Better Internet for Kids

There are so many apps, games and websites that children enjoy using online. While some games and apps cost money, most are free to download and use. But are they actually ‘free’?

Online companies use clever tactics to make money through products and services they market as being free. These tactics are not always obvious and some can be very persuasive, especially those aimed at children.

In this learning module, you will explore the digital marketing tactics used in ‘free’ apps, games and services to encourage children to spend real money. You will learn why companies use these tactics and how they can impact your child and their rights. You will also learn how you can support your child to spot and avoid these issues, as well as where you can seek help and support.

What are manipulative digital marketing tactics?

There is a classic saying about online services: “If it is free, then YOU are the product.”

This means that, when an app, game or service is offered for free, a user is paying for it in other ways – usually through giving away personal data by using the app or service. Personal data holds value to companies – they may sell it to third party companies, or use it to target specific advertising towards users. Some platforms may also use consumer data to change how their service works, often in ways that will persuade users to give away more personal data or spend real money on additional features or services.

The following sections will explore the three main types of tactics in greater detail to help you understand how they might persuade children to give away personal data or spend money.

The three main types of tactics you will learn about are:

• Persuasive features – Product design features and advertising methods that encourage children to spend money or share personal data.
• Subscription traps – Methods of persuading children into joining subscription services that cost money.
• Product placement and promotion – Featuring other products in games and apps to encourage children to buy them or using endorsements from popular people known to children who can influence their views.

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What are the persuasive features in online games?

There are many different types of persuasive features used in online games, apps and platforms. Some are designed to grab a user’s attention and encourage them to take an action or spend more time playing/interacting. Other features are designed to pressure a user into making a purchase or spending more money than they had planned to. These features are often known as ‘dark patterns’ – features that guide a user into making decisions that the online game/platform wants them to make, rather than a choice made of free will.

The best way to get to grips with some of the different features is to understand what they are and what they do. Below are persuasive features that online games and apps might use to pressure your child into sharing their personal data or spending money. 

Exercise

Can you match the correct term to each definition? (If you’re not sure, why not work together with your child to match these terms!)

Did you successfully match all the terms? Check your answers below:
^{(1e, 2h, 3a, 4j, 5f, 6i, 7b, 8d, 9g, 10c)}

These are just some of the methods used in online games and platforms to persuade users to spend more money and time. Can you think of any other methods that are used?

What are the tactics for subscription traps?

Subscription traps are tactics used by companies to persuade users to sign up for monthly subscription or to unlock special features for a set period of time. One of the examples in the previous section, a battle pass, is a good example of this. Some games allow a user to set up a recurring payment to ensure they always unlock the battle pass and have access to additional items and features that non-paying players do not.

Some games and apps will try to attract users to start a subscription by offering a discount for the first month, or a special reward for subscribing. These may be tempting to younger players who wish to unlock a unique item. Other games and apps may offer other subscription-like features, such as removing in-game adverts for a certain number of days.

Not all games and apps make it clear to users that they are entering into a recurring subscription rather than making a one-time payment, and some games make it very difficult to end the subscription – they provide no clear cancel button (and instead require an email to be sent to the company to confirm cancellation) or will try to keep a user subscribed by offering them new discounts and deals when they attempt to quit. 

How does product placement and promotion work online?

The third tactic you will consider is one that is becoming increasingly common in online games, apps and other content aimed at children – product placement and promotion.

This approach can take many different forms and can be designed to encourage people to buy a product, to share personal data, or both. Here are some examples that your child might encounter online:

• A pop-up advert appearing in an online game for another game or product that players would enjoy.
• An advert is displayed in an app for a product that other children of a similar age would like. (Note: Targeted advertising to children is no longer permitted under EU rules, but it can still happen.)
• An advert for a product shows lots of the 5-star reviews it has received and positive comments from people who purchased it.
• A product being advertised within a game world. For example, products appearing on billboards next to the track in a racing game, or an in-game character wearing a pair of branded footwear.
• An influencer talking about or giving a positive review about a product they know their viewers would be interested in.
• A celebrity or influencer running a competition to win a product. Entrants must share some personal data or subscribe to the influencer’s social media channels.

It is important to remember that, in most cases, when a famous person or influencer is talking about a product then they have usually been paid by the company to do so. Online promotion is seen by companies as an effective form of advertising, as it allows them to make their products known to a large audience of people who might want to buy it, including children. If an influencer likes the product, their followers might be more likely to buy it as well.

Big social media platforms and video sharing sites expect influencers to tell their audience when they are being paid to promote a product, but not all influencers are truthful. Many influencers will include a link to the product in the description of their post/video. For every person who clicks that link and purchases from the company, the influencer receives a commission.

Why do online companies use these tactics?

Online companies rarely offer free products and services as a gesture of goodwill; they will use the lure of ‘free’ to attract new users. The more users on a service, the more opportunities to sell other products, to capture personal data and to show advertising.

Most ‘free’ services make money from advertising. Using persuasive tactics can encourage users to spend more time engaging with the service. More time spent by a user equals more opportunities to show adverts to them, and more opportunities to collect their data.

Some ‘free’ games also lure new players in with low-cost special offers that encourage a purchase. Once a user has purchased something in a game, they may be more likely to purchase something in the future. For some users, this can act as a strong justification for continuing to spend money in game. This is known as the ‘sunk cost fallacy’ – a user is unable to quit the game because they have already invested significant time and money into it. 

What are the ‘hidden’ costs to your child?

Persuasive digital marketing tactics can have a number of costs to your child, not just in terms of financial well-being, but also mental health and well-being, privacy and safety.

It is important to remember that all children are different and can be affected by online risks in different ways depending on their age and experience.

Here are some of the possible impacts:

• Financial well-being – Persuasive tactics could lead a child into spending all their available money on in-game purchases or even going into debt. If a child is using a shared payment method (such as a parent or caregiver’s credit card), expensive online purchases could have a negative effect on a family’s finances. Being tricked into signing up for a subscription service might lead to a child being unaware or unsure of how to end the subscription, which would cost them more money in the future.
• Physical health – Although not fully proven through research, there is some evidence to suggest that prolonged use of technology can impact on children’s eyesight and posture. Some research shows a link between prolonged use and disrupted sleep, obesity and unhealthy snacking when playing video games. Persuasive marketing tactics could lead a child to using technology for longer than normal, increasing the risk of negative impacts to their health.
• Mental health and well-being – Excessive spending in online games might lead a child to become anxious and worried about the consequences, particularly if they have spent money that belongs to other family members. Prolonged use of some online services (such as social media) has also been linked with anxiety and depression, though the exact causes are unknown, and not all children are affected in the same way. Persuasive tactics in online games may also cause children to become anxious if they fear that they are ‘missing out’ on something if they don’t make a purchase.
• Privacy – Personal data allows a service to profile its users. This can lead to a company knowing more about your child than you (or they) may be comfortable with. It can also lead to an app or website showing your child different content to other users, based on the personal data it has collected. 
• Safety – While data profiling of users can help to protect children (by making sure they only see content appropriate for their age), not all services use personal data in this way. Persuasive marketing tactics on some services could lead to a child seeing content that is upsetting or even harmful.

What are my child’s rights online?

Just like offline, your child has rights online as well. It is important to help them know and understand these so that they can protect themselves online.

The General Data Protection Regulation (GDPR) that applies across all EU Member States also contains rules for companies when collecting and processing children’s data.

These include:

• Children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of personal data. (Recital 38)
• Parental consent must be obtained for data collection of children under 16 on services that are offered directly to children (Note: EU Member States can choose an age between 13-16 for consent). (Article 8)
• Providing information to data subjects in a manner that is concise, transparent, intelligible and easily accessible, using clear and plain language. (Article 12)
• Information provided to children about data processing should be clear and in plain language that the child can easily understand. (Recital 58)

The Digital Services Act (DSA) also applies to all EU Member States and sets out rules that all online platforms must follow and a number of these rules are designed to protect children and young people under 18 (minors). There are specific rules that apply to the largest online platforms, known as Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs).

When thinking about persuasive digital marketing practices, all platforms must do the following under the DSA:

• Consider if minors will easily understand how the service works. (Recital 81)
• Make extra effort to explain things clearly to minors so they understand what they are agreeing to. (Article 14)
• Consider how design features could cause addiction. (Recital 81/83)
• If the service can be accessed by minors, to put in place appropriate measures to ensure a high level of privacy, safety and security of minors. (Article 28)
• If a user is known to be a minor, they cannot be shown adverts based on their data profiling. (Note: children will still see adverts) (Article 28)
• VLOPs and VLOSEs must carry out risk assessments on the severity and probability of risk that their service presents to users, including the protection of minors, physical and mental well-being, the use of algorithms and recommender systems, and systems for selecting and presenting adverts. (Article 34)
• VLOPS and VLOSEs must put measures in place to limit the impact of the risks outlined in Article 34. These measures may include adapting terms and conditions, testing algorithmic systems and adapting advertising systems. They must also take measures to protect the rights of the child. (Article 35)
• “Dark patterns” that persuade users to make purchases, or make it hard to leave subscriptions, are forbidden. (Recital 67)

There are also other rules designed to keep children safer on online platforms, as well as help them to report issues. There are also rules to help parents and families take more control to monitor their child’s use of the internet and protect them from online risks.

Want to know more about how the Digital Services Act is working to protect children online? This child-friendly booklet (available in 24 languages) can help you and your family to learn more.

What are the rights of digital consumers?

It’s not just children who have rights online – all EU consumers are protected under the Consumer Rights Directive and have rights to truthful advertising, clear pricing information, equal access to goods and services and the right to withdraw from online purchase contracts.

You can learn more about your consumer rights online on the European Consumer Centres Network (ECC-Net) website, including details of how to contact your country’s ECC.

How can I talk to my child about these issues?

As persuasive digital marketing tactics can often be quite subtle or even hidden, it is important to take time to discuss these tactics with your child in order to help them spot and manage them.

This is a topic that doesn’t lend itself to a natural conversation! And sometimes it can be tricky to know where to start or how to discuss this with your child, so you may find the following tips useful:

• Explore together – Playing your child’s favourite game with them, or exploring their favourite apps and sites together provides you with opportunities to spot marketing tactics and point them out to your child. This can give you something to discuss together, including what they can do to manage these risks.
• Use your own examples – If your child doesn’t want to explore their favourite apps/games with you, you could use examples from your own online experiences to highlight different tactics used to pressure users into sharing data or making purchases.
• Look for news/articles – Another approach is to look for stories that show the impact of aggressive digital marketing tactics. Although rarer today, there are news reports in many countries from recent years highlighting how children have used a parent’s credit card to amass huge bills in some online games. These stories can serve as cautionary tales that you can discuss with your child.
• Discuss personal data – One way into this topic is to talk with your child about their personal data, and how and where it is shared online. Discussing how personal data can hold different value to different people can help them understand why companies are keen to collect their data in many different ways.
• Always offer help and support – As a trusted adult in your child’s life, you play an important role in support them to be safe, happy and healthy – this includes online too! Remind your child that they can always talk to you if they are worried about anything they experience online, including when they feel pressured into doing something or have made mistakes involving money or personal data.
• Use the AdWiseOnline guide – This guide for young people explains in simple terms how companies make money through online advertising and offers tips to young people on navigating marketing traps, as well as the online rights that young people have. The guide is available in 29 languages!

More advice on how to talk to your child about online safety and privacy issues such as these can be found in the ‘How can I talk to my child about online safety?’ learning module.

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What can I do to protect my child from digital marketing tactics and scams?

There are many steps that you can take to support and empower your child to manage and avoid aggressive digital marketing tactics in their favourite games and apps.

Here are some things to consider:

• Ask questions – Work with your child to create a checklist of questions they should ask themselves when they encounter something online that may be trying to pressure them into making a purchase. Questions such as “Is this trying to sell me something?”, “Is this too good to be true?”, “How much is this in ‘real’ money?” and “What is this asking me to do?” can help a child to spot when they are being pressured into sharing personal data or spending money.
• Don’t rush! – Advise your child not to rush into online purchases. Some games will try to create FOMO or use language that produces strong emotions to secure a sale. Taking time to consider their purchase can empower your child to make a well-informed decision.
• What do others think? – Help your child to look for other opinions about a product or deal online. This could involve independent reviews (from experts or customers), comments underneath a video/post or websites with more information.
• Adjust settings – Support your child to find settings on their device, in apps and games to manage their privacy. This could include the option to turn off notifications or restrict the sharing of their personal data.
• Discuss responsible spending – As with offline spending, it is important to help your child learn to make informed purchases and manage their money responsibly. This could include setting a weekly or monthly limit on purchases or teaching your child about budgeting and saving for more expensive online purchases.
• Check terms and conditions – Work with your child to look at the terms and conditions for games and platforms they use, to understand what personal data may be collected and shared. This also includes terms and rules for any online competitions that they may enter.
• Exercise privacy rights - Explore how to contact companies if you (or your child) wish to delete personal data records. Look for options to opt out of marketing communication when your child signs up or makes a purchase online.
• Consider alternatives – Although sometimes difficult, if you or your child are unhappy with the marketing practices in a game or app, you may be able to find an alternative title or platform that better meets your needs and expectations.

Where can I go for help?

If you are concerned about your child’s experiences online, or if you feel that their rights have not been respected by an online platform or service, then you can contact your national Safer Internet Centre for help with reporting or reaching the right authority.

Details of your national Safer Internet Centre can be found on the Better Internet for Kids portal.

How can I learn more about these issues?

Want to know more? There are lots of resources that can help you (and your child) learn more about manipulative digital marketing:

• AdWiseOnline - The AdWiseOnline initiative on child and youth consumer protection in digital environments aims to raise awareness about manipulative digital marketing practices. It includes resources for parents and caregivers and a guide for young people.
• Educational Toolkit for Young Consumers – Although aimed at teachers and educators, this free toolkit contains some offline quizzes that you can work through with your child to better understand manipulative digital marketing, subscription traps and consumer rights online.
• Better Internet for Kids resources directory– Educational resources provided by the Insafe network of Safer Internet Centres. You can search for keywords to find resources in your language on a range of online safety issues.
• School of Social Networks – This resource for primary-aged children, teachers and parents/carers provides information and advice on a range of online issues, including around loot boxes and healthy digital behaviours. There are accompanying activities that you can work through with your child.

• Dark Pattern Games – This website provides reviews of games that contain dark patterns, including those that encourage spending. It also includes a list of healthy games that do not include dark patterns!