― Upton Sinclair
No extra hoops at all.
To signup they just went to foo.com and there was list of plans with links to their sign up pages right there, so click one of those, fill out the one page form, click submit.
To cancel, they have to go to foo.com, click the login link, full in the login form, click to submit, then on their home page click on the profile icon to get the profile menu, click account in that menu, and then click the cancel button on the account page.
That's 2 clicks to sign up and 5 to cancel--6 if the cancel button asks if you are sure.
Unless there were several efforts to get you to think twice before subscribing, clearly trying to get you to think twice before unsubscribing is not as easy to use.
The only reason any company would have trouble complying with this rule is if they want to abuse customers to keep them from canceling when they want to cancel. The amount of sympathy I have towards such companies requires advanced scientific notation to quantify.
This is what courts are for. There is no exact line because many situations are different.
Surely you don't have to have a big red cancel button on every page of your platform
Why not?
Some examples would be helpful
The text you quoted is clear enough to me, and it's probably clear to any reasonable person (most rules are written this way). If you're worried about gaming the system to find the exact process that just on the "legal" side of things, you probably aren't reasonable.
So now you’ve opened a bunch of businesses up to liability from an upset customer who files a complaint, even if they are making a good faith effort to follow this law.
That is why clear and specific details should be in the law, not vague hand wavy things that require lawyers and judges to interpret.