Vulnerable Customer Care Policy

1. Our commitment

Playbay is committed to giving fair, transparent and effective support to every customer, and to doing more for those in vulnerable circumstances. We understand that anyone can become vulnerable, whether temporarily or permanently, and that the way we communicate, sell, bill and resolve problems can either lessen or worsen the harm that vulnerability brings.

This commitment is driven from the top: senior management is accountable for embedding the policy throughout the organisation and for making sure that frontline staff and third parties are able to deliver it. Information a customer shares about their vulnerability is handled with care, kept only with their knowledge and consent, and used solely to give them better support.

2. Who is a vulnerable customer?

We adopt the widely recognised UK regulatory approach: a vulnerable customer is anyone whose personal circumstances leave them significantly less able to engage with our service, make informed decisions, speak up for themselves, or withstand a financial or service-related setback. Vulnerability can be permanent, temporary or situational. The driver categories we work with are:

Important: this list illustrates rather than exhausts the possibilities. A customer does not have to disclose a label or diagnosis to be supported — we respond to signs and circumstances, not categories.

3. Identifying vulnerability

Customers are not required to declare themselves vulnerable in order to receive support. We aim to spot signs of vulnerability through any channel — phone, email, web form or correspondence from an aggregator or operator — and to respond appropriately. Indicators may include:

• Difficulty grasping subscription terms, charges or the cancellation process.
• Repeatedly asking for the same information, confusion over dates or amounts, or seeming distressed, agitated or upset.
• Statements that a third party (such as a carer, family member or friend) is acting for the customer, or that the customer is the parent or carer of someone who used the service.
• Mentions of bereavement, illness, mental health, financial hardship, domestic abuse, or being the victim of fraud or crime.
• Indications that the user may be a minor (under 18), or that the bill-payer is an older adult or someone who did not take out the subscription themselves.
• Difficulty using digital tools, hearing the agent, or communicating in English.

Where staff notice any of the above, they flag the contact as potentially vulnerable and follow the support actions in Section 5.

3.1 Asking about needs

At the earliest suitable point in any contact, agents ask whether the customer has any accessibility or customer-service needs we can accommodate. Questions are asked openly and never require the customer to disclose medical, financial or personal detail.

3.2 Recording vulnerability

Where a customer tells us about their circumstances, we will, with their consent, add a short note to our case-management system so they do not need to repeat themselves in later contacts. The note records the help they asked for, not a diagnosis or a label. Records are kept in accordance with UK GDPR, the Data Protection Act 2018 and our Privacy Policy. Customers can ask us to amend or delete a vulnerability note at any time.

4. Accessible communication

We adapt the way we communicate to fit a customer's needs, free of charge. On request, we can:

• Give more time, repeat information, slow the pace of a call, or arrange a callback at a quieter moment.
• Provide information in plain English, in large print, or as a written summary sent by email after a phone call.
• Deal with a nominated third party — for instance a family member, carer, advocate, or someone holding power of attorney — where the customer has given (or, if the customer cannot give it, the third party can evidence) suitable authority.
• Use the UK text relay service for customers who are deaf, hard of hearing or have speech difficulties.
• Pass the customer to a specialist colleague or supervisor where their needs exceed what a frontline agent can handle.

4.1 Customer support availability (UK)

Our UK Customer Care team runs the following channels free to the customer, or at no more than the basic call rate where a telephone number is used:

• Email: productsupport@goplaybay.com, a UK-facing customer care mailbox monitored every working day.
• Telephone: 0800 029 4506 (freephone from UK landlines and mobiles), 09:00–17:00 UK time on working days, with a free callback option when no agent is available.

Telephone calls are answered on a best-efforts service level. Email enquiries and complaints are acknowledged within five (5) working days and we make best efforts to resolve them without unnecessary delay.

5. Support actions for vulnerable customers

When a customer is identified as, or tells us they are, in vulnerable circumstances, the supporting agent takes the following steps on top of standard customer care:

5.1 Immediate cancellation

Where the customer asks to cancel a subscription, or where the contact relates to a subscription taken out by a minor, by an older adult who did not consent, or by any other person in vulnerable circumstances, the agent cancels the subscription immediately on first contact. No further charges are made to the relevant number, and the customer receives written confirmation of the cancellation through their preferred channel.

5.2 Refunds and redress

Refund requests from customers in vulnerable circumstances are prioritised and reviewed sympathetically. As under our standard Customer Care Policy, refunds may be granted up to the full billed value of the most recent six months of the subscription. For customers in vulnerable circumstances:

• Decisions are escalated to a supervisor where a refund outside the standard parameters is needed to restore the customer to the position they would have been in had the problem not arisen.
• Where the subscription was taken out by a minor (under 18), or where the customer credibly states it was started without their knowledge or consent, we apply a presumption in favour of a full refund, subject to supervisor review and, where relevant, confirmation from the aggregator or mobile operator involved.
• We do not make the customer re-explain their circumstances over and over; the supporting agent gathers the necessary detail in as few contacts as possible.

5.3 Protecting against further harm

Where there is any sign that a customer is at risk — for example, indications of serious financial difficulty, a mental health crisis, fraud or coercion — the agent will:

• Pause all further communications about the subscription (including marketing) to the relevant number.
• Confirm the cancellation in writing and give a clear single point of contact for any follow-up.
• Where appropriate, signpost the customer to free, independent support organisations.
• Escalate the case to the designated Vulnerable Customer Lead (see Section 8) for review.

5.4 Minors

Playbay's services are intended for users aged 18 or over. Where we are told, or have reasonable grounds to believe, that a minor has subscribed:

• The subscription is cancelled immediately.
• A refund is issued in line with section 5.2.
• The case is logged for trend analysis and reported internally; where a systemic issue emerges, we work with our aggregator and operator partners to tackle the underlying cause.

6. Working with aggregators and operators

Many of our UK-facing subscriptions reach customers via mobile network operators and aggregators. We expect these partners to work to standards consistent with this policy, and our contracts with them require:

• Prompt forwarding of any customer complaint or refund request — particularly those involving a person in vulnerable circumstances — with enough information for us to take action.
• Co-operation with refund and cancellation requests, including where it cannot be evidenced that the original subscription was informed and consensual.
• Implementation of opt-in, age-gating and spend-reminder controls in line with Ofcom and PRS requirements.

Requests from aggregators or operators are treated as urgent. We investigate the subject matter of each request thoroughly and promptly respond with accurate information.

7. Training and culture

Every member of staff or contractor who deals with UK customers, or who handles UK customer data, completes vulnerability training before going live and refresher training at least once a year. The training covers:

• Recognising signs of vulnerability across channels, including where customers do not disclose them explicitly.
• Plain-English communication, active listening, and handling difficult or distressing conversations.
• This policy, our cancellation and refund processes, and when to escalate.
• Data protection and confidentiality when dealing with vulnerability information.

Performance is tracked through call and case reviews. The handling of vulnerable-customer cases is judged on outcomes (was the customer's need met, did they have to repeat themselves, was the resolution fair and timely?) rather than on handling time.

8. Governance, monitoring and review

8.1 Vulnerable Customer Lead

A named senior employee is appointed as Vulnerable Customer Lead, with responsibility for maintaining this policy, approving training content, reviewing escalations, reporting outcomes to senior management, and serving as the point of contact for Ofcom and other regulators on vulnerability matters.

8.2 Records

We keep appropriate written records of enquiries, complaints, vulnerability flags, investigations, determinations and resolutions. Records are retained in accordance with our Data Protection Policy and are made available to regulators on request.

8.3 Key indicators

At a minimum, we monitor:

• The volume of contacts flagged as involving a customer in vulnerable circumstances.
• Time to resolution, broken down by channel.
• Refund and cancellation outcomes for vulnerable-customer cases compared with the wider customer base.
• Repeat contacts about the same issue (a signal that the customer is having to chase us).
• Complaints, including any referred to Ofcom or an ADR scheme.

8.4 Review

This policy is reviewed at least once a year, and earlier if there is a material change in regulation (including Ofcom guidance, the Regulation of Premium Rate Services Order 2024 or successor instruments), in our service, or in the issues we see from UK customers.

9. How to contact us

UK Customer Care: telephone 0800 029 4506 (freephone, 09:00–17:00 UK time on working days), or by email to productsupport@goplaybay.com. We acknowledge email enquiries and complaints within five (5) working days.

Postal address: Playbay B.V., Hurksestraat 64, 5652 AL Eindhoven, The Netherlands.

If you tell us you are in vulnerable circumstances, we will not ask you for proof or a diagnosis. We will listen, act on first contact wherever we can, and confirm in writing what we have agreed to do.