I’m no lawyer, but the text of the law below would seem to allow email as an acceptable mechanism for requesting a cancellation:
(b) A business that makes an automatic renewal offer or continuous service offer shall provide a toll-free telephone number, electronic mail address, a postal address if the seller directly bills the consumer, or it shall provide another cost-effective, timely, and easy-to-use mechanism for cancellation that shall be described in the acknowledgment specified in paragraph (3) of subdivision (a).
(c) In addition to the requirements of subdivision (b), a consumer who accepts an automatic renewal or continuous service offer online shall be allowed to terminate the automatic renewal or continuous service exclusively online, which may include a termination email formatted and provided by the business that a consumer can send to the business without additional information.
We agree with the solution to create a “mailto:” link with cancellation subject line or email text pre-filled. This link should live somewhere easily accessible on your website, but there are no specific requirements as to where.
Another option would be to create a club cancellation form, where you could ask additional questions such as reason for cancelling, and embed it on a dedicated Club Cancellation page.
This section of the law that states the requirement to “provide an acknowledgment that includes … information regarding how to cancel in a manner that is capable of being retained by the consumer” suggests that you would need to provide the “mailto” link and/or the link to cancellation form in your wine club sign up confirmation email and in subsequent club notification emails.
Disclaimer: I am not a lawyer, and WineDirect does not provide legal advice, so we always recommend consulting your own counsel in these matters.
As @EdFarmCollective noted, we are working on building the capability for club members to cancel fully online. It’s part of a comprehensive update we are making to our club tools, which we expect to begin testing out later this year.
@adriennestillman I’m assuming that you’ve released this functionality, but I can’t seem to find anything in documentation about it. Would you be able to point me to documentation?