Better Internet for Kids

There are so many apps, games and websites that children and young people enjoy using online. While some games and apps carry an upfront cost to access or own, most are free to download and use. But are they actually ‘free’?

Online companies use clever tactics to generate revenue through online products and services they market as being free. These tactics are sometimes subtle, and some can be very persuasive, especially those aimed at children and young people.

In this learning module, you will explore the manipulative 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 learners. You will also learn about how your learners’ rights apply online and the legal frameworks that exist to protect these rights. Most importantly, you will explore ways to educate your learners about manipulative digital marketing, and how you can offer support as a teacher or educator.

What are manipulative digital marketing tactics?

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

In other words, 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. Companies use personal data in a variety of ways; they sell to third parties, use data to personalise advertising and paid services and adjust the way their services operate based on usage data.

Companies will also use various tactics to encourage spending – in online games this can include purchases of extra lives, new characters, new outfits for characters, additional levels or unlocking special features. Some free games also offer a one-time purchase to remove the adverts displayed during the game that may interrupt gameplay.

Quiz time! 

Are companies are allowed to make money from a game they call a “free game”?

a) Yes, but only if they tell players that upgrades cost money.

b) Clearly yes, it doesn’t matter if they call it 'free' in advertising.

c) No, in that case they are not allowed to say the game is 'free'.

^{Answer: (a)}

The following sections explore four types of persuasive tactics, integration, interaction, personalisation and emotion. Some common examples of these tactics in action will be included. These tactics are also used in apps, on websites and other digital services that children may use.  

There are also a number of technical features that are used to manipulate user behaviour when interacting with devices and games. Some examples of these will be provided later in this learning module but you may find it useful to work through the learning module, Persuasive design, on the Better Internet for Kids Learning corner for teachers and educators alongside this learning module.

As you work through the following sections, take some time to consider the popular games your learners enjoy, and how these tactics might appear in those games. 

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Persuasive tactic: Integration

This term refers to the integration of commercial messages into non-commercial content. It can take a number of forms, including presenting adverts in the style of the regular content (for example, showing an advert for a product on a billboard in an in-game world), incorporating adverts that fit the theme of the game (for example, adverts for sports brands in sports game such as a soccer or basketball game) and embedding advertising into the narrative (for example, in-game characters wears particular brands of clothing or eat certain brands of food).

Another form of integration in online games is the sale of in-game currency – purchasing gems or coins using real money. This in-game currency is then used to purchase items in the in-game shop. As in-game currency rarely has a 1:1 conversion rate with real currency, it becomes harder for a young person whether the in-game purchase is good value for money.

The aim of integration is to blur the boundaries between advertising and in-game content, making it more difficult for young people to recognise that the placement and promotion of these products is part of a persuasive approach. Attempts to blur the relationship between in-game currency and real currency can make it harder for young people to make well-informed purchasing decisions.

Persuasive tactic: Interaction

This term refers to the interactive nature of in-game marketing practices where the players are actively involved in the marketing campaign.

Social games, where players inhabit a game world with other players, lend themselves to this approach. Products and services can be promoted regularly through in-game pop-ups and adverts, but also through word-of-mouth and interactions between players. Gaming culture extends beyond the confines on individual titles, with influencers and live streamers creating content that shows gameplay, discusses games or recommends specific titles.  

The above can apply to products and services external to the game (purchased physically or digitally elsewhere), but also for in-game purchases. For example, players may discuss in open chat the benefits of purchasing a particular feature or powerup that provides a competitive advantage (known as ‘Pay to win’) or some players may show off a purchased cosmetic outfit or item that encourages others to buy it too.

Using this tactic in online games can persuade purchasing through peer pressure and Fear of Missing Out (wanting to have the same branded items as other players) and can strengthen positive association with advertised brands. Young people may unwittingly become part of the marketing campaign and act as multipliers and influencers to encourage other players to make purchases. These tactics can also be difficult for young people to spot

Persuasive tactic: Personalisation

This term refers to the harvesting of data collected from tracking children’s online activities, in order to profile them. Advertising is then targeted towards an individual child or young person based on their marketing profile.  

While this takes place most frequently on social media and video-sharing platforms, usage data in some online games may be used to target children with specific advertising and promotional messages. Commonly, if the game is aimed at children, any in-game adverts will often feature products that children find appealing. But a player’s data could also be used to target specific offers towards them – for example, if the game knows a player is close to levelling up their character, it might show a ‘special offer’ purchase that could speed up that process. This is another example of ‘Pay to win’ that seeks to capitalise on a player’s impatience rather than their need to be competitive.

Personalisation can also be an effective technique for persuading children and young people into subscription traps. 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. 

Quiz time! 

Is a game company allowed to charge money every month, even if somebody has stopped playing the game?

a) Yes, they may charge you until you stop the open-ended contract.

b) No, the contract ends automatically when you stop playing.

c) No, they have to ask you first if you want to continue to play.

^{Answer: (a)} 

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 – either through making cancellation complicated (such as requiring an email to be sent to the company to confirm cancellation) or persuading a user to stay by offering them new personalised discounts and deals when they attempt to quit.  

The AdWiseOnline report, ‘Manipulative digital marketing practices targeted at children and youth online’, found that many children and young people are unaware as to the extent of profiling and commercial tracking, and often view personalised messages and offers as relevant and useful. However, older teens were able to recognise excessive personalisation as an intrusion on their privacy. 

Persuasive tactic: Use of emotion

This tactic involves the evoking of an emotional response from players. Emotional responses can be positive or negative. Positive responses (such as joy, excitement, etc.) are effective in capturing attention and influencing attitudes – for example, providing a free daily reward for logging into the game will encourage young people to play regularly, and increase their positive attitude towards the game for giving away free items.  

Negative responses (anger, frustration, worry) are more varied in terms of success, but in some games, they can be used to create a sense of urgency (for example, having a countdown until a special item leaves the store, or using persuasive language like ‘Last chance to buy’, can prompt players into making a quick purchase for fear of missing out).

Emotions can also change how children and young people process information – feeling emotions such as excitement or worry may lead some players to make purchasing decisions based on how they are feeling, rather than being well-informed. Research has shown that children find it harder to applying advertising literacy skills when presented with content that affects emotions.

Other persuasive tactics

There are also a number of technical features that can persuade children and young people to engage with advertising messages or make purchases in online games; through playing for longer, greater engagement and techniques designed to change behaviour.

These include the use of notifications to bring attention back to a device or game, nudge techniques that encourage selecting one option over another, use of colour and size to affect in-game buttons and features to draw attention, autoplay features that automatically queue up additional content or adverts and gambling mechanics that encourage spending money with no guarantee of reward.

Why not put your knowledge (and your learners’ knowledge) to the test? In the ‘Manipulative marketing in games’ learning module for parents and caregivers, there is an exercise to match persuasive tactics to their descriptions! 

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 their 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.

Advertisers always seek opportunities to encourage spending and recognise that children are an attractive customer group – they are primary consumers in their own right, with money to spend, but they also act as secondary consumers who can influence the buying decisions of parents and caregivers. They are also engaged consumers, with brand recognition beginning as young as the age of two.

The AdWiseOnline report found that children under 12 are particularly vulnerable to persuasive marketing tactics. Young people above the age of 12 are also vulnerable to some practices, particularly tactics that promote brand recognition and positive feelings towards brands.

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 unwilling to quit the game because they have already invested significant time and money into it.  

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What are the ‘hidden’ costs to your learners?

Persuasive digital marketing tactics can affect your learners in numerous ways, 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 evidence is mixed, some research suggests that prolonged use of technology can impact on children’s eyesight and posture. Other 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 to anxiety about the consequences. 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 – Pervasive data collection and personalised marketing towards your learners can be a breach of their privacy. It can also lead to worry or anxiety in young people who feel that an online service knows too much about them.  
• 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 learners’ rights online?

All children and young people have fundamental rights -these apply online and offline. Educating your learners about their rights is an important way to empower them to protect themselves and others from manipulative digital marketing practices.

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, your learners and their families to learn more. 

What other legislation applies?

Quiz time! 

Do you think that a game company can charge you money, if it wasn’t clear that there were extra costs?

a) Yes, they can, but only if the costs are mentioned somewhere else, like on their homepage.

b) No, they cannot if the additional costs are not mentioned directly in the offer.

c) Yes, they can send you information about the costs later, for example by email.

^{Answer: (b)}

There is other legislation that also works to strengthen the protecting of children and young people from digital marketing practices. It is not necessary for your learners (particularly younger learners) to be familiar with this, but it may prove helpful for you as a teacher or educator when supporting your learners and their families.

Under the Unfair Commercial Practices Directive (UCPD), in-game promotions and advertisements must be clearly distinguishable from gameplay or they could amount to misleading practice involving misleading or hidden marketing messages, prohibited by this directive. Personalised advertising based on collected data about a child could be considered undue influence and an aggressive commercial practice that is prohibited under this directive. The UCPD also considers children to be a vulnerable consumer group and companies/advertisers are prohibited from directly telling children to purchase a product or persuade parents/caregivers to purchase a product for them. 

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.

Quiz time! 

What can parents do if their children have been tricked, and this has led to an unjustified payment?

 a) The paid money is lost. They must cancel the contract and pay nothing from now on.

b) They should complain to the company, ask what happened and ask for the money back.

c) Parents can simply block the payment. They are not responsible for what their child did online.

^{Answer: (b)} 

How can I educate my learners on 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 learners in order to help them spot and manage them.

You may find the following tips useful:

• Discuss the games they play – Finding out about and discussing your learners’ favourite online games is a great way to help them recognise persuasive tactics that exist within those games. You may even be able to explore their favourite games together in the classroom to identify and point out these tactics to your learners.  
• Use your own examples – If appropriate, you may be able to use examples from your own online experiences to highlight different tactics used to pressure users into sharing data or making purchases. This could lead to discussions about the emotions it evoked, and the actions someone could take in response to these tactics.
• 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 learners. It also opens up discussion about making informed purchases and responsible spending.
• Discuss personal data – One way into this topic is to educate your learners 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 ways.
• Always offer help and support – Although issues resulting from manipulative digital marketing are likely to occur outside of the classroom, you are a trusted adult to your learners and play an important role in support them to be safe, happy and healthy – this includes online too! Ensure that your learners are aware of who they can turn to in school for help with online issues – this could be you, other designated staff or professionals in school who offer support.
• Use the Educational Toolkit for Young Consumers – The quiz questions you have answered throughout this learning module are taken from this free toolkit. It offers a video (with a supporting teacher’s discussion guide) and four sets of quiz cards that can be printed and used with learners in the classroom to explore their consumer rights online.

• 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!

   

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What advice can I give to my learners about manipulative digital marketing?

There are many steps that you can take to advise and empower your learners 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 learners 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 your learners to spot when they are being pressured into sharing personal data or spending money. “What if…?” questions provide opportunities for considering possible scenarios as well as strategies that learners can use to mitigate and manage risks.
• Don’t rush! – Advise your learners 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 learners to make well-informed decisions.
• What do others think? – Remind your learners 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 – Make your learners aware of settings on their device, in apps and games that can help them to manage their privacy. This could include the option to turn off notifications or restrict the sharing of their personal data.
• Discuss responsible spending – Teaching learners to make informed purchases and manage their money responsibly (including how to budget and save) can help them resist the persuasive offers in games and apps.
• Check terms and conditions – Explore terms and conditions with learners for the most popular games they use. This can help them understand what personal data may be collected and shared, and how it might be used.
• Exercise privacy rights – Educating learners on privacy, including their rights and how they apply online can empower them to exercise those rights. Depending on the age of your learners, you may wish to educate them on relevant legislation that protects their rights, as well as how to contact companies if they feel their rights have been violated or if they wish for their personal data records to be deleted.