Marketing of customer loyalty programmes must describe the conditions according to which benefits can be obtained, including possible joining fees and whether personal data must be provided. The availability of the full terms and conditions of the customer loyalty agreement must also be indicated.
Predominance of loyalty discounts
Marketing discounts or benefits given to all customers as loyalty benefits is misleading.
Loyalty benefits may not be the predominant element of marketing materials intended for all consumers. The price to loyal customers may only assume the central focus in marketing that is directed only at members of the loyalty programme.
Loyalty prices and bonuses
The price that is generally applicable to a product is the primary price information to be provided. It must be clearly and unambiguously presented in marketing materials, so that it receives at least as much attention as the price offered to loyal customers.
Bonuses obtained on purchases may not predominate in marketing directed at either loyal customers or all consumers. Information on bonuses may not be misleading. If specific information is given on bonuses, then the conditions applicable to receiving these bonuses must also be indicated. Information on bonuses may be provided by giving typical examples.
In customer loyalty programmes, those paying on credit may not receive better benefits than cash customers.
Partners’ pricing information
If the bonuses received from a customer loyalty programme can be increased by making an ongoing service agreement with a separate business, then sufficient and clear price information on the services in question must be indicated.