available
rounds to participate which was attached to the answer and explanation u nder question 2 above”.
The two documents referred to by the Level 2 provider both depicted consumer journeys into
the Service.
The Level 2 provider did not provide any examples or explanation as to what occurred when a
consumer dialled the PRN included in the text they received, however it did provide a
spreadsheet of new questions, it had recorded, based on a trivia-quiz containing local UK
based questions and generic trivia questions.
Executive’s account of the operation of the Service
Executive’s experience with the promotion of the Service
The Executive captured a consumer journey whilst monitoring the Service, on a desktop
computer, much like that described by the Level 2 provider. However, the access point was
through a Google search for a Roblox game hack using the search terms “robux generator” (an
in game currency to purchase upgrades and buy special abilities in games), the journey of which
contained content locking. The mode of opt in was through the process of co-registra tion.
3
After selecting the first link on the result page titled “Free Robux Generator 2018…”, to
generate the items, the Executive was instructed to; select their platform on which they play
the game, input the amount of Robux they wanted and then connect to their account by
inputting their username on the page.
They were then instructed to verify that they were human by choosing one offer or installing
one app from a list which came up on the screen.
To continue reading
Request your trial