Are Your Subscription Disclosures Compliant? What You Need to Know for 2025
Paavana Kumar breaks down the new disclosure, consent, and cancellation rules subscription businesses must follow under the FTC’s Click-to-Cancel Rule and stricter state laws.
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Paavana Kumar
PARTNER, DAVIS+GILBERT
Paavana Kumar helps major advertisers, retailers, disruptive e-commerce companies and startups assess risk and comply with the shifting landscape of advertising and media law. Clients rely on her counsel as they work to promote innovative products, run high-exposure campaigns and streamline the online customer experience.
Paavana is particularly experienced at navigating cutting-edge social commerce issues. She frequently advises businesses looking to leverage influencer talent, engage creatively on social media, and reimagine (or launch) e-commerce and subscription programs. Her ability to quickly spot and assess issues and provide efficient, practical advice makes her an invaluable sounding board for C-Suite executives and general counsel facing high-stakes judgment calls ranging from social media opportunities to major business model changes. Paavana works with brands in almost every industry sector including fashion and cosmetics, food and beverage, entertainment streaming, and software.
As subscription programs become more popular, Paavana’s knowledge of the highly regulated automatic renewal and negative option laws in all 50 states, together with her deep understanding of the regulatory focus on “dark patterns,” sets her apart. Clients in this space look to her to draft transparent marketing disclosures and design effective, compliant user flows. She also advises on all types of consumer promotions, including sweepstakes, contests, loyalty rewards and gift cards, cause marketing and donation programs, text message and email marketing, and major entertainment and sports collaborations.
Whether she’s counseling on a discrete issue or working with global legal teams for international campaign clearance, Paavana delivers practical advice for clients at all stages of growth — from subscription box startups to major technology and retail companies. She is also closely following industry trends such as the rising use of generative AI. She is a recognized thought leader who frequently speaks and writes about e-commerce and influencer marketing for in-house counsel and industry stakeholders.
More Articles By Paavana Kumar
Paavana Kumar helps major advertisers, retailers, disruptive e-commerce companies and startups assess risk and comply with the shifting landscape of advertising and media law. Clients rely on her counsel as they work to promote innovative products, run high-exposure campaigns and streamline the online customer experience.
Paavana is particularly experienced at navigating cutting-edge social commerce issues. She frequently advises businesses looking to leverage influencer talent, engage creatively on social media, and reimagine (or launch) e-commerce and subscription programs. Her ability to quickly spot and assess issues and provide efficient, practical advice makes her an invaluable sounding board for C-Suite executives and general counsel facing high-stakes judgment calls ranging from social media opportunities to major business model changes. Paavana works with brands in almost every industry sector including fashion and cosmetics, food and beverage, entertainment streaming, and software.
As subscription programs become more popular, Paavana’s knowledge of the highly regulated automatic renewal and negative option laws in all 50 states, together with her deep understanding of the regulatory focus on “dark patterns,” sets her apart. Clients in this space look to her to draft transparent marketing disclosures and design effective, compliant user flows. She also advises on all types of consumer promotions, including sweepstakes, contests, loyalty rewards and gift cards, cause marketing and donation programs, text message and email marketing, and major entertainment and sports collaborations.
Whether she’s counseling on a discrete issue or working with global legal teams for international campaign clearance, Paavana delivers practical advice for clients at all stages of growth — from subscription box startups to major technology and retail companies. She is also closely following industry trends such as the rising use of generative AI. She is a recognized thought leader who frequently speaks and writes about e-commerce and influencer marketing for in-house counsel and industry stakeholders.
