We already comply with that with our subscription cancellation buttons. Most of the directive is pertaining to the return of physicals goods and only partially applies to subscriptions.
The withdrawal process must be as easy as concluding a contract
It's 2 clicks so we're within the directives requirements (Unsubscribe -> Confirm). How accessible you make the plans page is entirely up to you. For example see our site where "Your Membership" is in the header next to "Log Out" immediately at the top.
Instead of email/forms, users must be able to withdraw via a clearly labeled button (“Withdraw contract”)
It does not have to say "withdraw contract" exactly. Just needs to be a clearly labelled and visible legal withdrawal verbiage (Cancel and Unsubscribe for example qualify). No dark patterns of hiding it behind a dozen pages and verbiage.
The button must:
be easily accessible and permanently available (e.g. in the footer)
not be hidden behind login areas
This is half true. It needs to be easily accessible, but it can be in a login area (e.g. orders page, etc..). We do not accept guest payments so it's not possible to have guest subscriptions or cancellations. Given this we do not require the "form" step of the directive since it specifically excludes needing that if the user is already logged in.
After clicking, a two-step process is required:
Contract identification (e.g. email or order ID)
Confirmation (“Confirm withdrawal”)
The two step process simply requires a 2 page process. 1 for the button then 1 for the confirmation. We already provide this.
A confirmation of receipt (e.g. via email) must be sent automatically
If you've configured the "Email on cancellation by user" parameter then you've this covered.
Additionally Art. 11a doesn't apply to CBSubs as it doesn't apply to digital services and goods. It's a right to return within 14 days of purchase for physical goods. So you don't need to worry about some automatic refund process.
krileon
