This policy sets out how Triple Tonic B.V. ("Triple Tonic", "we") identifies, supports and protects customers in vulnerable circumstances who use our services in the United Kingdom. It supplements (and does not replace) our general Customer Care Policy and our published Terms and Conditions. It applies to all Triple Tonic staff, contractors and third parties (including aggregators and operators) acting on our behalf.
It is designed to meet the expectations set out in Ofcom's General Condition C5 (Measures to meet the needs of vulnerable consumers and disabled end-users), Ofcom's guide "Treating vulnerable customers fairly", and the Regulation of Premium Rate Services Order 2024 (SI 2024/1046), in force from 1 February 2025, which extends vulnerability-related obligations to all PRS providers.
1. Our commitment
Triple Tonic is committed to providing fair, transparent and effective support to every customer, and to going further for those in vulnerable circumstances. We recognise that any customer can become vulnerable, either temporarily or permanently, and that the way we communicate, sell, bill and resolve issues can either reduce or increase the harm that vulnerability causes.
Our commitment is led from the top: senior management is accountable for embedding this policy across the organisation and for ensuring that frontline staff and third parties are equipped to deliver it. We will treat information about a customer's vulnerability with care, hold it only with their knowledge and consent, and use it solely to provide better support.
2. Who is a vulnerable customer?
We follow the widely recognised UK regulatory approach: a vulnerable customer is anyone whose personal circumstances make them significantly less able to engage with our service, make informed decisions, advocate for themselves, or absorb a financial or service-related setback. Vulnerability may be permanent, temporary or situational. The driver categories we use are:
- Health: Physical disability, long-term illness, mental health conditions, hearing or sight impairment, cognitive impairment, addiction.
- Life Events: Bereavement, relationship breakdown, domestic abuse, caring responsibilities, recent diagnosis, victim of crime or fraud.
- Resilience: Low or unstable income, problem debt, unemployment, inability to absorb financial shocks, economic abuse.
- Capability: Low literacy or numeracy, limited English, low digital confidence, learning difficulties, minor (under 18), older adult with reduced confidence.
Important: this list is illustrative, not exhaustive. A customer does not need to disclose a label or diagnosis to receive support — we look at signs and circumstances, not categories.
3. Identifying vulnerability
We do not require customers to identify themselves as vulnerable in order to receive support. We aim to recognise signs of vulnerability through any channel — phone, email, web form or correspondence from an aggregator or operator — and respond accordingly. Signs may include:
- Difficulty understanding subscription terms, charges or how to cancel.
- Repeated requests for the same information, confusion about dates or amounts, or appearing distressed, agitated or upset.
- Statements indicating that a third party (e.g. carer, family member, friend) is acting on the customer's behalf, or that the customer is the parent or carer of someone who has used the service.
- References to bereavement, illness, mental health, financial hardship, domestic abuse, or being a victim of fraud or crime.
- Statements suggesting the user may be a minor (under 18) or that the bill-payer is an older adult or someone who did not subscribe themselves.
- Difficulty using digital tools, hearing the agent, or communicating in English.
Where staff identify any of the above, they will flag the contact as potentially vulnerable and follow the support actions in Section 5.
3.1 Asking about needs
Agents will ask, at the earliest appropriate point in any contact, whether the customer has any accessibility or customer-service needs we can adapt to. Questions are framed openly, without requiring disclosure of medical, financial or personal detail.
3.2 Recording vulnerability
Where a customer shares information about their circumstances, we will, with their consent, record a brief note on our case-management system so they do not have to repeat themselves on later contacts. The note will record what help they have asked for, not a diagnosis or label. Records are held in line with UK GDPR, the Data Protection Act 2018 and our Data Protection Policy (clause 10 of our Terms and Conditions). A customer may ask us to remove or change a vulnerability note at any time.
4. Accessible communication
We will adapt how we communicate to meet a customer's needs, free of charge. On request, we can:
- Allow more time, repeat information, slow the pace of a call, or call back at a quieter time.
- Provide information in plain English, large print, or as a written summary by email after a phone call.
- Accept contact from a nominated third party — for example a family member, carer, advocate, or someone with power of attorney — provided the customer has given (or, where the customer is unable to give, the third party can evidence) appropriate authority.
- Use the UK text relay service for customers who are deaf, hard of hearing or have speech difficulties.
- Refer the customer to a specialist colleague or supervisor where their needs go beyond what a frontline agent can resolve.
4.1 Customer support availability (UK)
Our UK Customer Care team operates the following channels free to the customer, or at no more than the basic call rate where a telephone number is provided:
- Email: info@tripletonic.com, monitored every working day.
- Telephone: 0800 408 0791 (freephone from UK landlines and mobiles), 09:00–17:00 UK time on working days, with a free callback option if no agent is available.
Telephone calls are answered within best-efforts service levels. Email enquiries and complaints are acknowledged within five (5) working days and we use best efforts to resolve them without undue delay.
5. Support actions for vulnerable customers
When a customer is identified or self-discloses as being in vulnerable circumstances, the supporting agent will take the following actions, in addition to standard customer care:
5.1 Immediate cancellation
Where the customer asks to cancel a subscription, or where the contact relates to a subscription started by a minor, an older adult who did not consent, or any other person in vulnerable circumstances, the agent will cancel the subscription immediately on first contact. No further charges will be applied to the relevant number. The customer will receive a written confirmation of cancellation by their preferred channel.
5.2 Refunds and redress
Refund requests from customers in vulnerable circumstances are treated as a priority and reviewed sympathetically. In line with our standard Customer Care Policy, refunds may be granted up to the full billed value of the last six months of the subscription. For customers in vulnerable circumstances:
- Decisions are escalated to a supervisor where a refund outside standard parameters is needed to put the customer back in the position they would have been in had the problem not occurred.
- Where the subscription was started by a minor (under 18), or where the customer credibly states it was started without their knowledge or consent, we will apply a presumption in favour of a full refund, subject to supervisor review and, where applicable, confirmation from the relevant aggregator or mobile operator.
- We will not require the customer to repeatedly re-explain their circumstances; the supporting agent will gather the necessary detail in as few contacts as possible.
5.3 Protecting against further harm
Where there is any indication that a customer is at risk — for example, signs of severe financial difficulty, mental health crisis, fraud or coercion — the agent will:
- Pause any further communications about the subscription (including marketing) to the relevant number.
- Confirm cancellation in writing and provide a clear single point of contact for any follow-up.
- Where appropriate, direct customers to free independent support organisations.
- Escalate to the designated Vulnerable Customer Lead (see Section 8) for review.
5.4 Minors
Triple Tonic's services are intended for users aged 18 or over. Where we are notified, or have reasonable grounds to believe, that a minor has subscribed:
- The subscription will be cancelled immediately.
- A refund will be issued in line with section 5.2.
- The case will be logged for trend analysis and reported internally; where there is a systemic issue, we will work with our aggregator and operator partners to address the cause.
6. Working with aggregators and operators
Many of our UK-facing subscriptions reach customers through mobile network operators and aggregators. We expect those partners to operate to standards consistent with this policy, and our contracts with them require:
- Prompt forwarding of any customer complaint or refund request, especially those involving a person in vulnerable circumstances, with sufficient information for us to act.
- Co-operation with refund and cancellation requests, including where the original subscription cannot be evidenced to have been 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. A thorough investigation is conducted into the subject matter of the request and accurate information is promptly provided in response.
7. Training and culture
Every member of staff or contractor who has contact with UK customers, or who handles UK customer data, completes vulnerability training before going live and refresher training at least annually. Training covers:
- Recognising signs of vulnerability across channels, including those that customers do not disclose explicitly.
- Plain-English communication, active listening and managing difficult or distressing conversations.
- This policy, our cancellation and refund processes, and when to escalate.
- Data protection and confidentiality when handling vulnerability information.
Performance is monitored through call and case reviews. The handling of vulnerable customer cases is evaluated on outcomes (was the customer's need met, did they have to repeat themselves, was the resolution timely and fair?) rather than handling time.
8. Governance, monitoring and review
8.1 Vulnerable Customer Lead
A named senior employee is appointed as Vulnerable Customer Lead. They are responsible for: maintaining this policy, signing off on training content, reviewing escalations, reporting to senior management on outcomes, and acting as the contact point for Ofcom and other regulators on vulnerability matters.
8.2 Records
We maintain appropriate written records of enquiries, complaints, vulnerability flags, investigations, determinations and resolutions. Records are retained in line with our Data Protection Policy and are made available to regulators on request.
8.3 Key indicators
We monitor, at a minimum:
- Volume of contacts flagged as involving a customer in vulnerable circumstances.
- Time to resolution, by channel.
- Refund and cancellation outcomes for vulnerable-customer cases versus the wider customer base.
- Repeat contacts for the same issue (a signal the customer is having to chase us).
- Complaints, including any escalated to Ofcom or an ADR scheme.
8.4 Review
This policy is reviewed at least annually, and sooner 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 408 0791 (freephone, 09:00–17:00 UK time on working days), or by email to info@tripletonic.com. We acknowledge email enquiries and complaints within five (5) working days.
Postal address: Triple Tonic B.V., Pelmolenlaan 16-18, 3447 GW Woerden, The Netherlands.
If you tell us you are in vulnerable circumstances, we will not require you to provide proof or a diagnosis. We will listen, act on first contact wherever possible, and confirm in writing what we have agreed to do.