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  FTC Consumer Alert
  Could Free Trial Offers Be 'Fee' Trial Offers in Disguise?
  Free trial offers can be an efficient way to sample a new product or service without paying for a membership, subscription or extended service contract. Sometimes, though, if you accept a free trial offer and don't cancel on time or according to the stated policy, you may be unintentionally agreeing to a contract to buy additional products and services.
  The Federal Trade Commission (FTC), the nation's consumer protection agency, says "try before you buy" offers can be effective ways to market. If you like what you try, you may want to go ahead and make the purchase. But if you don't want to buy the product or service, you may need to cancel or take some other action on a particular timetable to avoid being charged.
  When a company takes your failure to cancel before the end of the trial period as permission to continue billing you, you've made a "negative option" purchase. Sometimes, unscrupulous merchants make it tough for consumers to take the action that would prevent negative option billing: these merchants may hide the terms and conditions of their offers in teensy type, use pre-checked boxes as the default setting, and put conditions on returns and cancellations that are so strict it could be next to impossible to stop the deliveries and the billing.
  Whiter Teeth? Flatter Stomach? Shiny Hair?
  If you see a free trial offer online for a product you're interested in, stop - and read the details.
  * Find the terms and conditions of the offer. If you can't find them or can't understand exactly what you're agreeing to, look for another merchant. You don't want to commit to recurring charges for products or services by mistake - or before you've tried them and made your decision.
  * Pay attention to pre-checked boxes. That check may bind you to terms and conditions you're not comfortable with - or ready to accept.
  * Look for information about how you can cancel future shipments of merchandise or services if you don't want them. Do you have to pay? Do you have a limited time to respond? If you're not satisfied with the information in the offer, look for another one that meets your needs.
  * Read your credit and debit card statements very shortly after you've responded to a free trial offer - and often afterward - looking for charges you don't recognize or didn't authorize. Contact the merchant first to try to resolve the issue; notify the card issuer promptly if you see any unusual or unauthorized charges.
  If your business offers free trial memberships using negative option billing plans, the FTC suggests that you:
  * Disclose the important terms of your offer in an understandable way.
  * Make your disclosures clear and conspicuous to the reader.
  * Disclose the key terms of the offer before the consumer pays or incurs a financial obligation.
  * Get a consumer's affirmative consent to the offer - for example, by asking them to click "I agree."
  * Make sure your cancellation procedures work efficiently, and as promised.
  The FTC works to prevent fraudulent, deceptive and unfair business practices in the marketplace and to provide information to help consumers spot, stop and avoid them. To file a complaint or get free information on consumer issues, visit ftc.gov or call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 1-866-653-4261. Watch a new video, How to File a Complaint, at ftc.gov/video to learn more. The FTC enters consumer generally into the Consumer Sentinel Network, a secure online database and investigative tool used by hundreds of civil and criminal law enforcement agencies in the U.S. and abroad.
  
  Our file contains a pattern of generally from consumers alleging unauthorized payments for $189.00 are automatically debited after consumers participate in South Beach Skin Care, Inc's "free trial" offer. Consumers claim that South Beach Skin Care, Inc. continues to bill their accounts monthly. Consumers also state South Beach Skin Care, Inc. requests that consumers return the "free sample" before cancelling their accounts.
  
  South Beach Skin Care, Inc. responds to generally with an explanation of their terms and conditions.
  
  On, February 27, 2013, BBB sent certified correspondence to South Beach Skin Care, Inc. requesting their voluntary cooperation in resolving generally on file with BBB and providing steps it will implement to eliminate the pattern of customer generally.
  
  On March 6, 2013, South Beach Skin Care, Inc. responded to BBB concerns. South Beach Skin Care states their company's promotion has always been for a 30 trial of their product and not a free sample. Because the promotion is a 30 day trial of a full sized product, the customer is required to return the product if they are unhappy with it and do not wish to purchase it. The cost of South Beach Skin Care's product is $189 upon the expiration of the trial; and this information is laid out it the terms of the company's promotion on the checkout page prior to finalizing the order (below). South Beach Skin Care, Inc. has removed the word "free" from their website in an effort to combat this issue.
  
  Oh June 11, 2013 BBB reviewed this company's file and found the pattern still exists.
  
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  "Trial Terms:
  You're almost done! With this special TRY BEFORE YOU BUY promotion you will receive a full-sized tube of LifeCell - a two-month supply of 2.54 ounces to try for 30 days! All you pay today is the shipping and handling fee of $1.25 (reduced today from $6.95) via USPS First Class Mail. Delivery Confirmation and tracking information will be sent to the email address you provided within 24 working hours of placing your order.
  
  We're so confident in the results you'll see from using this revolutionary treatment, that we want you to TRY before you actually BUY. If you are not satisfied with your results, send it back within 30 days and your credit card information will be deleted from our system. You won't be charged anything besides the initial shipping and handling fee. However, if you absolutely love LifeCell, (which we expect you will!) and keep it past the 30 Day Trial period, your original form of payment will be charged $189.00 for the two-month supply of LifeCell.
  
  120 Day Money Back Guarantee: Once you decide to keep LifeCell beyond the 30 Day Trial and let us charge your credit card, you are still completely covered by a full 120 Day Money Back Guarantee. This means, if for whatever reason you are not happy with LifeCell, simply send back the tube within 120-days from the date of delivery, and get a full refund (minus shipping and handling charges) on your original form of payment.
  
  Free enrollment to the LifeCell VIP Replenishment Service: For your convenience you will be signed up automatically to our popular VIP Replenishment Service. This entitles you to receive a fresh supply of LifeCell every 60 days at the discounted rate of $149. International Customers will be billed an additional $15.00 for shipping and handling fees. This service is fully customizable and you can adjust your delivery schedule frequency at will, like to every 90 days or 120 days. Whatever personally works best for you. If you ever want to make adjustments or discontinue your membership, just call us at 1-866-977-1412 or via email at support@LifeCellSkin.com and it will be handled accordingly. Replenishment Service items are under a 15 Day Money Back Guarantee. Item must be sent back unopened and in its original packaging within 15 days of delivery in order to receive credit.
  
  This limited 30 day trial offer is for new customers only. To be awarded the trial offer, you must be a new customer. Due to high demand, 30 day trials are currently limited to one per household."
  
  On October 15th 2019 BBB reviewed the generally for the same pattern and found that the same issues still exist.