BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords...

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Directorate-General for Consumers 2018 EUR 1 EN BEHAVIOURAL STUDY ON ADVERTISING AND MARKETING PRACTICES IN ONLINE SOCIAL MEDIA Annex 1.3.1 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

Transcript of BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords...

Page 1: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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

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

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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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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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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

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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

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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

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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

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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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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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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

EUROPEAN COMMISSION

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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

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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)

Page 2: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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

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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)

Page 3: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 4: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 5: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 6: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 7: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 8: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 9: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 10: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 11: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 12: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 13: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 14: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 15: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 16: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 17: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 18: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 19: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 20: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 21: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 22: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 23: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 24: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 25: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 26: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 27: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 28: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 29: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 30: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 31: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 32: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 33: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 34: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

Page 35: BEHAVIOURAL STUDY ON - European Commission · 2018. 9. 5. · The logbook also lists the keywords used and a quantification of the findings of the ... Xing and Draugiem. Marketing

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)

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