Pricing Disclosure Policy

This policy is drafted to align with global platform standards (Shopify/Stripe-style) and anchor to the strictest legal regimes, including the EU Omnibus/Price Indication Directive (30-day prior price and total-price display), FTC Guidance/California SB 478 Honest Pricing (ban on drip pricing), and PSD2/payment rules on FX disclosure and fees. The objective is to show the all-in price upfront, reduce risk of misleading/deceptive pricing, and ensure customers see the true payable amount before confirming payment. These are operational requirements for product/legal/marketing to implement in UI/Checkout, pricing/promotions, tax/shipping/FX handling, and evidence/log retention for audits and multi-jurisdiction compliance.

Scope includes (1) total price display with only narrow exceptions for government taxes and shipping (FTC fees policy, CA SB 478, EU PID) (2) 30-day prior price on promotions with price-history logs (EU Omnibus/PID) to mitigate risk under UK CPRs/CRA and AU ACL (3) auto-renewal flows with express consent and click-to-cancel per FTC Negative Option and US state laws (e.g., CA/NY), plus consent and pre-renewal notice records for ≥3 years (4) FX/markup disclosure at Checkout per PSD2/payment network guidance.

Sources of truth (in priority order, highest first when conflicts arise):

1. Live Pricing page at https://tanqory.com/pricing — the binding offer to customers.
2. Canonical pricing source of truth at apps/legal/_compliance/sources-of-truth/10-pricing.yaml (v2.1, effective 2026-06-05) — the authoritative schedule of subscription tiers, AI credit packs, plan bundles, add-ons, metered SKUs, cloud SKUs, domains, marketplace commission, and currency display rules. The accompanying commercial narrative lives in apps/legal/docs_company/commercial/pricing-policy-v2-dev-brief.md. This Disclosure Policy references — but does not duplicate — the prices, credit allowances, seat counts, trial mechanics, refund-window values, and feature-bundle decisions defined in the YAML.
3. This Disclosure Policy — the compliance-side operational rules (drip pricing, EU 30-day prior price, FTC Negative Option, FX/tax disclosure) that govern how the prices in (1) and (2) are presented.
4. Latest signed Order Form (Enterprise customers) — overrides (1)–(3) for the contracting party only, to the extent the Order Form expressly addresses the disputed item.
5. Invoice / confirmation emails — last-resort tie-breaker for individual transactions.

All price changes must be logged with timestamps. The requirements below are mandatory operational rules above the principles section, so Tanqory can operate transparently, reduce enforcement risk, and meet global platform expectations.

Immediate Operational Requirements (Platform/Checkout)

To comply with global standards and key laws (CA SB 478 Honest Pricing/FTC Fees Policy, EU PID, PSD2 FX disclosure), Tanqory must show an all-in price from the first screen (Landing/Product/Cart/Checkout), bundling all mandatory fees and excluding only government taxes and shipping that cannot yet be calculated. Provide estimated taxes/shipping or a calculator before the confirmation button to avoid misleading consumers, and ensure the total price is prominent (not obscured by promotions/coupons).

Display the binding currency (e.g., EUR/GBP for EU/UK B2C) with symbol/code and local rounding. If converting/quoting a secondary currency, show the FX rate and any markup with a note that the price includes FX risk management. In the US, show total price upfront per SB 478 while separating state tax before confirmation; in EU/UK/AU show VAT/GST-inclusive consumer prices.

All promotions must display the “prior price” = lowest price in the preceding 30 days (EU Omnibus/PID) on promo pages/banners, with a 30-day price log to substantiate under FTC 16 CFR 233, UK CPRs/CRA, and AU ACL. For flash sales or restocks, use the actual prior price from the last sale within the 30-day window and log the event.

Subscriptions/auto-renewals: obtain express, informed consent separate from other consents before collecting payment info; disclose billing cycle, amount, charge date, and cancellation method; provide an online “cancel” that is as easy as signup (click-to-cancel). Send pre-renewal notices 15–45 days before renewal for terms ≥1 year (CA baseline) and retain proof of notices/consent for ≥3 years.

Other regions: EU/UK/AU use VAT/GST-inclusive pricing; US honors UDAAP/FTC/SB 478; show currencies consistent with target market and local rounding. Prioritize price sources: (1) live Pricing/Dashboard (2) latest Order Form (3) invoice/confirmation. If conflicting, follow that order. Pricing/add-ons/infrastructure costs published on the Pricing site are more authoritative than offline materials. Log/timestamp all price changes, promotions, and customer communications for auditability.

Comprehensive Global Pricing Disclosure Policy Report
Section 1: Global legal imperatives for price disclosure

1.1 Introduction: The need for a comprehensive global pricing disclosure policy
Operating cross-border exposes Tanqory to diverse, stringent consumer protection regimes. A unified, high-watermark pricing disclosure policy is strategically necessary to protect brand trust and manage legal risk across core jurisdictions (EU, US, APAC). The objective is to ensure Tanqory’s advertising and price presentation are truthful, non-deceptive, and substantiated (FTC standards), with sufficient evidence to support any price claims.

Failure to comply can trigger significant financial exposure. Under the EU Omnibus Directive, violations of price transparency can lead to fines up to 4% of annual turnover in the Member State concerned. Adopting the strictest rules in each region as a global baseline is the most effective way to reduce operational risk and build consumer confidence.

1.2 Convergence on the “total price” principle
1.2.1 Prohibition of drip pricing

Drip pricing—hiding unavoidable fees late in the purchase flow so the initial price is lower than the true payable amount—is treated as unfair/deceptive in many jurisdictions. In the US, California’s Honest Pricing Law (SB 478) and FTC junk-fee guidance require the advertised price to be the final price (“the price is the price”), including all mandatory fees (e.g., handling, payment, card, platform). Non-compliance risks UDAAP liability and similar state laws.

In the EU, the Price Indication Directive (PID) and Omnibus require the communicated price to be all-inclusive, except for taxes/duties and shipping that cannot yet be calculated. In the UK, the CPRs and CMA view hidden mandatory fees as misleading. In Australia, the ACCC/ACL treats drip pricing as deceptive and has imposed significant penalties (notably in travel/ticketing). Using the strictest standards from CA/FTC/EU/UK/AU as a baseline reduces risk globally.

1.2.2 Permitted narrow exceptions to total price

While total price is required, consumer law allows narrow exceptions where the seller cannot set the amount upfront:

1. Government taxes/duties/fees that vary by location or buyer tax data
2. Shipping/delivery costs that depend on destination, weight, or method

Key guardrails:

• Show estimated tax/shipping or a calculator at Checkout before confirmation so consumers see the expected payable amount (FTC Fees Policy, CA SB 478, EU PID).
• If itemizing mandatory fees, do not downplay the all-in price; font/placement must be at least as prominent as line items.
• Do not separate mandatory fees that belong in the all-in price (e.g., “system fee,” “card fee,” “processing fee”)—these are unavoidable (see enforcement by CMA UK, ACCC AU, CFPB/FTC US).
• In markets requiring tax-inclusive display (EU/UK/AU for B2C), include tax in the shown price; for tax-exclusive B2B, clearly state “price excludes VAT/GST.”
• If user options affect price (e.g., shipping upgrade/packaging), show option prices transparently before selection and update the all-in price immediately after selection.

Enforcement exposure:

• EU Omnibus: up to 4% of annual turnover in the relevant Member State.
• US/CA: consumer/class actions and civil penalties by authorities.
• UK CPRs/CRA and AU ACL: fines, redress, corrective orders.

Operational note: Set all-in price as default on every page; use tax/shipping estimators before confirmation; avoid separating mandatory fees; retain evidence of total price/itemization for disputes/audits.

Key requirements:

• Display estimated tax/shipping or a calculator at Checkout before confirmation so consumers see the expected payable amount (FTC Fees Policy, CA SB 478, EU PID).
• If itemizing mandatory fees, do not downplay the all-in price; font/placement must be at least as prominent as line items.
• Do not separate mandatory fees that belong in the all-in price (e.g., “system fee,” “card fee,” “processing fee”)—these are unavoidable (see enforcement by CMA UK, ACCC AU, CFPB/FTC US).
• In markets requiring tax-inclusive display (EU/UK/AU for B2C), include tax in the shown price; for tax-exclusive B2B, clearly state “price excludes VAT/GST.”
• If user options affect price (e.g., shipping upgrade/packaging), show option prices transparently before selection and update the all-in price immediately after selection.

Enforcement exposure:

• EU Omnibus: up to 4% of annual turnover in the relevant Member State.
• US/CA: consumer/class actions and civil penalties by authorities.
• UK CPRs/CRA and AU ACL: fines, redress, corrective orders.

Operational note: Set all-in price as default on every page; use tax/shipping estimators before confirmation; avoid separating mandatory fees; retain evidence of total price/itemization for disputes/audits.

1.3 Jurisdiction-specific price disclosure requirements
1.3.1 European Union (EU): Accuracy of discounts

The EU Omnibus Directive and Price Indication Directive (PID) require both total-price transparency and accurate discount/prior-price display:

• 30-Day Rule: Every reduction must show the “prior price” = lowest actual retail price in the previous 30 days. For flash sales/restocks, use the last actual sale price within 30 days, not a fictitious price.
• Recordkeeping: Maintain verifiable price history per product/service/plan for consumer authorities.
• Tax and display: B2C prices must be VAT-inclusive; if B2B or excluding VAT, state “price excludes VAT” and show VAT before confirmation.
• Personalized pricing: If personal data/profiling is used to adjust prices, disclose at the offer/Checkout per Omnibus.
• Paid placement/ranking: Disclose when ranking/badges are paid so users do not assume purely merit-based ordering.
• Penalties: Violations can trigger fines up to 4% of annual turnover in the Member State, plus corrective orders/refunds.

Operational (EU/EEA):

• Keep price history ≥30 days and 12–24 months for internal audit; show prior price on promo pages/banners with the applicable period.
• Ensure UI keeps prior price visible; promo text must not obscure it.
• If using personalized pricing, provide clear disclosure, record logic/factors, and offer opt-out as required.
• Ensure B2C prices are VAT-inclusive; if not, label clearly that VAT is excluded.

1.3.2 United States (US): Avoiding deceptive price comparisons

FTC and state laws (including CA SB 478 and state deceptive pricing rules) require truthful, non-misleading, substantiated pricing:

• Comparative/reference pricing: Claims like “regular price,” “other retailer price,” or “comparable value” must be supported by actual market prices (e.g., comparable local retailers), not inflated anchors.
• Materiality: Discounts must be meaningful, not trivial, to avoid deceptive impressions.
• Auto-renewal/negative option: Obtain express informed consent separate from other consents; disclose billing cycle/amount/charge date/cancellation; provide click-to-cancel; send pre-renewal notices per state rules (e.g., CA 15–45 days).
• Total price/Junk Fees: SB 478 mandates all mandatory fees upfront except taxes/shipping; FTC/CFPB pursue junk-fee enforcement under UDAAP.
• Evidence/records: Retain UI scripts, screenshots, timestamps of price/promo displays, and consent/notice for at least 3 years.
• Cooling-off/refund: Some categories have specific rescission/refund rights; disclose them in offers/materials.

Operational (US):

• Avoid “compare-at” pricing without external substantiation; use actual prior price or proven market price.
• Show total price from the first page and use tax/shipping estimators before confirmation.
• Implement click-to-cancel and pre-renewal notices per CA/state; log consent/notice.
• Review promos against FTC Guides 16 CFR 233; avoid misleading comparisons.

1.3.2.1 Annual subscription cool-off window — start date (added v7.3)

Annual subscription plans (per Pricing v2.1 source-of-truth billing_rules section) include a 14-day cool-off window as Tanqory's global baseline, harmonized with EU Consumer Rights Directive (Directive 2011/83/EU Art. 9–16) for EU/EEA consumers. The 14-day clock starts on the date of the initial Annual purchase, not on the date of any subsequent renewal:

• A first-time Annual subscriber is entitled to a pro-rated refund (minus one month of usage, per Pricing v2.1 source-of-truth billing_rules section) if they cancel within 14 days of the initial purchase date.
• A renewal of an existing Annual subscription is a continuation of the original contract and is non-refundable — no fresh 14-day window applies, consistent with EU CRD Art. 16(a) (services already supplied) and US/CA standard SaaS practice.
• This rule must be visible at the point of sale (Pricing page Annual upgrade flow + Checkout review screen) using language equivalent to: "Annual plans include a 14-day cool-off from your first purchase. Renewals are non-refundable."
• The order confirmation email for first-time Annual subscribers must state the cool-off end date in customer-local time.

Evidence retention: keep the initial-purchase timestamp, the cool-off end timestamp, the cancellation timestamp (if any), and the refund calculation for ≥3 years (per Section 10.1).

1.3.3 Singapore (SG): Advertising and consumer pricing compliance)

Singapore’s CPFTA and SCAP prohibit misleading pricing, including drip pricing and fake discounts:

• Unfair Practice: Failing to disclose mandatory fees upfront may be an unfair practice; CCCS can enforce.
• Price Display/GST: Show all mandatory fees; if GST/shipping cannot yet be calculated, show GST rate and estimated shipping. If GST is excluded, label “price excludes GST” and show GST before acceptance.
• Comparative Pricing: “Regular” or reference prices need evidence of genuine prior sales (SCAP misleading savings).
• Subscription/Auto-renewal: Disclose material terms (amount, billing cycle, charge date, cancellation) clearly; provide an easy online cancellation channel.
• Personalized Pricing/Data: If personal data is used to set prices, disclose purpose and obtain consent/opt-out consistent with PDPA (SG) and Omnibus (EU) where applicable.

Operational (SG):

• Show all-in prices and GST before payment; if GST-exclusive, label clearly.
• Avoid “compare-at” pricing without evidence; keep records of actual sales and periods.
• No drip pricing/hidden fees; option-based fees must be shown before selection and update totals immediately.
• For subscriptions/auto-renewal, disclose cycle/amount/date/cancellation and log consent and pre-renewal notices per CPFTA/regulator guidance.

1.4 Transparency in cross-border transactions and FX fees
1.4.1 FX conversion fee disclosure

Cross-border payment laws (e.g., EU PSD2, related US guidance) require disclosure of FX rates, transfer fees, and total amounts. Tanqory generally embeds FX conversion fees (e.g., 2.5%) in the product price so customers see the final local-currency amount at Checkout. This lets customers understand the total and reduces unexpected issuer FX charges.

1.4.2 VAT/GST and de minimis thresholds

Government taxes and import duties may be excluded from initial advertised prices but must be calculated/disclosed at Checkout. Sellers shipping into the EU must collect local VAT/GST. Tanqory must inform customers about de minimis thresholds; if an order exceeds the threshold (varies by country, e.g., AU AUD 1,000), the customer may owe additional duties/import taxes levied by destination customs.

Part 2: Tanqory pricing disclosure policy

4. General pricing and transparency provisions
Section 4.1 Principle of total price disclosure

Tanqory requires prices shown to consumers to be all-inclusive (the maximum net price payable), to comply with the strictest anti-drip-pricing regimes globally.

1. Inclusion of fees: The total price must include all mandatory fees (e.g., handling, payment fees, other foreseeable costs). Permitted exceptions: initial display may exclude only (a) government taxes/duties and (b) shipping/delivery. These excluded items must be shown clearly at Checkout before order confirmation.
2. Itemization: If mandatory fees are itemized, they must not obscure or downplay the all-in price.

Section 4.2 Fair pricing

Tanqory must ensure pricing is fair and not misleading under consumer protection laws (FTC/UDAAP, UK CPRs/CRA, AU ACL, SG CPFTA). Pricing operations must be transparent across base pricing, tax/fee display, and promotions:

• Avoid “regular”/“compare-at” prices not genuinely offered, or used to create fake discounts.
• Keep all-in pricing as the default across channels, except for legally allowed tax/shipping exclusions, and show estimates before confirmation.
• Maintain prominence: net/total price must be as or more prominent than any sub-line items.
• Singapore: align with CPFTA/SCAP—no drip pricing; comparative pricing requires evidence; if GST is excluded, label “exclusive of GST” and show GST before confirmation.

5. Promotional and discount policy
Section 5.1 Reference price rule

1. EU 30-day rule: For price reductions in the EU/EEA, display the prior price = lowest retail price in the preceding 30 days.
2. Genuine discount: Globally, advertised discounts must be genuine/meaningful, not trivial.
3. Evidence/logging: Keep a 30-day lowest-price log used on promo pages/banners with timestamp/period, to substantiate under Omnibus/PID, SCAP (SG), FTC 16 CFR 233, UK CPRs, AU ACL.
4. Comparative/“compare-at” pricing: Only use when supported by actual market prices in comparable channels/retailers—not inflated anchors.

Section 5.1.1 Bundle savings substantiation (added v7.3 — example refreshed v7.4 after AI Agent paid SKUs were removed)

Any bundled-pricing claim must be substantiated under FTC 16 CFR 233 (Guides Against Deceptive Pricing), EU UCPD Annex I §20 (claims of a particular price advantage), and SG SCAP rules on comparative pricing. Tanqory must hold evidence that each component product is actually sold at the catalog price reflected in the savings calculation:

1. Catalog-price evidence. Retain dated catalog snapshots showing each component at its individually-purchasable price for the entire period the bundle claim is displayed. Example for the v2.1 catalog: an annual subscription claim such as "Save 25% on Scale Annual" must be backed by snapshots showing Scale monthly at $399 and Scale annual at $3,588 (= 25% off monthly × 12). Snapshots are retained alongside the 30-day price-history log (Section 10.1). Note: v2.1 removed the v1.1 "AI Team Workspace $149/mo" paid bundle along with the four AI Agent paid SKUs (AI Marketing $19, AI Support $29, AI Sales $49, AI Commerce $99); those capabilities are now bundled into the subscription plans and metered via the shared native-AI credit pool, so a "Save with AI Workspace" bundle claim is no longer applicable.
2. Active SKU verification. Each component must be a live, purchasable add-on at the quoted price during the entire time the bundle-savings claim is displayed. If any component is discounted, withdrawn, or its price changed, the bundle-savings claim must be recalculated or withdrawn within 24 hours (Section 8.1 SLA).
3. Materiality. Bundle savings below 5% are not advertised as "savings" (per FTC §233.1 materiality guidance and EU UCPD genuineness requirement).
4. Rounding and presentation. Savings figures must be exact, not rounded up. Both the bundle price and the component-sum reference price must be visible side-by-side at the bundle's point-of-sale.

Section 5.2 False urgency messaging

Do not use false urgency/scarcity (fake timers, fake remaining stock, fake limited-time/stock) to avoid misleading practices under FTC (US), CPRs/CRA/ASA CAP (UK), ACL (AU), CPFTA/SCAP (SG), and other local rules. Claims like “only X left” or “ends in Y minutes” must rely on verifiable data updated in real time or reasonable intervals; otherwise it is false scarcity. For time/quantity-limited promos, state actual end date/time, timezone, remaining quantity/quota, update promptly, and stop urgency messages when limits are hit. If specials end, remove or update the messaging immediately.

Internal controls: Require backend data for stock/quota, promo owner approval, and auto-stop when stock/time ends. Avoid dark patterns (e.g., self-resetting timers, fake “others viewing” counts). If offers expire, show true status (“promotion ended”/“regular price”).

Evidence: Keep UI/message copies with timestamps and matching stock/quota data for authority inquiries (FTC, CMA, ACCC, CCCS). SCAP/CPFTA treat false urgency as misleading/unfair; in the US, false urgency can be UDAAP. Run A/B tests only with truthful data and legal/ethics review. If using third-party metrics (views/orders), verify accuracy; avoid unverifiable exaggeration. After promos, record outcomes (e.g., sold out/claims used) for dispute defense and future compliance.

Section 5.3 Personalized pricing disclosure

If automated decision-making/profiling sets individualized prices, disclose clearly in required markets (EU Omnibus, SG PDPA, FTC/CFPB/state rules):

• Explain data used (e.g., usage history, purchase behavior, location); avoid prohibited/sensitive data (race, religion, health) to prevent unfair discrimination.
• Explain factors affecting price (e.g., usage level, plan/region, time), not vague wording.
• Provide opt-out/withdrawal where required (PDPA/Omnibus); if using legitimate interest, perform balancing tests and offer objection mechanisms.
• Record reasons/factors and evidence of disclosure/consent (timestamps/UI/messages) for audit.
• Test AI/ML models for bias; offer human review for complaints.
• US: if pricing intersects negative option/auto-renewal or credit/payment data, disclose key terms before consent per FTC Negative Option/UDAAP.
• EU: if automated decisions have legal/similar significant effects, honor GDPR Art. 22 rights, provide summary logic, human review option, and likely effects.
• SG: disclose PDPA purpose for personalized pricing and provide accessible opt-out/withdrawal.
• UI must be clear near pricing/checkout or settings, with a “learn more” link; keep change logs (version/date/approver). If offers are behavioral, state they are tailored (not general catalog pricing). Provide a contact channel and SLA to contest perceived unfair pricing.

6. International transactions and FX
Section 6.1 FX conversion fee disclosure

1. Final price display: Show the final local-currency price at Checkout and in confirmations to reduce FX/DCC disputes. If offering DCC/choice of currency, show the binding amount in the chosen currency and explain any differences between Tanqory conversion vs issuer.
2. Fee explanation: Clarify that the shown price includes FX risk/markup (if any) and is part of the all-in price, not a separate add-on, to avoid drip pricing (PSD2/FTC/Junk Fees/CPFTA/SCAP).
3. Rate/markup disclosure: Show the FX rate used, date/time reference, and any markup (PSD2/EU, MAS/CCCS if applicable). If using mid-market + markup, state the percentage or a clear explanation; if rates refresh periodically, state the refresh cadence.
4. Consumer notice: Provide concise UI/receipt language (e.g., “This amount is calculated with the FX rate at checkout and includes any FX risk markup; the binding amount is the local-currency total shown before you confirm”). Note that issuer rates/fees may differ if the customer selects issuer conversion.

• DCC/FCA/MAS/card scheme note: When offering DCC, show the DCC rate alongside mid-market/issuer comparison, honor the customer’s choice of billing currency, and disclose that issuer conversion may differ (per FCA UK, MAS/CCCS SG, Visa/Mastercard rules).
• FX SLA/logging: Refresh FX rates at least every 30 minutes or pull live at Checkout; log rate/time/provider per order for audit/disputes.
• Opt-out/consent example for personalized pricing: In settings, provide text such as “We may tailor prices/offers to your usage; turn this off to opt out” with a toggle and timestamped record.
• QA/staging: Every release must QA FX (including DCC toggle) and tax estimators in staging before production to prevent mispricing.

Section 6.2 VAT/GST and de minimis thresholds

Tanqory must calculate and display VAT/GST at Checkout per destination law and state that:

• EU/UK/AU/SG B2C: prices should be tax-inclusive, or if excluding, clearly label “price excludes VAT/GST” and show the rate/amount before payment.
• US: show state/local tax (where nexus exists) before confirmation.
• De Minimis: warn that orders above the destination threshold (e.g., AU AUD 1,000) may incur duties/import taxes from customs.
• If tax cannot be fully calculated from current data, request tax/address info before finalizing and note taxes may adjust once data is complete.
• Keep evidence of tax calculations and displayed totals (invoice/confirmation/UI) for internal audit and disputes.
• Customer messaging: Add notices such as “Taxes calculated from the info provided at checkout; amounts may change if tax/address data is incomplete” and “Orders above de minimis may incur customs duties/taxes at destination.”

Part 2: Tanqory pricing disclosure policy

4. General pricing and transparency provisions
Section 4.1 Principle of total price disclosure

Tanqory requires consumer-facing prices to be all-inclusive to comply with the strictest anti-drip-pricing rules.

1. Inclusion of fees: Total price must include all mandatory fees (handling, payment, other foreseeable costs). Permitted exclusions: (a) government taxes/duties and (b) shipping/delivery; these must be shown clearly at Checkout before order confirmation.
2. Itemization: Itemized mandatory fees must not obscure/downplay the all-in price.

Section 4.2 Fair pricing

• Avoid fake “regular/compare” prices; keep all-in default; ensure prominence; align with CPFTA/SCAP for SG (no drip pricing; evidence for comparative prices; GST labeling if excluded).

5. Promotional and discount policy
Section 5.1 Reference price rule

1. EU 30-day prior price; 2. Genuine discount; 3. 30-day lowest-price logs with timestamps for substantiation (Omnibus/PID, SCAP, FTC 16 CFR 233, UK CPRs, AU ACL); 4. “Compare-at” only with real market evidence.

Section 5.2 False urgency messaging

• No fake timers/stock; time/quantity limits must be real, with clear end time/timezone, real remaining stock/quota, auto-stop when exhausted.
• Internal controls: backend data, promo-owner approval, auto-stop; avoid dark patterns; show true status when ended.
• Evidence: keep UI/timestamps + stock/quota data; false urgency may be UDAAP/unfair (FTC/CMA/ACCC/CCCS); A/B tests must remain truthful; verify third-party metrics; record outcomes post-promo.

Section 5.3 Personalized pricing disclosure

• Disclose data/factors; avoid sensitive data; provide opt-out/withdrawal where required; log disclosure/consent; test bias; offer human review; comply with FTC/CFPB/state, GDPR Art.22, PDPA; clear UI near pricing with “learn more”; keep change logs; note tailored vs catalog prices; provide contact/SLA for disputes.

6. International transactions and FX
Section 6.1 FX conversion fee disclosure

• Final local-currency display; DCC choice with explanations; clarify embedded FX/markup; disclose rate/time/markup; customer notice about issuer conversion differences; DCC comparison per FCA/MAS/card schemes; FX refresh/logging; opt-out text example; QA/staging for FX/tax estimators each release.

Section 6.2 VAT/GST and de minimis thresholds

• Tax-inclusive for EU/UK/AU/SG B2C or clear exclusion labels; US tax shown before confirmation; de minimis warnings; request data if tax incomplete; retain evidence; add customer notices about possible adjustments/duties.

Section 6.2.1 Prepaid AI Credit Pack expiration disclosure (added v7.3)

For AI Credit Packs (per Pricing v2.1 source-of-truth ai_credit_packs section), purchased credits remain valid for 12 months from the purchase date and then expire (expired credits are forfeit and not refunded). Because the 12-month expiry is a material term of the contract — a digital good with a time-limited consumption window — it must be disclosed before checkout to satisfy:

• EU Consumer Rights Directive (Directive 2011/83/EU) Art. 6(1)(o) — "the duration of the contract, where applicable, or the conditions for terminating the contract" — and Art. 8 (formal pre-contract requirements).
• SG CPFTA s.4(b) — misleading omissions of material information; SCAP rules on prepaid product terms.
• UK Consumer Rights Act 2015 s.50 — information about services to be binding.

Operational requirements:

1. Pricing page disclosure — Each Credit Pack product card on https://tanqory.com/pricing must show "Credits expire 12 months from purchase" with the same prominence as the price and credit count.
2. Cart line-item disclosure — Cart and Checkout-review screens must restate the 12-month expiry per pack.
3. Order confirmation — The order confirmation email must state the explicit expiry date (purchase_date + 12 months) in customer-local format for each pack purchased.
4. Pre-expiry reminders — Reminder emails at 60, 30, and 7 days before expiry are sent to the account email, modeled on the reasonable-notice standard in CA ARL §17602(b). These are reminders, not consent collections; their delivery is logged ≥3 years.
5. Consumption-order disclosure — Because purchased credits drain before subscription credits (Pricing v2.1 source-of-truth ai_credit_packs section), this rule must also be disclosed on the Pricing page Credit Pack section to satisfy SG CPFTA s.4(c) (no misleading "burn order") and EU UCPD Art. 7 (material information).

Part 3: Implementation and compliance

8. Pricing error management
Section 8.1 Regular review and update

• Proactive QA (rule-based/automation), price-change logs with timestamps/approvers/reasons, publish binding updates on Pricing/Order Form within SLA (e.g., 24 hours), error playbook (pause sales or honor/cancel per local law with transparent comms), regression tests before promo/price releases and use staging.

Section 8.2 Contract formation clause

• Prices are an invitation to treat; binding contract on explicit acceptance (shipment/separate acceptance email). Keep disclaimers clear and consumer-law compliant; assess obvious mistakes per local law; communicate with appropriate remedies; record incidents (root cause, affected orders, fixes, comms).

9. Oversight and internal training
9.1 Pricing ownership: assign an executive/lead owner; require annual (or pre-campaign) pricing audits covering base price, tax, FX/shipping fees, promos/prior prices.

9.2 Training: Regular training for sales/marketing/product/legal on Omnibus/PID (EU), FTC/CFPB/state (US), CPFTA/SCAP (SG), SB 478 (CA), auto-renewal/click-to-cancel. All ads/banners/landing pages require legal/QA review; keep training/review evidence for audits.

10. Technology and monitoring
10.1 Robust price monitoring system: retain ≥30-day price history (and longer internally), UI/banner evidence with timestamps (FTC 16 CFR 233, UK CPRs/CRA, AU ACL), auto-check all-in pricing (SB 478), link logs to Pricing/Order Form/invoice as sources of truth, retain consent/notice logs ≥3 years (FTC Negative Option/state auto-renewal).

10.2 Platform alignment: comply with marketplace/app-store pricing rules (no drip; total price upfront); automated scans for misleading comparisons/prior-price mismatches (FTC 16 CFR 233, UK CPRs); alert/SLA to fix price/promo discrepancies.

11. Free trial and intro-price disclosure (revised v7.5)

Tanqory offers a 3-day free trial, no payment card required to start (Enterprise: 30-day trial via Order Form) for the Starter, Growth, Business, and Scale monthly subscription plans. Selecting and confirming a plan ends the trial: a customer who selects and confirms a plan, at any time during or after the 3-day trial, is charged US$1.00 at that moment for their first billing month (the net price of the first billing period for whichever eligible monthly plan is active — not a fixed discount tied to one plan); after that first month, the subscription renews automatically at the plan's regular price until cancelled. The Terms of Service (Free Trial) incorporate this Section 11.

Because (a) confirming a plan converts the trial into a paid US$1 first month, and (b) the subsequent renewal at the regular price is a "negative option" under US law and a "trader-initiated subscription contract" under EU law, the following operational requirements apply globally per FTC Negative Option Rule (16 CFR Part 425, 2024 final rule), California Automatic Renewal Law (Cal. Bus. & Prof. Code §§17600–17606), EU Consumer Rights Directive (Directive 2011/83/EU) as amended by the Modernisation Directive (Directive 2019/2161), Singapore CPFTA s.4 (misleading practices), and UK Consumer Rights Act 2015 + CMA enforcement on subscription traps:

11.1 Trial-start disclosure. At signup, before the trial starts, Tanqory must clearly state: the trial length (3 days), that no payment card is required to start the trial, that selecting a plan ends the trial and a payment method is required to select a plan (and to continue after the trial), the US$1 first-month price, and the plan's regular price that applies from the second billing month.

11.2 Pre-charge disclosure (trial → US$1). Because no card is on file during the trial, the US$1 first-month charge only occurs after the customer affirmatively selects and confirms a plan and payment method. That confirmation screen (including a hosted checkout page) must, in the same field of view, disclose:

1. Charge amount and timing. The US$1.00 amount, the currency, and that it is charged today, when the plan is confirmed (e.g. "US$1.00 today for your first month") — never described as charged "after your trial".
2. Auto-renewal terms. That the subscription renews automatically at the plan's regular price after the first billing month, stating the plan name and the regular-price amount that will apply from the second month.
3. How to cancel. A clear, one-sentence statement of how to cancel (per the click-to-cancel mechanism in Section 11.4), with a visible link or button to the cancellation flow, before the customer confirms the charge — not buried in a separate Terms link.

Items 1–3 must all be visible on the confirmation screen without an extra click; none may be satisfied only by a linked-out Terms of Service section (per FTC §425.4/§425.5 — clear-and-conspicuous disclosure of the negative option's material terms). The customer's express, affirmative consent to these terms (a required control that is not pre-selected) must be captured before the charge, and the consent event is retained under Section 11.8.

11.3 Pre-renewal notice (US$1 month → regular price). Before the first US$1 billing month converts to the plan's regular recurring price, Tanqory must send a notice via email and in-app at least 7 days before the regular-price charge date. If that notice has not been delivered at least 7 days before the regular-price charge date, Tanqory will not charge the regular price until 7 days after the notice is delivered. The notice must clearly state:

• The regular-price charge date and time (customer-local).
• The recurring charge amount, currency, and billing cycle.
• The payment method that will be charged (last 4 digits).
• A one-click link to cancel before the charge is taken.
• The plan name and a link to current Pricing.

11.4 Click-to-cancel parity. Cancellation during the trial, during the US$1 month, and after conversion to the regular price must be available through the same channel as signup: web for web signup, app for app signup. The cancellation flow must require no more clicks than the signup action, must not require a phone call, support email, or wait on hold, and must not present retention offers as a precondition to cancelling (per FTC §425.6 — "simple cancellation mechanism"). Cancelling during the trial incurs no charge; cancelling after the US$1 month avoids the regular-price renewal.

11.5 Eligibility gating (updated 2026-09-21 — owner order, program-control#39, 2026-09-20 15:12Z). The offer (3-day trial and the US$1 first month) is granted once per store: a store that already carries an active or paid subscription is not eligible for the offer again on that store. The offer is not limited by customer, account owner, organization, or payment method — a merchant may take the offer again on each new store they create, including a further store owned by the same person or organization as an earlier one, and a change of card does not affect eligibility either way. This rule exists to prevent double-billing the same store for the same offer, not to limit how many of a merchant's stores may use it (per FTC §425.4 — material terms of the offer).

11.6 Exclusions. The offer does not apply to: Annual plans (annual plans never receive the US$1 first month), AI Credit Packs, the Region Pin add-on, BYOC, the Additional Store add-on, the Merchant Subscriptions add-on, the Marketplace App Store / Theme Store partner commission SKUs, or any other Add-on. Enterprise customers receive a 30-day trial under their Order Form rather than the self-serve 3-day trial and are not eligible for the US$1 first month; the Enterprise trial is sales-led and subject to the customer's signed Order Form. The exclusion list (with the Enterprise 30-day exception called out) must be visible on any page where the offer is presented, in the same field of view as the offer (per EU UCPD Art. 7 — material omissions).

11.7 Trial-credit forfeiture disclosure. AI Credits or other usage allowances granted during the trial are forfeit on cancellation before conversion. This must be disclosed at signup (in the trial Terms presented before the end-of-trial plan confirmation) and in the cancellation flow.

11.8 Evidence retention. Retain timestamped evidence of:

1. Trial-start consent (the screen text shown + the customer's acceptance event).
2. The trial Terms as displayed at signup, including the US$1 first-month and regular-price disclosures.
3. The plan-confirmation event that ends the trial and triggers the US$1 charge (Section 11.2).
4. Delivery of the pre-renewal notice (Section 11.3) — email send-event log and in-app delivery log.
5. Any cancellation event — the click path, the screen shown, the timestamp.

Retention period: ≥3 years (FTC §425.5 + CA ARL §17602(d) minimum). Records must be producible in response to regulator requests within 30 days.

12. AI Credit unit disclosure (added v7.3)

Tanqory bills usage of AI features in AI Credits, defined in Pricing v2.1 source-of-truth credit_definition section as 1 Credit = 1 AI action (the global consumer-AI standard used by Lovable, Cursor, v0, ChatGPT, Claude, Midjourney). Because the credit-unit definition is a material term of the offer — without it, the "X Credits / month" headline figure on the Pricing page is meaningless to a reasonable consumer — it must be visibly disclosed on the Pricing page and at Checkout to satisfy:

• EU UCPD (Directive 2005/29/EC) Art. 7 — misleading omission of material information needed to make an informed transactional decision.
• SG CPFTA s.4(c) — misleading practice through omission of material information.
• FTC Act §5 — deception/unfairness via incomplete disclosure of unit pricing.
• UK CPRs (Consumer Protection from Unfair Trading Regulations 2008) Reg. 6 — misleading omissions.

12.1 Pricing page disclosure. The Pricing page tier comparison must visibly include, for each plan and within the same field of view as the credit allowance:

1. The plan's headline credit allowance (e.g., "20,000 AI Credits / month" for Business).
2. A brief unit definition: "1 Credit = 1 AI action (e.g., one chat reply, one product description, one image generation)."
3. The effective per-credit price for the plan, available at least on hover/expand (e.g., "$99 / mo · 20,000 credits · $0.0050 per credit").

12.2 Checkout disclosure. The Checkout review screen — the last screen before payment confirmation — must restate the monthly credit allowance and the unit definition for the chosen plan. This is the moment at which the customer makes the transactional decision (UCPD Art. 7 trigger).

12.3 Action-table reference. The full action-credit consumption table (per Pricing v2.1 source-of-truth credit_definition section — chat reply 1, product description 1, image 1, bulk operation 1-per-item, etc.) must be accessible via a "How credits work" link adjacent to every place a credit allowance is quoted, including: Pricing page, Checkout, billing dashboard, AI feature inline tooltips.

12.4 Failed-action and streaming rules. Per Pricing v2.1 source-of-truth credit_definition section:

• Requests that error at the model layer are not charged.
• Requests that return a result but the customer rejects the output are charged.
• Streamed responses count as 1 credit when the stream begins; cancellation mid-stream does not refund.

These rules must be disclosed in the action-table reference (Section 12.3) and in the billing dashboard per-action breakdown.

12.5 Real-time consumption display. The customer's billing dashboard must show credit consumption in near-real-time with a per-action breakdown (action type, timestamp, credits consumed, surviving balance). Latency on the dashboard refresh is ≤5 minutes. This is the substantiating record customers rely on when questioning a charge and is the company's evidence in a regulator dispute.

12.6 Evidence retention. Per-customer per-cycle credit-consumption records are retained ≥3 years (consistent with Sections 10.1 and 11.6).

Appendix A: Mandatory flow/UX (auto-renewal and consent)

• Separate consent screen: clearly state recurring charges, frequency, charge date, cancellation; require a distinct checkbox from Terms/Privacy.
• Click-to-cancel: online cancel in the same channel as signup (web/app), not hidden, no agent required.
• Evidence: keep consent timestamps, UI copies, pre-renewal notice logs, cancel clicks ≥3 years.
• Pre-renewal notice: 15–45 days baseline (CA/US) for terms ≥1 year; shorter cycles follow local law.

Appendix B: Regional price/promo display

• EU/UK: VAT-inclusive for B2C; prior price (lowest in 30 days) on sale pages/banners; cooling-off notice on confirmations; comply with Omnibus/PID.
• US: Total price upfront per CA SB 478/FTC (only taxes/shipping may be separate); tax shown pre-confirmation; avoid misleading comparisons per FTC 16 CFR 233/UDAAP.
• AU: ACL misleading pricing rules; consumer prices GST inclusive.
• Prior price/flash sale/restock: always use the lowest price in the last 30 days; for restocks use the last sale price within 30 days; keep verifiable logs.
• CA: Competition Act deceptive marketing/pricing; show taxes/shipping before confirmation; avoid unsubstantiated “regular price” claims.
• JP: Act against Unjustifiable Premiums and Misleading Representations; show consumption tax properly; avoid unsupported compare-at pricing.
• UAE: Follow local consumer ad rules and FTA VAT display; avoid misleading marketplace discounts.

Appendix C: Tax/shipping/FX calculation and display

• Tax/shipping estimator before confirmation, noting they are legally allowed separate items.
• FX disclosure (PSD2/payment providers): show rate, date/time used, markup (if any), and binding local-currency total before confirmation.
• Refund/FX: state that refunds use the rate at refund time or processor rules to inform FX risk.
• Sample FX notice: “This total uses the FX rate at checkout and includes any FX risk markup; the binding amount is the local-currency total shown before you confirm.”

Appendix D: Price history and price-update SLAs

• Keep price-history logs ≥30 days (EU/UK prior price) and 12–24 months for internal audit/disputes; make accessible for prior-price verification.
• Burdensome price increases: give ≥30 days’ notice (email/dashboard) and update Pricing/Order Form with timestamps within 24 hours of notice.
• Conflict resolution: priority = live Pricing page > latest Order Form > invoice > historical references.

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Appendix E: Version history