BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords...
Transcript of BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords...
Directorate-General for Consumers
2018 EUR 1 EN
BEHAVIOURAL STUDY ON
ADVERTISING AND MARKETING
PRACTICES IN ONLINE SOCIAL MEDIA
Annex 131 Desk research report
Consumers Health Agriculture and
Food Executive Agency
Specific contract No 2015 85 01 under Framework contract No Chafea 2015 CP 01 Prepared by the GfK Consortium
Final version June 2018
Directorate-General for Consumers
2018 EUR 2 EN
EUROPEAN COMMISSION
Produced by Consumers Health Agriculture and Food Executive Agency (Chafea) on behalf of
Directorate-General for Justice and Consumers
Unit 03 Economic analysis and evaluation
Contact Unit 03
E-mail JUST-03eceuropaeu
European Commission
B-1049 Brussels
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 3 EN
Behavioural Study on
Advertising and Marketing
Practices in
Online Social Media
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Directorate-General for Consumers
2018 EUR 4 EN
LEGAL NOTICE
This report was produced under the EU Consumer Programme (2014-2020) in the frame of a specific contract
with the Consumers Health Agriculture and Food Executive Agency (Chafea) acting on behalf of the
European Commission
The content of this report represents the views of GfK Belgium and is its sole responsibility it can in no way
be taken to reflect the views of the European Commission andor Chafea or any other body of the European
Union
The European Commission andor Chafea do not guarantee the accuracy of the data included in this report
nor do they accept responsibility for any use made by third parties thereof
Project number 20183823
Title Desk research report
Language version FormatVolume Catalogue number ISBN DOI
EN PDF PDFVolume_01 EB-01-18-686-EN-N 978-92-9200-943-4 102818084680
copy European Union 2018
Reproduction is authorised provided the source is acknowledged
EUROPEAN COMMISSION
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2018 EUR 5 EN
Table of Contents
1 Introduction 7
2 Desktop OSM platforms 9
21 OSM providers with an in-house advertising service 9
211 Native advertising 10
212 Influencer marketing 11
213 Advertorials 13
214 Astroturfing 14
215 Artificial boosting of social indicators 15
216 Extrapolation of social endorsements 17
217 Practices that involve misleading commercial content 19
218 Non-commercial misleading practices 21
22 Third-party display network OSM platforms 24
221 Blacklist practices on misleading display advertisements 24
23 Practices that involve personal data access 31
231 Social logins 31
3 Mobile OSM applications 32
31 Snapchat 32
311 Native advertising 33
312 Clickbait 35
32 SoundCloud 35
33 Facebook Messenger 36
34 Viber 36
35 Skype 37
4 Conclusion 39
5 Appendix 40
51 Appendix 1 Desk research codebook - sample 40
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Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
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2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
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2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
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2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
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213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
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Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
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2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
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2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
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2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
Directorate-General for Consumers
2018 EUR 2 EN
EUROPEAN COMMISSION
Produced by Consumers Health Agriculture and Food Executive Agency (Chafea) on behalf of
Directorate-General for Justice and Consumers
Unit 03 Economic analysis and evaluation
Contact Unit 03
E-mail JUST-03eceuropaeu
European Commission
B-1049 Brussels
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 3 EN
Behavioural Study on
Advertising and Marketing
Practices in
Online Social Media
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 4 EN
LEGAL NOTICE
This report was produced under the EU Consumer Programme (2014-2020) in the frame of a specific contract
with the Consumers Health Agriculture and Food Executive Agency (Chafea) acting on behalf of the
European Commission
The content of this report represents the views of GfK Belgium and is its sole responsibility it can in no way
be taken to reflect the views of the European Commission andor Chafea or any other body of the European
Union
The European Commission andor Chafea do not guarantee the accuracy of the data included in this report
nor do they accept responsibility for any use made by third parties thereof
Project number 20183823
Title Desk research report
Language version FormatVolume Catalogue number ISBN DOI
EN PDF PDFVolume_01 EB-01-18-686-EN-N 978-92-9200-943-4 102818084680
copy European Union 2018
Reproduction is authorised provided the source is acknowledged
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 5 EN
Table of Contents
1 Introduction 7
2 Desktop OSM platforms 9
21 OSM providers with an in-house advertising service 9
211 Native advertising 10
212 Influencer marketing 11
213 Advertorials 13
214 Astroturfing 14
215 Artificial boosting of social indicators 15
216 Extrapolation of social endorsements 17
217 Practices that involve misleading commercial content 19
218 Non-commercial misleading practices 21
22 Third-party display network OSM platforms 24
221 Blacklist practices on misleading display advertisements 24
23 Practices that involve personal data access 31
231 Social logins 31
3 Mobile OSM applications 32
31 Snapchat 32
311 Native advertising 33
312 Clickbait 35
32 SoundCloud 35
33 Facebook Messenger 36
34 Viber 36
35 Skype 37
4 Conclusion 39
5 Appendix 40
51 Appendix 1 Desk research codebook - sample 40
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 3 EN
Behavioural Study on
Advertising and Marketing
Practices in
Online Social Media
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 4 EN
LEGAL NOTICE
This report was produced under the EU Consumer Programme (2014-2020) in the frame of a specific contract
with the Consumers Health Agriculture and Food Executive Agency (Chafea) acting on behalf of the
European Commission
The content of this report represents the views of GfK Belgium and is its sole responsibility it can in no way
be taken to reflect the views of the European Commission andor Chafea or any other body of the European
Union
The European Commission andor Chafea do not guarantee the accuracy of the data included in this report
nor do they accept responsibility for any use made by third parties thereof
Project number 20183823
Title Desk research report
Language version FormatVolume Catalogue number ISBN DOI
EN PDF PDFVolume_01 EB-01-18-686-EN-N 978-92-9200-943-4 102818084680
copy European Union 2018
Reproduction is authorised provided the source is acknowledged
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 5 EN
Table of Contents
1 Introduction 7
2 Desktop OSM platforms 9
21 OSM providers with an in-house advertising service 9
211 Native advertising 10
212 Influencer marketing 11
213 Advertorials 13
214 Astroturfing 14
215 Artificial boosting of social indicators 15
216 Extrapolation of social endorsements 17
217 Practices that involve misleading commercial content 19
218 Non-commercial misleading practices 21
22 Third-party display network OSM platforms 24
221 Blacklist practices on misleading display advertisements 24
23 Practices that involve personal data access 31
231 Social logins 31
3 Mobile OSM applications 32
31 Snapchat 32
311 Native advertising 33
312 Clickbait 35
32 SoundCloud 35
33 Facebook Messenger 36
34 Viber 36
35 Skype 37
4 Conclusion 39
5 Appendix 40
51 Appendix 1 Desk research codebook - sample 40
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 4 EN
LEGAL NOTICE
This report was produced under the EU Consumer Programme (2014-2020) in the frame of a specific contract
with the Consumers Health Agriculture and Food Executive Agency (Chafea) acting on behalf of the
European Commission
The content of this report represents the views of GfK Belgium and is its sole responsibility it can in no way
be taken to reflect the views of the European Commission andor Chafea or any other body of the European
Union
The European Commission andor Chafea do not guarantee the accuracy of the data included in this report
nor do they accept responsibility for any use made by third parties thereof
Project number 20183823
Title Desk research report
Language version FormatVolume Catalogue number ISBN DOI
EN PDF PDFVolume_01 EB-01-18-686-EN-N 978-92-9200-943-4 102818084680
copy European Union 2018
Reproduction is authorised provided the source is acknowledged
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 5 EN
Table of Contents
1 Introduction 7
2 Desktop OSM platforms 9
21 OSM providers with an in-house advertising service 9
211 Native advertising 10
212 Influencer marketing 11
213 Advertorials 13
214 Astroturfing 14
215 Artificial boosting of social indicators 15
216 Extrapolation of social endorsements 17
217 Practices that involve misleading commercial content 19
218 Non-commercial misleading practices 21
22 Third-party display network OSM platforms 24
221 Blacklist practices on misleading display advertisements 24
23 Practices that involve personal data access 31
231 Social logins 31
3 Mobile OSM applications 32
31 Snapchat 32
311 Native advertising 33
312 Clickbait 35
32 SoundCloud 35
33 Facebook Messenger 36
34 Viber 36
35 Skype 37
4 Conclusion 39
5 Appendix 40
51 Appendix 1 Desk research codebook - sample 40
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 5 EN
Table of Contents
1 Introduction 7
2 Desktop OSM platforms 9
21 OSM providers with an in-house advertising service 9
211 Native advertising 10
212 Influencer marketing 11
213 Advertorials 13
214 Astroturfing 14
215 Artificial boosting of social indicators 15
216 Extrapolation of social endorsements 17
217 Practices that involve misleading commercial content 19
218 Non-commercial misleading practices 21
22 Third-party display network OSM platforms 24
221 Blacklist practices on misleading display advertisements 24
23 Practices that involve personal data access 31
231 Social logins 31
3 Mobile OSM applications 32
31 Snapchat 32
311 Native advertising 33
312 Clickbait 35
32 SoundCloud 35
33 Facebook Messenger 36
34 Viber 36
35 Skype 37
4 Conclusion 39
5 Appendix 40
51 Appendix 1 Desk research codebook - sample 40
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 6 EN
Disclaimer This document contains a review of desk research conducted during the first
quarter of 2017 As a result of the rapid development of the OSM platforms researched it is possible that some of the examples provided as well as certain links have become outdated or are not longer available Over the course of the
study and while this report was being prepared for publication some OSM providers may have introduced changes to their platforms (eg with the
purpose of product improvements or because of new legal obligations) making some of the practices described in this report no longer applicable
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 7 EN
1 Introduction
An in-depth systematic review of the content on the most relevant OSM providers
identified was conducted to build a typology of commercial practices in OSM and to
identify practices that could be misleading or unfair from a consumer perspective The
research was conducted from three perspectives advertising and marketing options
offered by the OSM to traders marketing content OSM users are actually exposed to
and specific marketing practices commonly adopted by traders
To gain insights on the latent commercial practices a web search has been conducted
via use of specific keywords on Google and Ecosia (based on Yahoo Search terms)
This web search consisted of two parts The first part focused on the end-point of the
potentially misleading practices and in particular on the complaints of users and news
articles about misleading practices The second part focused on the starting-point of the
misleading practices and the intention to make profit by using misleading practices on
online social media
A total of 678 internet sources have been collected and examined in the course of the
Desk Research conducted The collected internet sources have been assessed for their
credibility before they were included in the logbook in order to exclude sources that
might not represent real practices from the desk research The collected sources mainly
fall within one of the following categories news articles blogs academic articles
forums and communities The source credibility assessment was based upon a brief
review of the author of the content provided the date when the content was published
or last updated the sources quoted (if any) the overall perceived credibility of the
domain the examples given within the content and the design of the website and the
writing style Further background checks were based on domain reviews (and their
authors) the quality form and functionality of references and links (if any) to other
sources cited the websitersquos linking policy and a website-user interaction analysis In
case of uncertainty multiple sources were gathered in order to verify that the content
was credible Whenever a source was assessed as credible it was stored in the
logbook Forum threads were also stored in the logbook as they identify the scope of
activity on certain topics including any activity on misleading commercial practices or
complaints1
Many of the search results related to forum threads and topics about black hat
marketing and how-to guides on making money on the internet The term Black hat
(marketing) refers to practices that violate the terms of service of online platforms such
as social media The black hat activities most discussed on these forums are the
exchange of social proof indicators as well as automation programs for spamming
purposes in order to sell goods to OSM users The most active forums related to
applying potentially misleading practices on social media are BlackHatWorld2 and
HackForums3 Both forums have specific topics related to social media marketing45
1 Forum threads were never used as a primary source for defining a potentially misleading
practice but rather to back-up primary sources 2 httpswwwblackhatworldcom 3 httpshackforumsnet 4 httpshackforumsnetforumdisplayphpfid=263 5 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 8 EN
Furthermore both forums have been active for approximately 10 years and have
extensive user bases with active members
On these forums the term black hat marketing was consistently used for describing
unethical practices that may take place on the World Wide Web including social media
Black hat marketing practices appear to be discussed mainly with relationship to larger
rather than smaller social media platforms This can be observed through the uneven
distribution of messages posted in each subtopic concerning social media marketing on
Blackhatworld6 Facebook and Instagram are most often discussed with respectively
177000 and 120000 messages posted The next most active subtopics concern
Twitter with 20000 messages and Pinterest with 6000 messages in the subtopic
Smaller OSM platforms appear to be less popular primarily because the user base and
target audience are smaller which makes it more time-consuming to reach a specific
target audience In addition online social media that do not offer an in-house self-
service advertising platform are less interesting for malicious advertisers because the
advertising process is longer more curated and more expensive However this does
not imply that smaller platforms are not affected by misleading commercial practices
As our analysis of display advertisements has shown third-party display advertising
networks that are connected with certain smaller OSM platforms provide more
misleading display advertisements than the OSM platforms themselves do
A third-party display advertising network acts as an intermediary between a network of
connected websites and the advertisers In case a website chooses to connect to a
third-party display advertising network all or part of their advertisements are managed
by the third-party advertising network It is also possible that a website chooses to host
its own advertisements and to connect to one or more third-party advertising networks
to cover all remaining advertising space
The logbook also lists the keywords used and a quantification of the findings of the
desk research The keywords collected will be used for presenting the potentially
misleading practices occurring in the social media landscape in the form of a narrative
The remainder of this report features two sections the first covering the desktop OSM
platforms and the second discussing the mobile OSM
6 httpswwwblackhatworldcomforumssocial-networking-sites32
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 9 EN
2 Desktop OSM platforms
The desktop OSM platforms cover most of the potentially misleading practices
identified The next section is divided in two parts The first part elaborates on the OSM
platforms that provide an in-house self-service advertising platform on which
advertisers can create their own advertisements from start to end In this process the
only action OSM platforms are to take is the review of the final advertisement The
second part of this section discusses OSM platforms that only provide advertising via
third-party display advertising networks mainly consisting of smaller and national OSM
platforms The main difference between the two parts lies in the role and potential
responsibility of OSM platforms towards the commercial content that is being displayed
on their websiteplatform OSM platforms that provide an in-house self-service
advertising platform generally play a more important role and can be considered to
bear greater responsibility towards the commercial content that is being shown on their
websiteplatform These OSM platforms need to set up their own advertising policies
and are themselves in charge of the reviewing process OSM platforms that make use
of third-party display networks may be seen as mainly having the responsibility of
choosing or allowing certain display networks to populate advertising display areas on
their websites The third-party display network in this case is in charge of the
advertising policies and reviewing process Lastly the third part will discuss practices
that involve personal data access which is used on both types of OSM-platforms
21 OSM providers with an in-house advertising service
OSM providers with in-house advertising platforms that are included Facebook
YouTube Twitter Instagram Reddit Tumblr LinkedIn Pinterest Twitch Imgur
Odnoklassniki (OKru) VKontakte (VKcom) Xing and Draugiem
Marketing content can be displayed on OSM via one of two channels an in-house
advertising platform that is developed and hosted by the OSM provider or a third-party
advertising network that acts as an intermediary in the process Not all OSM have their
own in-house advertising platform some use only third-party advertising networks
while others use a combination of both78 Third-party advertising networks operate by
matching advertisers to specific OSM providers with high user traffic and available
advertising space These networks serve as intermediaries matching advertising supply
from publishers to advertiser demand online The most widely used third-party
advertising network is Googlersquos AdSense network9 The key distinction between these
7 OSM that have in-house advertising platforms are Facebookcom Youtubecom Twittercom
Instagramcom Redditcom Linkedincom Pinterestcom Twitchtv Imgurcom Okru Vkcom
Wikiacom 9gagcom Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Facebook Messenger Snapchat Third-party Redditcom Tumblrcom Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 8 OSM that work with third-party advertising networks are Redditcom Tumblrcom
Linkedincom Twitchtv Imgurcom Okru Vkcom Wikiacom 9gagcom Cdapl Gutefragenet Xingcom Vbox7com Gyakorikerdesekhu Draugiemlv Flashbackorg Skyrockcom Suomi24fi SoundCloud Skype 9 OSM providers that work with the Googlersquos Adsense network are Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit and Odnoklassniki Other
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 10 EN
two types of advertising channels in terms of roles and responsibilities is that when
traders advertise through OSMrsquos in-house advertising platforms they need to abide by
the content and formatting rules and guidelines set by the OSM provider On the other
hand when advertising through a third-party advertising network the rules and
guidelines of that network apply
In terms of content and format advertisements displayed through third-party networks
are more standardised10 compared to in-house advertising platforms where more ad
customisation is available to traders As such advertising through in-house platforms is
more flexible in terms of the type of content displayed and the mode and context of its
presentation on the platform In addition marketing content displayed through in-
house advertising platforms is more likely to generate possibilities for social interaction
(eg like follow share etc) usually appearing directly in usersrsquo feeds which makes it
more difficult to distinguish from user-generated content For example a sponsored
Tweet is a form of advertising that takes place through Twitterrsquos in-house advertising
platform When OSM use third-party advertising networks in addition to their in-house
platform the advertisements mostly include bannerskyscraper ads on top or on the
side of the page and the content is often static For example third-party network ads
can be seen on the fixed right-side column of Facebookrsquos website and as TrueView ads
on YouTube which appear as short videos displayed directly before user-generated
video content
211 Native advertising
Native advertising formats are pertinent to the OSM platform itself How native
advertisements are used and displayed is mainly a result of how the OSM platform
decides to implement native advertisements This gives the OSM a proactive role in the
display of native advertisements
As the online communities report indicates it is sometimes very difficult to differentiate
between commercial or non-commercial intent This is largely due to the increasing use
of native advertising advertising that is aimed to blend in with non-commercial content
as much as possible and the diversity of disclosures used between different OSM
platforms The appearance of native advertising mainly dependents on how an OSM
platform displays and discloses its content The more business-oriented the platform is
the more difficult it is to differentiate between commercial or non-commercial content
as on business platforms all content displayed appears to be commercial As it was also
observed in the online communities it is particularly difficult to identify advertising on
platforms such as Pinterest LinkedIn and Xing As the activity on these platforms is
mostly related to the promotion of a business profile it is sometimes difficult to
distinguish the user-generated non-commercial content
Since native advertising is ubiquitous in OSM contexts its potential impact on
consumers is likely to be considerable if they have difficulties differentiating it from
non-commercial content This is difficult to establish via desk research since consumer
reactions are difficult to measure Readily available information is also limited most
probably due to the fact that it is difficult for consumers to identify the potentially
third-party advertising networks are mainly Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for Gyakorikerdesek and Appnexus for Skyrock 10 Standardised formats are necessary due to the large scale at which third-party advertising networks operate
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 11 EN
misleading nature of native advertising This subtle impact combined with how its ever
increasing popularity is what makes native advertising interesting to explore further via
more concrete quantitative methodologies In addition native advertisements can also
be ldquosocially wrappedrdquo meaning that social interactions are possible on the
advertisements making it even more difficult to distinguish user-generated posts from
advertisements OSM users can react like and share advertisements just as with
regular user-generated posts These practices were recommended to study further via
behavioural experiments within the scope of Task 2
212 Influencer marketing
Another type of social proof marketing perceived as potentially misleading is covert
product promotions by influencers The problem with covert product promotions is
mainly caused by influencers who do not disclose their sponsorship related to the
content shared Undisclosed advertising occurs when explicitly promoting a product
service or brand in content without mentioning that the content is sponsored YouTube
for example defines paid product placements and endorsements as follows11
ldquoPaid product placements may be described as pieces of content that are
created for a third party in exchange for compensation andor where that
third partys brand message or product is integrated directly into the content
Endorsements may be described as pieces of content created for an advertiser
or marketer that contain a message that consumers are likely to believe
reflects the opinions beliefs or experiences of the content creator or
endorserrdquo
Several OSM platforms have addressed the issue of undisclosed advertising and have
set specific rules in order to disclose the - mostly contracted - affiliation with the brand
that is sponsoring the shared content Both the brand that is sponsoring the product
and the influencer that is promoting the message or content are held responsible for
providing the appropriate disclosures However these rules are not always followed and
even when they are in many cases it remains difficult for users to distinguish between
sponsored and unsponsored user-generated content Disclosing the sponsored
character of the content could influence usersrsquo purchasing behaviour This effect is
likely to increase if the fansfollowers of the celebrity or influencer are unaware of the
paid endorsement and believe that the influencer is a genuine fan of the sponsored
product Knoll and Matthes (2017) for example pointed out that the most positive
attitudinal affect appeared when male actors implicitly endorsed a product The most
negative effect occurred when female models explicitly endorsed a product12
The sponsoring of products without clearly stating that the communication about the
products is paid for occurs mainly on social media platforms with large public sections
or on platforms where celebrities and influencers can be followed This contrasts with
the OSM platforms which are aimed primarily at private communication such as Skype
and WhatsApp The studied OSM platforms have different means of handling sponsored
content On YouTube for example users who upload a video are required to notify
YouTube if their video contains paid product placements (and has to disclose this in the
description of their video as well) However in certain cases users do not adhere to
these rules13 or they do not fully comply with them14 Consequently it is difficult to
11 httpssupportgooglecomyoutubeanswer154235hl=en 12 httplinkspringercomarticle101007s11747-016-0503-8 13 httpwwwindependentcouknewsmediaonlinevloggers-increasingly-target-children-with-covert-advertising-10114715html
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 12 EN
identify whether a video was endorsed or not Moreover there is no specific button or
functionality devoted to report videos with implicit product endorsement
Facebook countered the use of native advertising in 2016 by automatically adding ldquowith
[brand] and ldquopaidrdquo to native posts that are connected to and endorsed by a specific
brand15 Facebook promotes the use of this so called ldquobranded content toolrdquo16 by
allowing the brands that are tagged in these posts to be able to see high-level
performance insights and receive notifications for events that occur on the branded
content posts However in order to use the branded content tool page owners are
required to apply for it first The creators and publishers also remain responsible for
complying with the advertising regulations in their markets and they are obliged to
provide the necessary disclosures themselves besides Facebookrsquos standard disclosure
The potentially misleading practice of not disclosing sponsored content is widespread
and can be observed among celebrities as well as lesser known vloggers across the
globe There are for example online platforms through which brands can hire vloggers
on YouTube for endorsements17 with prices starting from $500
Also on Twitter for example rules concerning the promotion of products on usersrsquo
personal page should be followed Those who are paid for promoting a brand should
include at least the handle ldquoadrdquo or ldquosponsrdquo This however does not always appear to
be present in sponsored tweets The example from Cristiano Ronaldo below does not
include the ldquoadrdquo handle
Cristiano Ronaldo promoting his ldquoNike am97rdquo shoes without using any sponsorship
tags
14 httpwwwcosmopolitancoukbeauty-hairmakeupnewsa36000youtube-makeup-tutorial-
banned-for-misleading-advertising 15 httpsmediumcomstartup-grinddid-facebook-just-deliver-a-crushing-blow-to-native-advertising-30ae5acf61e 16 httpswwwfacebookcomfacebookmediaget-startedbranded-content 17 httpswwwgrapevinelogiccom
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 13 EN
213 Advertorials
While endorsements such as influencer marketing are a common and conventional way
of promoting a product or service the practice becomes more problematic when the
commercial purpose of this content is not disclosed to the users with whom the content
is shared This gives a misleading pseudo-spontaneous character to the content while
the influencers or the OSM are on the contrary often paid for their positive presentation
of the product In addition to that the commercial nature of the content can be
disguised even more when the product which is meant to be promoted is not
addressed explicitly in the content but is only (though clearly visibly) present in the
content ndash eg an influencer wears a particular brand of sporting clothes in a video they
share about them doing a work-out
Wikia also includes a high number of native advertising spread all over the main page
of the website However these donrsquot always seem to be tagged as ldquosponsoredrdquo which
makes native advertisements seem more like advertorials One can find for example
several ldquotop storiesrdquo on the main page which apparently are part of the website After
users click on the hyperlink it redirects them to a story on an external website There
is however no mention of sponsored content in most of these cases except for one
case where the tag ldquosponsoredrdquo was shown When considering the creator of the
specific sponsored post we observed that most writers of top story articles are also
staff writers at Wikia Furthermore most unsponsored top story articles are written by
external writers who have a direct connection with Wikia There are for example top
stories that direct users to an actual Wikia page whereas there are also top stories that
direct users to an article on an external website The latter top stories are thus not
created by a writer on Wikia but by a partner which can be a magazine or blog that
publishes fanfiction articles The content users are redirected to is clearly not generated
by the users of Wikia as users are redirected to a completely different website when
clicking on the content The observations suggest that Wikia has several ldquopartnersrdquo
which occasionally publish articles about fanfiction topics and receive mentions on
Wikiarsquos ldquotop storiesrdquo for their articles However by not indicating the redirected articles
as sponsored in any way these ldquotop storiesrdquo could be seen as disguised
advertisements
An external article of a partner called ldquoSlashfilmrdquo on the left and a sponsored Wikia post
on the right referring to a page on Wikia
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 14 EN
Both the upper and the lower top stories direct visitors to an article on an external
news website which is clearly not written by the users of Wikia respectively to
httpdeadlinecom201702fargo-season-3-premiere-date-fx-ewan-mcgregor-
1201942334 and httpwwwhollywoodreportercomheat-visionyvonne-strahovski-
joins-shane-blacks-predator-978541
214 Astroturfing
The potentially misleading practice of promoting a product (or political standpoint) can
also constitute ldquoastroturfingrdquo The word astroturfing is described as the practice of
hiding the sponsors of a message or an organization to pretend as if the message
originates from a genuine user customer participant or organization18 Instead of
merely sponsoring a product without disclosing that it is sponsored astroturfing goes
beyond this by also creating a false impression about the product For example
Microsoft had closed agreements with vloggers to stop them from spreading negative
word-of-mouth about the Xbox One or any of its games Microsoft hereby aimed to
create a positive image about their brand using influential people to spread their
messages19 Individuals associated with spreading artificial messages are also called
ldquointernet shillsrdquo Internet Shills promote companies products public figures and
viewpoints for the sole purpose of financial gain In the context of e-commerce fake
reviews could also be considered as astroturfing20
18 httpswwwtheguardiancomcommentisfree2012feb08what-is-astroturfing 19 httptechrightsorg20130609reddit-infiltrated 20 httpwhatistechtargetcomdefinitionInternet-shill
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 15 EN
215 Artificial boosting of social indicators
The digital and often anonymous nature of the social proof indicators makes them
vulnerable to exploitation In particular traders can artificially boost social proof
indicators for specific content on a large scale to create the perception that the content
is more popular than it actually is Different types of social proof indicators can be
boosted artificially likes views followers fans shares retweets reviews up-votes
and more This practice does not aim to get actual users to interact with content but
merely aims to give them the wrong impression that there has been strong
engagement with a particular profile or piece of content It is usually paid for or
otherwise compensated depending on the channel used to boost the indicator
Artificial boosting is often achieved by using automated programs (so-called ldquobotsrdquo) or
by hiring firms (also known as ldquoclickfarmsrdquo) to manually like share or follow certain
content21 These companies facilitate the direct acquisition of fake social proof
indicators22 The main activities of ldquoclickfarmsrdquo include creating numerous fake user
accounts and using them to execute actions that simulate real usersrsquo behaviour through
automated scripts Several online micro jobs sites contain vacancies for farming social
proof indicators Another way of boosting social proof indicators includes the use of
automated programs often referred to as bots2324 The method is similar to that
adopted by ldquoclickfarmsrdquo but the process is fully automated and interested parties pay
for the software to help them boost social proof indicators rather than for specific
services A different technique used by marketers as well as individual users are share
for share (S4S) and like for like (L4L) networks25 These services allow individuals to
connect to a network of users who wish to boost their social presence through social
proof indicators for free Users offer likes or shares to other users that are connected to
the network in order to receive them in return
The practices listed above can distort social proof indicators creating artificially high
numbers of likes shares followers etc26 To the extent that users and OSM algorithms
cannot distinguish between sincere user interactions with content and artificial or paid-
for interactions by bots ldquoclickfarmsrdquo or L4L networks they may mistakenly perceive
the latter as added proof of the value of that content
As most OSM platforms rely heavily on shared content which can be liked and
commented on these practices occur on most of the selected OSM platforms Although
the social proof indicators differ slightly across different social media platforms they
rely on the common social foundation
- Facebook likes (including emotions) shares comments fans followers friends
and views
- YouTube views likes and subscribers
- Twitter likes retweets replies and followers
21 httpdigitaltohumancomviral-contentclick-farms-help-fake-online-popularity 22httpswwwfiverrcomcategoriesonline-marketingsocial-marketingsource=category_treeamppage=1ampfilter=rating 23 httpmoobotscom 24httpsdocumentstrendmicrocomassetswhite_paperswp-fake-news-machine-how-propagandists-abuse-the-internetpdf p24 25 httpswwwlike4likeorg 26 httpswwwnytimescominteractive20180127technologysocial-media-botshtml
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 16 EN
- Instagram likes followers and comments
- Reddit up-votes and karma
- Tumblr shares reblogs likes and comments combined as ldquonotesrdquo
- LinkedIn connections likes comments and shares
- Pinterest likes shares and repins
- Twitch (live) views comments likes and followers
- Imgur up-votes (points) views and comments
- Odnoklassniki likes shares comments friends fans and views
- Vkontakte likes shares comments friends fans and views
- Xing connections likes comments and shares
- Draugiem likes shares comments friends fans and views
For most OSM providers the psychological appeal of social proof is central to the
functionality of their platforms The more users interact with certain content the more
the platformrsquos algorithm will present this content to other users which will in turn often
lead to an even bigger boost in the contentrsquos popularity and visibility Facebook for
example utilizes an algorithm called ldquoEdgerankrdquo to display content in a certain order on
usersrsquo newsfeed The algorithm functions as follows if users never interact with a
certain page or friend posts from this page or friend will be marked as less interesting
and shown less frequently and less prominently in their newsfeed27 Conversely if users
often interact with a specific page or friendrsquos posts these will be shown more frequently
and higher up in their newsfeed As such by artificially boosting social proof indicators
commercial content may be able to lsquofoolrsquo the ldquoEdgerankrdquo algorithm and ensure that the
content achieves far wider reach and engagement than it otherwise would These
algorithms are not available to the public and are subject to continuous adaptations in
terms of which type of content is prioritised on usersrsquo newsfeeds28 As OSM users
appear to rely on perceived social activity or social proof indicators for decision-
making29 social proof that is artificially boosted and that is not identified as such by the
OSM providersrsquo algorithms could in principle start a bandwagon effect and ensure a
more prominent position for specific content in usersrsquo feeds
In an effort to appear more trustworthy to consumers and avoid identification from
OSM providers profiles stemming from ldquoclickfarmsrdquo often like or follow unrelated pages
for which they do not receive monetary compensation This practice is also problematic
as traders with no intention of associating their brand with unethical practices could
also receive fake endorsements without having taken any action to acquire them30
Although the traders concerned did not operate via ldquoclickfarmsrdquo to acquire likes they
still appeared to receive likes from profiles that are not associated with regular users
27 Here is a historical overview of specific changes made to Facebookrsquos algorithm in terms of content prioritisation httpswallaroomediacomfacebook-newsfeed-algorithm-change-history 28 Here is Facebookrsquos latest communication with this respect dating from 11 January 2018 httpsnewsroomfbcomnews201801news-feed-fyi-bringing-people-closer-together 29 Grahl Joumlrn Franz Rothlauf and Oliver Hinz 2013 How do social recommendations influence shopping behaviour A field experiment Available at httpswwwemarketstu-darmstadtdefileadminuser_uploaddownloadWorking_PapersValue-of-Social-Recommendation-2013-04-30-Working-Paperpdf 30 httpwwwbusinessinsidercomfacebook-advertising-fake-likes-2014-2IR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 17 EN
These profiles are characterised by a low number of connections or interactions with
other users and a high number of liked pages usually feature poorly written content or
incomplete information and originate from regions where ldquoclickfarmsrdquo tend to be
located
In addition encouraging interaction with or endorsement of content by promising
specific rewards also appears to be a common practice among smaller traders who aim
to gain a higher following on social media although some OSM providers seem to have
pushed back against this practice in the last few years For instance Facebookrsquos user
policies now forbid asking users to like a certain page before they can enter a
competition31 This policy relates specifically to profile pages however and not to
individual posts for which traders can still use this strategy to request endorsements
(eg likes or comments) During our desk research we did find specific instances of
this practice indicating that it still occurs and that OSM providersrsquo self-regulation
practices are not completely effective
There is some indirect evidence however that the use of and interest in these
practices seems to have decreased in recent years This finding is based on our
systematic investigation of online spaces (eg dedicated pages or forums) where the
topic is regularly discussed by traders and other stakeholders
216 Extrapolation of social endorsements
OSM providers have developed different ways to maximise the value and impact of
social proof indicators Facebook in particular applies a technique that links user
interactions with content to create a social proof effect for other related content
Whenever an advertisement is shown to an OSM user who has at least one Facebook
friend who has engaged in a certain way with the advertiser social information is added
to the advertisement Four types of interactions are used to show in socially wrapped
advertisements namely page likes post likes comments on a post and post shares
The addition of social information in advertisements does not require additional
payment and is automatically added to all advertisements there is also no option
available for advertisers to not use social information on their advertisements
However users can edit their permissions in order to not have their profile shown in
socially wrapped ads32 Thus when someone likes a commercial page Facebook will
not only add this like to the total number of likes for that page but it will also refer to it
in advertisements published by the trader who manages the page For example if
someone like a specific brandrsquos page an ad sponsored by the page owner would
contain ldquo[Friendrsquos name] likes [brand name]rdquo when presented to a user whose friend
liked the brandrsquos page Facebook refers to this option as ldquoadding a social storyrdquo and it
can be seen as a way of wrapping commercial content with social behaviour
The second potentially problematic practice related to social proof is based on the use
of individual rather than aggregated social proof It relies on the strength of existing
social ties between OSM users Within the context of this study we have labelled this
practice as the ldquoextrapolation of social endorsementsrdquo The extrapolation of social
31 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 32 httpsroseninstitutecomstop-appearing-facebook-ads
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 18 EN
endorsements happens when a userrsquos positive interaction with specific OSM content is
linked or transferred to different but related content creating the appearance that the
user also takes a positive stance towards the related content For instance people can
be asked or individually choose to connect to the profile of a specific company via a
social endorsement (eg a like) After OSM users engage with a piece of commercial
content for instance by liking or sharing it this interaction is ldquotranslatedrdquo as an
endorsement of related content3334 The extrapolation of such endorsements happens
for example when they are linked to specific products of that company even though
the user who endorsed the company has never specifically endorsed or interacted with
these products
Thus even though the original like does not apply specifically to the content shown
(the advertisement) the ldquosocial storyrdquo is presented in close visual proximity to that
content which may create the impression that the user not only endorses the page but
also the specific content shown These types of social endorsements focus on close
network connections rather than strangers because they are likely to have a stronger
impact on usersrsquo perception and evaluation of the commercial content (Aral amp Walker
2014 Bakshy et al 2012 Bapna amp Umyarov 2005)
The example below shows how an authentic endorsement of a close network connection
(a friend on Facebook) can be presented to the user in such a way that it creates the
impression that the friend endorsed something else than (s)he did In addition the
timing of this endorsement is not specified so users may assume the endorsement is
recent In other words real endorsements are extrapolated to related content as well
as in time
33 Daily Mail Online (2013) Is Facebook lsquoimpersonatingrsquo users to promote stories theyrsquove never
seen to all their friends From httpwwwdailymailcouksciencetecharticle-2267575Is-Facebook-impersonating-users-promote-stories-theyve-seen-friendshtml 34 Forbes (2013) Facebook is recycling your likes to promote stories yoursquove never seen to all your friends From httpswwwforbescomsitesanthonykosner20130121facebook-is-recycling-your-likes-to-promote-stories-youve-never-seen-to-all-your-friends79652aaa17aa
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 19 EN
Example of an extrapolated like from a friend
217 Practices that involve misleading commercial content
False offer practices
A wide-spread misleading practice on social media involves the use of ldquoclickbaitrdquo35
Clickbait is the practice of portraying an appealing (mostly misleading) message
combined with an attractive or curiosity-evoking call-to-action A misleading message is
typically used which includes either shocking or ambiguous content with the sole
purpose of amplifying the userrsquos curiosity and willingness to click The advertisement
however may not be related with the actual message Clickbait is mainly used for
attracting users to a website that features advertisements An increasing amount of low
quality content is available potentially providing misleading information to its
viewers36 Clickbait is also used for promoting and selling products False ldquofree offersrdquo
35 httpsadespressocomacademyblogclickbait-facebook-advertising-examples 36 httpcardiffstudentmediacoukgairrhyddfakebook-hoax-news-and-clickbait-on-social-media
----------
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 20 EN
are extensively placed on social media to attract the attention of users and convince
them to order a free product with large ldquoextrardquo costs37
Advertisements from web shops selling counterfeit goods however can also be found
on a range of OSM platforms including the larger international OSM platforms These
advertisements often advertise products as highly discounted or as limited in stock in
order to generate sales In certain cases advertisements contain highly discounted
products that are clearly counterfeit versions of popular brands In our approach with
the available user accounts of different GfK employees many of the advertisements of
counterfeit goods could for example be found on Instagram (on the mobile
application) While analysing the advertisements on Instagram we also noticed that
advertisers do not need an Instagram account (only a facebook account and page) in
order to advertise on Instagram As such it proved extremely difficult to trace back the
advertiser on Instagram if the advertiser did not have a specific Instagram account In
addition the Facebook pages that were created with the sole purpose to advertise on
Instagram also did not display any information about the trader in such cases38
Affiliate marketing
Affiliate marketing in itself is not considered a misleading practice although it facilitates
the use of misleading practices by individuals marketing an affiliate product For
example a case concerning misleading affiliate advertising on Facebook involved an
advertisement that promised consumers a tablet or smartphone for euro2 from ldquoTest-
Aankooprdquo39 a Belgian non-profit consumer protection organization There is nothing
misleading about how Test-Aankoop promotes its product (a subscription to their
magazines) instead the affiliate marketer aimed to mislead the consumer in this case
Test-Aankoop is connected through various affiliate networks which allows affiliate
marketers to register for their affiliate marketing campaign This allows the affiliate
marketers to earn a percentage of the subscription fee from everyone they have
referred to surbscribe for Test-Aankoop These affiliate marketers may use misleading
practices to convince users to subscribe page to Test-Aankoop In this case some
affiliate marketers used fake blogsites containing fake reviews filled with cloaked
affiliate links to the subscription page of Test-Aankoop The fake blogsite merely
constitutes an intermediate stage in order to convince the consumer with fake reviews
In addition it encourages comments to proceed to the page of Test-Aankoop and
acquire a subscription for the magazine Whenever a user clicks-through to the page of
Test-Aankoop and subscribes for a subscription the advertiser and creator of the fake
blogsite receives a commission of euro25 While the misleading practice may not be the
responsibility of Facebook the platform does allow for clearly fake websites to be
advertised
A second example related to misleading affiliate marketing is from gyakorikerdesekhu
The website appears to be displaying advertisements with dubious affiliate websites
through misleading display advertisements linking to various subdomains such as
newshealthtv40 These display advertisements are however not provided via an in-
37 httptheunextremecombuyer-beware-free-just-pay-shipping 38 Our approach did not contain enough diverse user profiles to be considered representative of the online landscape in the EU and comparable across providers Therefore the validity of findings as regards specific OSM providers could be an issue 39 httpswwwdailybitsbeitemis-nu-bedoeling-test-aankoop 40 httphunewshealthtv
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 21 EN
house advertising platform but by a third-party display advertising network called
ldquoAffiliaterdquo41
218 Non-commercial misleading practices
OSM platforms are used to conduct a number of malpractices that have no commercial aim as
such ie the aim is not to commit the OSM user to a transaction nor is there a goal to get revenue
out of the interaction itself (by spreading advertisements for instance) or advertise a particular
product or service The OSM is merely exploited to establish contact with users after which the
contact is abused for other malpractices like fraud identity theft hacking installing ransomware
selling of data etc
Promise of benefits in case of content interaction
False prize winning competitions are a form of promise of benefits in case of content
interaction The main idea behind it is to collect a large number of likesfollowersfans
for a specific company profile or page This practice enhances the social proof factor of
the profile or page and allows future posts to be shown on the newsfeed of
followersfans This is a common technique of black hat marketing mainly enacted on
OSM platforms such as Facebook OKru and VKcom4243 Encouraging interaction with
or endorsement of content by promising specific rewards appears to be a common
practice among smaller traders who aim to gain a higher following on social media
although some OSM providers seem to have pushed back against this practice in the
last few years For instance Facebookrsquos user policies now forbid asking users to like a
certain page before they can enter a competition44 This policy relates specifically to
profile pages however and not to individual posts for which traders can still use this
strategy to request endorsements (eg likes or comments)
When a business page has grown sufficient followerslikes false prize competitions are
used to lure OSM users to external websites Typically consumers will be asked to
enter their personal information on these websites in this case after theyrsquove answered
some irrelevant questions This information is then stored and can be sold During our
desk research we did find specific instances of this practice indicating that it still
occurs and that OSM providersrsquo self-regulation practices are not completely effective45
When a company page featuring false prize competitions has sufficient likesfollowers
the page can also be used to either generate leads or occasionally advertise (mostly
affiliate) products However the false prize winning promotions typically do not cease
to exist when a company page has sufficiently grown they are also used to generate
leads in a deceptive way For example a Facebook page called ldquoLucky Dealsrdquo46
deliberately misleads consumers in order to generate leads Instead of retaining the
41 httpaffiliatehu 42 httplatrendmicrocommediamiscspotlight-social-media-scams-enpdf 43 httpswwwblackhatworldcomseomethod-i-used-to-make-1000-in-3-days823160 44 httpsdevelopersfacebookcomblogpost20140807Graph-API-v21 ldquoTo ensure quality connections and help businesses reach the people who matter to them we want people to like Pages because they want to connect and hear from the business not because of artificial incentives We believe this update will benefit people and advertisers alikerdquo 45 For example httpswwwfacebookcomonlinewinnen httpswwwfacebookcomconsumentendienst httpswwwfacebookcomLucky-Deals-1367979303219105 46 httpswwwfacebookcomLucky-Deals-1367979303219105
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 22 EN
user on Facebook the user is directed to a misleading website through a cloaked URL
(ie a URL that differs from the URL shown)47 In this example of Lucky Deals visitors
are promised a ldquotest packagerdquo which they can apply for by filling in a short and simple
survey as well as their personal details on the website The false prize winning in this
example consisted of free dishwashing products worth euro150 (allegedly for testing
purposes) However despite filling in the survey and personal details it is highly
questionable that the user will ever receive the test package (cf having filled in the
details on this website the GfK team never received a confirmation email) As a result
of this false competition the company behind the misleading Facebook post can profit
from selling the acquired leads4849 LeadWorld the advertiser of the prize competition
campaign also seems to be using the same technique on Instagram and via email
Some False prize winning competitions go even further by claiming to be a ldquonational
energy survey for sustainable energyrdquo50 Other Dutch examples of false prize winning
competitions include a competition to win diapers51 and a competition to win gift
cards52
47 Cloaked URLs are mainly used as a way to shorten the original link In the case of the campaign of ldquoLucky dealsrdquo it was a short bitly URL that leads to httpwasmiddel2producten-testen-be-2095comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=email
ampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampaffid=1695
ampaff_sub2=391688495ampaff_sub3=548ampref=OACampsubid=391688495 Through the original link one can already find the type of personal data that the Black Hat marketer aims to obtain 48 httpwwwhoax-slayernetwhat-is-a-facebook-survey-scam 49 httpswwwtest-aankoopbehightechinternetnieuwsleadworld-misbruikt-onze-naam-voor-nepacties 50 httpshetnationaalonderzoeknlcpNjM2Ny03MTQ4duurzame_energie 51 httpkids-active-fitproducten-testen-nl-4903comfirst_name=firstnameamplast_name=lastnameampgender=genderampemail=emailampdob=dobampmobile=mobileamphousenumber=housenumberampzipcode=zipcodeampref=OACampaffid=1695ampaff_sub2=392038802ampaff_sub3=548ampsubid=392038802 52 httpswwwaaactienlslotmachineoa_clickid=392039027
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 23 EN
Example of Misleading giveaway in order to generate leads
Translation of the advertisement
Who needs to wash a lot [Thumbs up]
We are looking for testers
Apply as soon as possible ==gtgt
For the Netherlands [link]
For Belgium [link]
Fake profiles
The use of fake OSM profiles is not a form of advertisement in itself but is relevant to
our analysis as it is a common instrument that aims to expose OSM users to certain
content particularly advertisements ndash which are often misleading and in violation of
blacklisted practices A common way of using fake profiles is to set up a basic profile
with fake background information and a few pictures and trying to connect to as many
other users on the platform as possible This can be done by pretending to be an
acquaintance or a young woman (in which case mostly men will be targeted) Once
connected the fake profile will start sharing advertisements and commercial offers to
the connected users Such profiles can also be used to spread spam on the OSM
platform for instance in publicly accessible groups or profiles Valid OSM accounts are
also offered to advertisers by certain users For example HotUKDealscom features
users who offer their active account ndash which has received positive feedback ndash for
advertising purposes53 Furthermore the credibility of profiles can be artificially
enhanced on certain platforms In Gutefragede for example individuals appear to
have leveraged fake comments in order to gain recognition
Phishing
Due to the increasing usage of social media as an online communication channel
between companies and consumers phishing techniques have also largely surfaced on
social media platforms including Twitter for example54 Phishing is described as a
misleading technique used to obtain sensitive information (primarily focusing on credit
card details)55 Phishing techniques were originally used along with email services For
example sending users an email seemingly originating from a financial institution such
53 httpswwwblackhatworldcomseolooking-for-deal-poster-hukd-hotukdeals-deal-poster864363 54 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 55 httpsearchsecuritytechtargetcomdefinitionphishing
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 24 EN
as their bank However after clicking on a hyperlink (mostly cloaked as a different
website) provided by the email the users were redirected to a fake website to enter
their credit card details in order to verify their account More recent phishing
techniques make use of OSM platforms in order to direct users to malicious websites
and steal sensitive information from them In a recent case on Twitter fake copies of
the Twitter accounts of real banks were created and used to reply to users that publicly
posed a question to the bankrsquos real profile directing them to a malicious website56
Because information shared on Twitter is public it can also be harvested and connected
back to their publishers revealing a chain of events deriving from a specific user This
allows phishing to be increasingly targeted and relevant towards users The use of
targeting based on very specific information is labelled ldquospear fishingrdquo For example
through Artificial Intelligence (AI) tools automated bots can be used to create tweets
aimed at and related to specific users and their tweeting history Because the
automatically generated tweet is based upon a userrsquos tweeting history the tweet will
appear relevant to the specific user Each tweet can in turn contain a malicious link
Due to the perceived relevance of the tweets and the way they are directed at specific
users the latter are more inclined to click on the link An example exposing the
possible techniques of spear phishing is SNAP_R57 a tool created by data scientists that
can automatically generate a large number of tweets based on AI
22 Third-party display network OSM platforms
OSM Platforms included Gutefragenet Vbox7com 9gag CDApl
Gyakorikerdesek Draugiemlv Suomi24 Skyrock Reddit VKcom OKru
Not all online social media platforms have their own in-house advertising platform
Certain platforms use only third-party display networks to show advertisements others
use a combination of both The majority of these advertisements appear via the
Googlersquos AdSense network Providers that work with the Googlersquos Adsense network are
Gutefragenet Vbox7com 9gag CDApl Gyakorikerdesek Draugiemlv Suomi24
Skyrock Reddit and Odnoklassniki Other third-party display networks are mainly
Ligatus for Gutefragenet Criteo for Skyrock and Odnoklassniki CTnetwork for
Gyakorikerdesek and Appnexus for Skyrock
221 Blacklist practices on misleading display advertisements
As on OSM platforms without an in-house self-service advertising platform there is no
possibility for social interaction with display advertisements except for clicking on the
advertisement or reporting it Users however cannot interact with the advertisement
through likes shares comments retweets or other actions The only possible
interaction is to click on the advertisement which will redirect the user to an external
website The possible illegal and misleading aspects of this type of advertisements may
be found in the advertised content itself or in the redirection to the external website
During the desk research a large amount of screenshots from advertisements were
captured In the section below a few examples of misleading display advertisements
from third-party advertisement networks are shown
56 httpwwwtelegraphcoukpersonal-bankingsavingsone-week-on-criminals-scam-natwest-customers-on-twitter-again 57 httpobservercom201701spear-phishing-twitter-machine-learning
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 25 EN
For the potentially misleading content we refer to items listed on the UCPD Blacklist58
Most of the current blacklist practices consist of false use of limited offers bait
advertising false prize winning and false free offers With the false use of limited offers
advertisers lure consumers to their website by communicating that the stock has
almost exhausted or the discount will only be available until a certain date During the
desk research it was not always possible to check the stockrsquos actual exhaustion
However considering the amount that users were still able to order the product did
not appear to be out of supply in a short period of time
Example on Vbox7 Display advertisement via the Google network It gives the
impression that a particular music offer is available only for the next 24 hours This
advertisement however has appeared multiple times over multiple days and the product
remained downloadable
58 httpeceuropaeujusticeconsumer-marketingunfair-tradeunfair-practicesis-it-fairblacklistindex_enhtm
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 26 EN
Bait advertising appeared mainly on smaller national OSM platforms that make use of
third-party display networks other than Googlersquos AdSense network
Example on 9gag on the advertised website (httpfrtidebuycom) the original prices
of the products were unrealistically high in order to provide reductions that appeared to
be very large
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 27 EN
The national OSM providers are also more vulnerable to misleading false prize winning
and false free offers Free bets free shipping false promises were observed multiple
times on third-party display networks
Example on Suomi24 Free shipping is advertised but the shipping is only free when
users purchase for at least $80 worth of goods
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 28 EN
Example on Gutefragenet A salary of euro12500 is promised but the advertiser cannot
assure this It is another example of ldquotoo good to be truerdquo affiliate marketing
Example on Skyrock A prize winning of $3500 is guaranteed as click-bait
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 29 EN
Another practice is to redirect customers to a website or product that does not match
with the advertised product or website This switching practice mainly appeared on
Gyakorikerdesekhu and their advertisements from the third-party advertiser
CTnetwork
Example on Gyakorikerdesek When clicking on the ad users will be redirected to a
website that resembles a news website Each link on the latter website however
redirects visitors to an affiliate website selling pills
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 30 EN
Regardless of which link users click they will always be redirected to a sales website for
a bodybuilder product
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 31 EN
23 Practices that involve personal data access
A long-standing issue when it comes to OSM platforms and more broadly any kind of
online interaction is privacy concerns When a user connects with a commercial profile
or engages with specific commercial content especially when they aim to make a
transaction it is highly likely that the trader will request personal information from
them To the extent that this information is necessary to successfully complete the
transaction (eg payment and delivery information) sharing it is an unavoidable part
of online trading The practice of data collection may however become misleading
when the userconsumer is not properly informed about what information is collected
about him and to what end this information will be used This does not necessarily
concern the illegal collection of personal data but obtaining consent from the user to
access personal data in a way that is misleading or confusing
231 Social logins
A commonly used practice for example is to offer the possibility to sign up to a
traderrsquos website or web application through a personal OSM profile These so called
ldquosocial loginsrdquo allow users to login with their personal OSM account When logging in for
the first time users have to agree with the permissions the website has set in order to
login The permissions that can be set for the user to login are applicable to ldquoreadingrdquo
and ldquowritingrdquo permissions Reading permissions allow the traders access to read
information about the user while writing permissions allow the traders to post content
on the usersrsquo wall When a user logs in via a social login it also allows the trader access
to information on that profile that is not publicly available ndash and importantly more
information than they would acquire when the user would manually fill out a contact
form on that website59 Signing up on a website through an OSM platformsrsquo login
application increases ease of use (so-called ldquoone-click registrationrdquo) which creates the
risk that users will hastily allow access to more information than they would do
spontaneously or when taking the time to properly review and consider what info is
being shared
With regards to advertising and marketing practices that are of a potential concern are
those in which data acquired in different places and by different agents is connected
with each other across databases and platforms which allows traders and advertisers
to infer more information than a consumer has willingly shared with any of those
agents For instance by combining information about the purchases of consumers in
physical stores (often stored as part of customer loyalty programs) with OSM profiles of
those consumers advertisers can effectively adjust their ads to better target these
consumers60 Some OSM platforms offer the possibility of creating ldquocustom audiencesrdquo
which enables traders to target specific users by providing the platform with their email
address However the trader will not be able to see which user is connected to which
email address61
59 httpjbonneaucomdocRB14-fb_permissionspdf 60 httpwwwkobiecomwp-contentuploadscase_studiesCase_Study_Wheres-Everybody-
Atpdf 61 Chester J (2012) Cookie Wars How New Data Profiling and Targeting Techniques Threaten Citizens and Consumers in the ldquoBig Datardquo Era In S Gutwirth R Leenes P de Hert amp IPoullet (Eds) European Data Protection In Good Health (pp 53-78) Dordrecht Netherlands Springer Retrieved from httpbooksgooglecombooks
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 32 EN
3 Mobile OSM applications
The selected Mobile OSM applications function quite differently from Desktop OSM
platforms as they are mainly focused on ldquodark socialrdquo content Dark social content is
content that cannot be seen or tracked (eg for marketing purposes) and is thus
considered private Nevertheless potentially misleading commercial practices may also
occur in private (one-to-one) conversations Because the advertisements on each
platform function differently we will discuss the potentially misleading practices for
each mobile OSM platform on a case-by-case basis
There is however one recurring misleading practice that is internet romance scams
which occurs on all selected mobile OSM applications except for SoundCloud Internet
romance scams on Mobile applications have the same fundaments as internet romance
scams on Desktop OSM platforms a fake account of an attractive single girl is created
and used to ldquocatfishrdquo people The term Catfish refers to someone who pretends to be
someone else on social media in order to create fake identities and to pursue deceptive
online romances The difference is that on OSM applications the fake account is not
used to gather as many followers or friends as possible (except for on Snapchat) but
rather for private conversations in order to lure people into paying or entering a
subscription
The individuals behind the fake accounts pretend to be someone who is seeking a
relationship and use manipulative techniques on their victims to convince them to
register for a subscription of an affiliated program or transfer money to the person
behind the fake accounts62 As indicated on Snapchat romance scams occur in a public
way as on OSM desktop platforms A fake Snapchat account of an attractive girl is
created to generate as many followers and friends as possible The Snapchat account is
then used to sell ldquoshoutoutsrdquo on black hat forums63 Shoutouts constitute snapchats
ie disappearing pictures which everyone who is connected to the userrsquos account can
see that contain commercial content or a direct link to someone elsersquos Snapchat
account To start spreading the fake account followers on Snapchat are gained through
buying ldquoshoutoutsrdquo Besides buying shoutouts it is also possible to join S4S (shout for
shout) groups Having joined that group a snapchat that links to a userrsquos account will
be posted on someonersquos snapchat The user in turn will also send a shoutout of a
picture of a snapchat that links to the other person
31 Snapchat
Snapchat is one of the newest arrivals of OSM applications and includes certain
innovating and alternative ways of sharing content with peers Publishers also have the
possibility to push their content to the users of Snapchat via the so-called ldquoDiscoveryrdquo
page which consists of commercially generated Snapchat stories We have mainly
identified native advertisements and a specific advertisement format related to the
platformrsquos ldquogeofilterrdquo product64
62 httpswwwconsumerftcgovblogfaking-it-scammers-tricks-steal-your-heart-and-money 63 httpwwwblackhatteamcomthreadsget-snapchat-generator-monetize-snapchat114986 64 httpswwwsnapchatcomlen-gbgeofilters
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 33 EN
311 Native advertising
Similar to the native advertising on desktop OSM platforms native advertising on
mobile OSM applications can be very difficult to identify For the selected mobile
applications we noticed that especially on Snapchat the use of native advertising is
quite covert This is the case in particular for sponsored filters and within the
ldquodiscoveryrdquo section of Snapchat
From left to right Snapchat video
overlay advertisement after opening a
story on Discovery no indication was
given that this was sponsored content
The video was masked very well as
being merely a regular snapchat
Native advertising as local sponsored geofilters
Sponsored geofilters which are layers with visual content that can be added to pictures
on snapchat are typically not labeled at all as being sponsored or advertisements
except for the few seconds when a user who is taking a ldquosnapchatrdquo chooses a company-
sponsored filter This person will see a ldquosponsoredrdquo tag appearing for approximately 3
seconds on their filter The receiver or viewer of the snap however is not given any
indications that a snapchat is sponsored by an external company This might not seem
a problem as most sponsored filters appear to be clearly marked with a brand and as
the online communities showed this is also an indicator of sponsored content
Nevertheless when the brand is not clearly displayed it might be very dificult to
identify the sponsored content
A potentially misleading practice associated with local sponsored geofilters is
ldquosnaphackingrdquo65 a practice that involves buying a geofilter for a specific location which
is heavily crowded (eg due to an event or a commercial activity) A trader can for
example buy a geofilter of the location of a competitorrsquos store and advertise their own
store on the competitorrsquos location Advertising a locally sponsored geofilter is available
for everyone on a self-service base
65 httpwallaroomediacomusing-snapchat-geofilters-to-sponsor-events-marketing-hack-of-the-week
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 34 EN
Example of a sponsored geofilter with the ldquoSponsoredrdquo tag showing to the person
taking a Snapchat
Native advertising on Snapchat ldquodiscoveryrdquo
Discovery is the latest add-on to snapchat on which users can view commercially-
oriented snapchats that are at the moment mainly being sponsored by well-known
brands and for which prices can increase66 Less known brands can however choose to
perform a ldquotake overrdquo or a ldquolive storyrdquo in case of a special event The only distinction
between the snapchat stories of the sponsored Discovery section and a userrsquos private
snapchats can be noticed through the buttons that are displayed when opening onersquos
Snapchat stories Private snapchat stories are in between Discovery stories and are
displayed as circles The Discover stories are displayed more prominently as large tiles
displaying the brand of the hosted discovery stories There are no other clear
indications that mark the discovery stories as sponsored except for the content that is
being displayed
When viewing the snaps of a discovery story the snaps are most likely to be filled with
sponsored content from SMEs displaying mostly products with their prices and a URL
to the website of the displayed product
66 httpwallaroomediacomsnapchat-advertising-cost
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 35 EN
Sponsored story on discovery
displaying a wide range of
sponsored products
312 Clickbait
Because the Discovery stories are managed by third-party companies Snapchat
appears to have certain issues with displayed buttons that are used in a misleading
way mainly in the form of clickbait in order to persuade users to click on their tile The
stories on Snapchat also appeared to contain explicit and sexual content without
disclosing any warning67 Following complaints regarding the explicit content being
shown without a warning Snapchat now requires the publishers of stories on Discovery
to conceal sensitive content unless it is newsworthy However a quick look on the
Discovery section still returns stories containing explicit content without a warning
Clickbait example on the Discovery
story of the DailyMail which displayed
one snap and story about a
McDonaldsrsquo burger but when
continuing started to show very
different and arguably some explicit
content
32 SoundCloud
For studying SoundCloud we adapted a slightly different research method Our
approach involved creating continuous video and audio recordings and studying these
recordings at a later point in time In between the songs played on SoundCloud
advertisements appear which were split out for the purpose of this research On
SoundCloud we could not observe any (potentially) misleading commercial practices As
the platform mainly functions via a contact form to place the audio-based
advertisements mainly larger brands advertise on SoundCloud However SoundCloud
is also build upon social proof indicators such as reposts likes shares comments
downloads and followers This makes SoundCloud prone to companies that aim to
exploit improving usersrsquo social proof factor on SoundCloud by offering services that
accomplish this improvement unethically on SoundCloud This in turn prevents the
67 httpukbusinessinsidercomsnapchat-cracks-down-on-sexual-and-misleading-stories-in-discover-2017-1r=USampIR=T
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 36 EN
users of the platform from defining which content is genuinely popular and which
content has been made to appear popular
In addition to third-party companies providing services to aid in boosting usersrsquo social
proof factor it also appears that SoundCloud itself is responsible for certain misleading
boosts of social proof indicators A blogpost created in 2014 on ukcomplexcom68
suggests that SoundCloud has aided certain artists with the acquisition of boosting fake
social proof indicators
33 Facebook Messenger
At the time of the desk research Facebook Messenger did not provide any paid
marketing services The provider was however testing the integration of
advertisements into Facebook Messenger in the form of card-style ads displayed as
large image thumbnails accompanied by text and a link or call-to-action69 Presently
advertisers do have the possibility of placing advertisements on the Messenger home
screen70 This feature was nevertheless not yet available during the desk research for
this study and is therefore not part of the current report
Facebook Messenger could however potentially be used for other problematic
practices such as spreading malicious software or acquiring sensitive information from
users by individuals with malicious intent (via one-to-one conversations) Furthermore
users might also not be aware of what happens with the data that is collected through
facebook Messenger Even though Facebook Messenger is integrated into Facebook
users who also wish to use Facebook Messenger on their mobile device are forced to
download the standalone Facebook Messenger application By installing the standalone
application Facebook (Messenger) requires several permissions (in addition to those of
the main Facebook application) to be accepted Users might however not be aware of
the amount of personal data they are handing over to Facebook while doing so as all
the information collected by Facebook via different sources can be easily pieced
together similar to what has ocurred with the data collected from WhatsApp71
A specific example of how user data collected through one application can be used in
another is geolocation Although Facebook states that they do not use information
based on geolocation to suggest new friends several forums and blogs have reported
that they did receive friendship suggestions of unknown individuals who they recognize
only from being at a location or event visited recently by the user72 One of the more
problematic stories regarding this issue concerns a man who had attended an
anonymous meeting and saw other visitors appear in-between his friendsrsquo suggestions
on Facebook
34 Viber
Viber is slightly more advanced compared to other social messaging applications As
does Facebook Messenger it enables companies to create Business specific profiles and
communicate with followers and clients In addition advertisers can craft a messaging
campaign on Viber targeting specific users worldwide by using ldquoservice messagesrdquo73
68 httpukcomplexcommusic201404soundcloud-bots-sway-numbers 69 httpstechcrunchcom20170125facebook-messenger-begins-testing-ads-and-theyre-big 70 httpswwwfacebookcombusinesshelp151265592264111 71 httpwwwbbccomnewstechnology-41761264 72 httpfusionnetstory319108facebook-phone-location-friend-suggestions 73 httpssupportvibercomcustomerportalarticles2165894-what-are-service-messages-
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 37 EN
These service messages are sent as regular Viber messages but the messages include
a banner on top indicating ldquoThis sender is approved by Viberrdquo Viber offers promoted
stickers and in-app advertised games on which users can compete with their Viber
contacts Furthermore Viber appears to have started experimenting with native
advertisements However as of today Viber did not yet officially introduce these native
advertisements
One of the special features of Viber is the use of promoting a company with sticker
packs Both paid and free sticker packs are on offer When users intent to download a
free sticker pack in most of the cases there is a small text saying that they will
automatically follow the group that is associated with the sticker pack or that they will
be redirected to the App store where a mobile game can be downloaded that is
associated with the stickers The problematic aspect here is that users may not fully
realise that by downloading a free sticker pack they implicitly agree to execute certain
actions such as 1) automatically following a certain group and therefore advertising
this group 2) visiting the App store to download an application which is not required for
using the sticker pack Users might thus not be fully aware of the implications when
simply downloading a sticker pack From the moment a user follows a group for
example the owner of the group is also able to contact that specific user
From left to right A free sticker pack provided by BBCcom which automatically makes
users follow the advertiserrsquos public account when downloading the sticker pack a free
sticker pack provided by Viber Twilight town which redirects users to the application on
the Google Play store and lastly a public group used for sharing movies
Finally Viber also features public groups the creation of which is not restricted to
companies These public groups section on Viber appears to be considerably diverse
However no misleading commercial content has been found on the examined public
Viber groups This could be due to the fact that there are apparently few active English-
speaking public groups
35 Skype
Skype is mainly used privately to communicate with contacts only This implies that
there are fewer options for social activities and public activities are not possible on
Skype
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 38 EN
Companies are able to advertise on Skype in two ways the first is by display
advertisements (limited to certain countries) and the second is through ldquomojirsquosrdquo74
Although we were not able to show display advertisements on Skype during our desk
research we did discover the ability to use (sponsored) Mojirsquos These Mojirsquos could be
described as native advertising as they blend in with non-sponsored Mojirsquos The
Sponsored Mojirsquos can be recognized solely by the presence of a copyright statement
displayed below (when choosing a Moji to send) or next to the specific Moji (when sent
to a user) There is however no other mention about the Mojirsquos being sponsored by
companies It also appears that the Mojirsquos are solely provided by partners of Microsoft
such as Universal BBC and Sony The Mojirsquos furthermore only contain fragments of
movies and series or music
From left to right a Moji by Universal and Rovio sent on Skype a Moji by BBC in-
between other Mojirsquos a music Moji by Tangerine in-between other music Mojirsquos
74 httpssupportskypecomenfaqfa34582what-are-mojis
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 39 EN
4 Conclusion
The desk research exercise confirmed that the majority of the misleading practices
encountered are based on leveraging the foundations upon which an OSM platform is
built social interactions between users With a higher number of social interactions a
page or profile becomes more valuable and consequently more vulnerable for
potential exploitations Examples include creating and maintaining fake user profiles for
advertising purposes Even small OSM platforms appear to have difficulties avoiding the
use of potentially misleading advertising
From a technical perspective marketing practices involving social proof indicators are
dependent on OSM providersrsquo in-house advertising platforms Without an in-house
advertising platform there is no possibility for social interaction with displayed
advertisements through likes shares comments retweets or other actions The only
possible interaction is to click on the advertisement which will redirect the user to an
external website or to report the content as problematic As such the responsibility
with respect to potential issues for consumers stemming from practices that involve
social proof indicators lies with OSM providers
Although falsely generated social interactions are not necessarily illegal under current
legislation we found related practices that can be considered problematic and harmful
towards OSM users Due to the ability of using short links inside user-generated
content on certain OSM platforms (in Twitterrsquos case itrsquos the only way of using links) it
becomes effortless for individuals with abusive intentions to disguise these links and
redirect users to malicious websites75 Moreover the increasing use of native
advertising on OSM platforms ndash as the platform owners aim to avoid displaying
commercial content that is too obtrusive for consumers- could render commercial
content more difficult to recognize Having native advertising combined with (covert)
paid endorsements results in OSM platforms being filled with commercial content that is
difficult for consumers to recognise
75 httpsblogcloudmarkcom20140806how-spammers-are-abusing-twitters-t-co-url-shortener
EUROPEAN COMMISSION
Directorate-General for Consumers
2018 EUR 40 EN
5 Appendix
51 Appendix 1 Desk research codebook - sample
Platform Search term Search engine Search results pageSearch option
Extra Description Links Click-through link Time visited
Facebook pinterest misleading advertising Ecosia Page 2 All Examples of misleading advertising for teachers provided by ASAhttpswwwasaorgukNews-resources~mediaFilesASAAdcheckAd20BanksMisleadingMisleading20advertisingashx15022017 1338Snapchat pinterest misleading advertising Ecosia Page 3 All Misleading product claim of Snapchat httptimecom107224misleading-products 15022017 1345
General pinterest user reports misleading advertising Ecosia Page 3 All Click fraud httpfortunecom20150825social-media-brands-ignore15022017 1437
Twitter pinterest user reports misleading advertising Ecosia Page 3 All How To Spot A Misleading Statistic Twitterrsquos Curious Political Ad Studyhttpstechcrunchcom20121016how-to-spot-a-misleading-statistic-twitters-curious-political-ad-study15022017 1446
Pinterest Pinterest bot Ecosia Page 4 All Spammers making money by posting advertisements on Pinteresthttpmashablecom20120328pinterest-amazon-spam5sOjM2vrfZqM15022017 1609
Facebook Messenger Pinterest bot Ecosia Page 5 All How to develop bots for Facebook Messengerhttpsdevelopersfacebookcomblogpost20160412bots-for-messenger15022017 1612Pinterest Pinterest blackhat Ecosia Page 4 All Spammers making money by posting advertisements on PinteresthttpwwwtomsguidecomusPinterest-pinboard-spam-Facebook-Black-Hat-Worldnews-14630html15022017 1624Pinterest Pinterest blackhat Ecosia Page 4 All Pinterest Vulnerability Exposed 70 Million Accountshttpswwwbitdefendercomsecuritypinterest-vulnerability-exposed-70-million-accountshtml15022017 1625General Pinterest buying likes Ecosia Page 1 All The Inevitable Bite of Buying Followers and Likeshttpwwwsocialmediatodaycomcontentinevitable-bite-buying-followers-and-likes15022017 1631Pinterest fake news on pinterest Ecosia Page 1 All 5 Pinterest Security Issues You Should Know Abouthttpwwwmakeuseofcomtag5-pinterest-security-issues15022017 1700Pinterest fake news on pinterest Ecosia Page 2 All Fake Pinterest Accounts Plaguing Users httplikenewmediacomsocial-mediapinterestfake-pinterest-accounts-plaguing-users15022017 1701Pinterest Pinterest bots Ecosia Page 1 All Sell and reach more on Pinterest Leverage automation to attract more clientshttpsautopinco 15022017 1515Pinterest Pinterest blackhat Ecosia Page 1 All Click-through Bot for Pinterest httpwwwbestseobotcompindemon-crack 15022017 1617Pinterest Pinterest blackhat Ecosia Page 1 All Bot for Pinterest httpwwwlearnblackhatus201611start-making-passive-income-withhtml15022017 1618General Pinterest blackhat Ecosia Page 3 All Overview site of bots for different social mediahttpwwwblackhattoolzcom 15022017 1620Pinterest Pinterest blackhat Ecosia Page 3 All Review site for Pinterest bots httpblackhatpwnagecomtagblackhat-pinterest15022017 1621General Pinterest blackhat Ecosia Page 3 All Tool for Pinterest and Tumblr httpwwwblackhattoolzcompinterest-tumblrphp15022017 1622Pinterest Pinterest buying likes Ecosia Page 1 All Websites to buy pinterest followers httpwwwbuypinfollowerscom 15022017 1628Instagram Pinterest buying likes Ecosia Page 4 All Website to buy followers on Instagram httpsquickfansandlikescom 15022017 1636YouTube Pinterest buying likes Ecosia Page 5 All Buy YouTube likes httpwwwbuyyoutubelikescom 15022017 1639Facebook Linkedin misleading advertising Ecosia Page 4 All A New Form Of Misleading Advertising Has Cropped Up On Facebookhttpwwwbusinessinsidercommisleading-advertising-on-facebook-2013-1IR=T16022017 1119Twitter Linkedin user reports misleading advertising Ecosia Page 1 All Is Twitter misleading its users on Data Protectionhttpswwwlinkedincompulsetwitter-misleading-its-users-data-protection-alexander-hanff16022017 1124YouTube Linkedin user reports misleading advertising Ecosia Page 4 All YouTube Kids App Accused Of Deceptive Excessive Advertisinghttpsconsumeristcom20150407youtube-kids-app-accused-of-deceptive-excessive-advertising16022017 1127LinkedIn LinkedIn buying followers Ecosia Page 1 All Why Buying Social Media Followers Can Hurt Youhttpswwwlinkedincompulse20140403180013-15750426-why-buying-social-media-followers-can-hurt-you16022017 1155LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpslinkedeepcom 16022017 1130LinkedIn LinkedIn bots Ecosia Page 1 All Click-through LinkedIn bot httpwwwlinkedautomatecomutm_source=my_postsamputm_medium=quora16022017 1132
Directorate-General for Consumers
2018 EUR 41 EN
HOW TO OBTAIN EU PUBLICATIONS
Free publications
bull one copy
via EU Bookshop (httpbookshopeuropaeu)
bull more than one copy or postersmaps
from the European Unionrsquos representations
(httpeceuropaeurepresent_enhtm)
from the delegations in non-EU countries
(httpeeaseuropaeudelegationsindex_enhtm)
by contacting the Europe Direct service
(httpeuropaeueuropedirectindex_enhtm) or calling 00 800 6 7 8 9 10
11 (freephone number from anywhere in the EU) ()
() The information given is free as are most calls (though some operators phone boxes or hotels may
charge you)
Priced publications
bull via EU Bookshop (httpbookshopeuropaeu)
Priced subscriptions
bull via one of the sales agents of the Publications Office of the European Union
(httppublicationseuropaeuothersagentsindex_enhtm)