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Policy on Geo-blocking Regulation (EU) 2018/302

1. Access to Digital Content and Services

All users within the European Union (EU) and European Economic Area (EEA) must be granted equal access to the mobile app, website, and associated digital services (e.g., subscriptions, downloadable content, or streaming features) regardless of their country of residence. Automatic detection of user location (via IP address, GPS, or payment details) shall not trigger redirection to country-specific versions of the platform unless explicitly required by law (e.g., age-restricted content compliance). Users accessing the service from any EU/EEA member state must be able to:

  • View the same catalog of products, services, and pricing tiers as users in other EU/EEA countries.

  • Register accounts without being forced to use a national domain (e.g., .fr, .de) or local-language interfaces.

  • Retain access to their accounts when traveling temporarily within the EU/EEA (e.g., a French user accessing their subscription while in Germany).

Technical Implementation:

  • Deploy geolocation checks only to confirm EU/EEA residency, not to restrict access.
  • Allow users to manually select their country of residence during account creation, with verification limited to payment method or ID checks for age-restricted services.
  • Disable IP-based automatic redirects to localized versions of the app/website.

2. Non-Discrimination in Sales and Pricing

Pricing, promotional offers, and terms of sale must remain consistent for all EU/EEA users, irrespective of their nationality, residence, or payment method location. Prohibited practices include:

  • Dynamic pricing adjustments based on a user’s geographic location (e.g., charging Spanish users more than German users for the same subscription plan).

  • Restricting access to sales, discounts, or bundled offers to specific member states without objective justification (e.g., VAT rate differences).

  • Requiring users to possess a local payment method (e.g., a Dutch bank account) or address to complete transactions.

3. Unrestricted Payment Method Acceptance

Users must be permitted to complete transactions using any payment method available within the EU/EEA, regardless of their country of origin or the payment provider’s jurisdiction. Prohibited restrictions include:

  • Blocking non-domestic credit/debit cards (e.g., rejecting a Polish user’s Lithuanian-issued card).

  • Imposing surcharges for cross-border transactions within the EU/EEA.

  • Forcing users to create accounts with regional payment gateways (e.g., requiring iDEAL for Dutch users but not others).

4. Transparency in Access Restrictions

If geo-blocking is legally justified (e.g., compliance with national copyright laws or age verification mandates), users must be informed proactively and provided with alternatives. Requirements include:

  • Displaying a clear, non-technical notice explaining the restriction (e.g., “This content is unavailable in your region due to licensing agreements”).

  • Offering users the ability to request access through a dedicated portal, with responses provided within 14 business days.

  • Providing contact details for the platform’s Geo-blocking Compliance Officer to address disputes.

5. Data Collection and Privacy Compliance

Geolocation data collected for geo-blocking compliance must adhere to GDPR principles:

  • Purpose Limitation: Geolocation data may only be used to verify EU/EEA residency or enforce legally mandated restrictions.

  • User Consent: Explicit opt-in consent is required for non-essential geolocation tracking (e.g., granular city-level data for personalized ads).

  • Data Minimization: Store only the minimum necessary data (e.g., country-level location, not precise coordinates).

  • Right to Erasure: Users may request deletion of geolocation data via a self-service dashboard.

Technical Safeguards:

  • Anonymize geolocation data within 24 hours of collection.

  • Encrypt location data during transmission and storage.

6. Compliance Monitoring and Enforcement

  • Internal Audits: Conduct quarterly reviews of geo-blocking practices, including test purchases from multiple EU/EEA countries to verify pricing and access parity.

  • User Reporting Tools: Implement in-app/website forms for users to report suspected violations (e.g., “Report Unfair Geo-blocking”).

  • Penalties: Train customer service teams to escalate geo-blocking complaints to legal departments within 48 hours.

  • Regulatory Cooperation: Designate a Geo-blocking Compliance Officer to liaise with national enforcement authorities (e.g., the European Commission’s Geo-blocking Contact Points).

7. User Rights and Redress Mechanisms

  • Complaint Resolution: Users may submit complaints via email, in-app forms, or postal mail, with guaranteed acknowledgment within 72 hours and resolution within 30 days.

  • Remedies: If a violation is confirmed, provide compensation (e.g., refunds, service credits) and corrective action (e.g., removing discriminatory pricing).

  • Judicial Recourse: Inform users of their right to pursue claims through national courts or alternative dispute resolution (ADR) bodies.

8. Policy Updates and Training

  • Annual Staff Training: Educate developers, customer support, and legal teams on geo-blocking regulation updates, including case law (e.g., CJEU rulings).

  • Public Documentation: Maintain a publicly accessible Geo-blocking Compliance Page detailing the platform’s adherence to Regulation 2018/302.

  • Version Control: Track policy changes in a revision log, with outdated versions archived for 5 years.