The company should offer advertising content policies that are easy to find and easy to understand.
Elements:
- Are the company’s advertising content policies easy to find?
- Are the company’s advertising content policies available in the primary language(s) spoken by users in the company’s home jurisdiction?
- Are the company’s advertising content policies presented in an understandable manner?
- (For mobile ecosystems): Does the company clearly disclose that it requires apps made available through its app store to provide users with an advertising content policy?
- (For personal digital assistant ecosystems): Does the company clearly disclose that it requires skills made available through its skill store to provide users with an advertising content policy?
Definitions:
Advertising content policies — Documents that outline a company’s rules governing what advertising content are permitted on the platform.
App — A self-contained program or piece of software designed to fulfill a particular purpose; a software application, especially as downloaded by a user to a mobile device.
App store — The platform through which a company makes its own apps as well as those created by third-party developers available for download. An app store (or app marketplace) is a type of digital distribution platform for computer software, often in a mobile context.
Clearly disclose(s) — The company presents or explains its policies or practices in its public-facing materials in a way that is easy for users to find and understand.
Easy to find — The terms of service or privacy policy is located one or two clicks away from the homepage of the company or service, or is located in a logical place where users are likely to find it.
Easy to understand / understandable manner — The company has taken steps to help users actually understand its terms of service and privacy policy. This includes, but is not limited to, providing summaries, tips, or guidance that explain what the terms mean, using section headers, readable font size, or other graphic features to help users understand the document, or writing the terms using readable syntax.
Mobile ecosystem — The indivisible set of goods and services offered by a mobile device company, comprising the device hardware, operating system, app store, and user account.
Personal digital assistant ecosystem — A personal digital assistant (PDA) ecosystem consists of an artificial intelligence-powered interface installed on digital devices that can interact with users through text or voice to access information on the Internet and perform certain tasks with personal data shared by the users. Users can interact with PDA ecosystems through skills, which are either made available by third-party developers/providers or the PDA itself.
Skills — Skills are voice-driven personal digital assistant capabilities allowing users to perform certain tasks or engage with online content using devices equipped with a personal digital assistant. Personal digital assistant ecosystem skills are similar to mobile ecosystem apps: users can enable or disable built-in skills or install skills developed by third-parties through stores similar to app stores.
Skill store — The platform through which a company makes its own skills as well as those created by third-party developers available for download. A skill store (or skill marketplace) is a type of digital distribution platform for computer software.
Indicator guidance: Companies that enable any type of advertising on their services or platforms should clearly disclose the rules for what types of ad content is prohibited—for example, ads that discriminate against individuals or groups based on personal attributes like age, religion, gender, and ethnicity. Companies should be transparent about these rules so both users and advertisers can understand what types of ad content are not permissible and so they can be accountable for the ad content that appears on their services or platforms.
Therefore companies should make these rules easy to find (E1) and easy to understand (E3), and available in the primary languages spoken by users in the company’s home jurisdiction (E2). Companies that operate mobile ecosystems (Apple iOS, Google Android, and Samsung’s implementation of Android) and personal digital assistant ecosystems (Amazon’s Alexa, Alibaba’s AliGenie) should enable users to choose which apps or skills to download on the basis of their participation (or not) in advertising networks. Therefore, Element 4 and Element 5 ask whether the company discloses a requirement for apps or skills made available through its app store or skill store to provide users with an advertising content policy.
Potential sources:
- Company advertising policies
- Company business help center
- Company terms of use
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