CARU’s Not Kitten Around During Review of Outfit7’s ‘My Talking Tom’ App, Recommends Modifications; Company Says It Will Do So

New York, NY –March 6, 2019 The Children’s Advertising Review Unit has recommended that Outfit7 Ltd. modify its “My Talking Tom” app to better disclose advertising content, prevent inappropriate ads from displaying, and remove advertising content from its privacy policy. The company has agreed and will do so.

“The mobile app environment is constantly changing and creators of apps directed to children need to be mindful that new advertising techniques may not comply with CARU’s guidelines” said CARU director Dona J. Fraser.

CARU is an investigative unit of the advertising industry’s system of self-regulation. It is administered by the Council of Better Business Bureaus. CARU initiates and receives complaints about advertising and privacy practices, and determines whether such practices are in compliance with CARU’s guidelines. CARU also monitors websites and apps for compliance with its guidelines, including guidelines on Online Privacy Protection, as well as with the federal Children’s Online Privacy Protection Act (COPPA.)

The My Talking Tom app features “Tom,” an animated cat. Through user-controlled buttons, children take care of Tom by making him do different things such as eat, sleep, play, and go to the bathroom.

While playing the game, the user is exposed to advertisements, including banner ads and pop-up ads for games developed by Outfit7  as well as for third-party games and products. In some cases, an ad launches automatically and in others, children can choose to watch an ad to obtain an item in the game. Upon CARU’s initial review, several of the advertisements were not clearly labeled as ads. CARU also noted ads for products that are inappropriate for children, such as prescription drugs.

In this case, CARU determined that a child might not understand that the in-app advertisements were actually ads and not game content. CARU found that the advertising was presented in a manner that blurred the distinction between the advertising and the content in a manner that would be misleading to children.

CARU also found ads for Teen-rated games and other products that were inappropriate for children and were not compliant with its guidelines.

The company, in its advertiser’s statement, agreed to comply with CARU’s recommendations. It also noted that, prior to receiving CARU’s inquiry, it was in the process of reviewing all its ad positions and had initiated a process of making ad disclosures even clearer.

CARU’s inquiry was conducted under NAD/CARU/NARB Procedures for the Voluntary Self-Regulation of National Advertising. Details of the initial inquiry, CARU’s decision, and the advertiser’s response will be included in the next NAD/CARU Case Report.