In response to a TODAY story, Trilegiant issued the following statement about its membership clubs and disclosures online:
Consumers sign up for our services because we offer them a great value. The enrollment process for all of our services involve multiple steps to ensure that consumers understand they are signing up for a service that will charge them. We have more than 65 million subscribers to our programs worldwide, and more than 5,300 leading companies around the world trust us to work with their customers. We could not have achieved this level of success without providing consumers a wide range of valuable services at low cost, or without adhering to the highest standards of legal and ethical behavior. We strive to achieve complete customer satisfaction and apply a full money back refund policy as appropriate.
Range of benefits for consumers
For over 35 years, we have been providing consumers with significant benefits through our innovative programs:
We operate one of the ten largest leisure travel agencies in the U.S., saving consumers millions of dollars annually in travel bookings and providing a low-price match on any competitor's price
We have been protecting more individuals from the crime of identity theft for longer than any other company, and have been the industry-leading innovator in developing tools and technology to adapt to this crime; we recently identified the imminent risk of identity theft for up to 200,000 consumers whose personal information was at risk following the data breach of a retailing merchant
We provide a low-price guarantee on brand name products from thousands of manufacturers, along with an automatic 2-year extension of the manufacturer's warranty and 3.5% cash back on purchases
Our insurance programs have paid out over half a billion dollars in benefits in the past three years alone, providing critical support to families when and where they need it most.
We make every effort possible to ensure that we do everything to continue to earn the trust of companies and consumers. That includes creating high value services, and offering them in exceptionally clear terms, so that a consumer can see the benefits and the costs, and make an informed decision about whether to participate. Last year we received less than 1 complaint for every 1 million offers made.
The offers we make to consumers are exceptionally clear, well understood by virtually all recipients, and of high value to the millions of people who sign on or renew each year. We make it as easy as possible for consumers to discontinue their enrollment in any one of our services through 24 by 7 support, and to receive a refund with full money back as appropriate.
Here's how an offer works
All of our offers are designed to ensure that a consumer understands the service they are signing up for. To begin, the consumer must first click on the special offer (typically an icon with promotional language such as "Save 15% off your next purchase"); an offer is never presented as a "pop up" window.
To decline an offer
- To decline an offer, all a consumer has to do is click once on the "No thanks" button, or close the browser, or navigate to a new address in the same way one does from any webpage.
- Selecting "No thanks" takes the consumer back to where they began.
To accept an offer
- Signing up for a service is a process with multiple steps to ensure that a consumer is signing on fully informed about the benefits, terms, conditions, and cost.
- To use any service, a consumer must fill out a form requiring certain information, such as mother's maiden name and date of birth, and must agree to terms and conditions. To reinforce that they are enrolling in a service, consumers must create their own password.
- Following the enrollment, a member is then sent a package to confirm their subscription
and reiterate the terms of their membership, including the expiration date of their free trial and the one-stop process needed to cancel the service at any time, 24 hours a day.
- Members receive regular ongoing communications through branded catalogs, brochures, letters and other material to keep them informed of changes and upgrades to the features of their service.
- In short, numerous safeguards are in place to make sure that a consumer understands the value of the service we are offering online, as well as the cost of that service.
What does an online offer look like? The leading text at the top of the webpage explicitly links the incentive offer to enrollment in a membership program, using phrases such as “receive your reward with your first thirty days of [the branded program]” or “get your reward by joining [the branded program]”. We believe this makes it clear that someone is reviewing a service that will require a fee.
Completing an online enrollment form is always required, and this form requires the customer to enter certain personal information, such as mother's maiden name, date of birth, and, depending on the program, re-entry of their billing information, including credit card number and expiration date. Regardless of the program, the customer is also always required to create a unique password that will become specific to them during their membership period.
The headline to the form includes the brand name of the program, and includes words such as "your trial", "savings club" and "your first month of savings".
The benefits to the program itself are summarized on the webpage, using the same style and font as other text on the webpage, to inform the consumer about the program.
The terms and conditions — which describe the trial period and the billing process — are presented multiple times on the same webpage, and in the same standard font size as the main text on the webpage, with at least one complete description of the terms and conditions always located either directly next to, or immediately below, the enrollment form.