Ad description

Two in-game ads for a chat and dating service, for the mobile app ToChat, seen in April 2023 on two apps:

a. The first ad, seen in the Goodville: Farm Game Adventure app, featured images which included a woman in a short, strappy dress pouting at the camera over text which stated “We using [sic] ToChat … Match hot girls firstly [sic] if u DL now”. Another image showed a woman wearing a revealing mesh top also pouting at the camera above text which stated “Date with.” Another image showed a blurred photograph of a woman in a bikini, which had been cropped to show only her torso from her neck to her hips, above text which stated “I just want friends with benefits”.

b. The second ad, seen in the Block Blast app, was identical to ad (a).


The complainant, who believed the sexual content of the ads was inappropriate for children to see, challenged whether they had been responsibly targeted.


Action First Holding Ltd t/a ToChat said the ads were distributed through an ad network which did not allow them to target specific age groups or to filter media. They believed, however, that the game apps’ publishers (Goodville and Hungry Studio) were able to target ads, and that the appearance of the ads in games that were not age-restricted resulted from their failure to do so. ToChat said their app was intended for users aged 17 years and older and that there was no good reason why they would want to target under-18s. They said the ads were categorised as “dating,” which should have alerted the ad network that they were intended for adults.

Goodville and Hungry Studio did not respond to the ASA’s enquiries.



The ads appeared in game apps which had age ratings of 12+ or “Everyone”. The ASA considered the game apps were therefore aimed at a broad audience which would include under-18s. The images they contained were therefore likely to be seen by both children and adults.

We considered the ToChat ads were not explicit, but were nevertheless sexually suggestive, in that they showed women wearing revealing clothing and posing provocatively, accompanied by suggestive language in the text, such as “Match hot girls” and “I just want friends with benefits”. For example, one image showed a woman wearing a mesh top which revealed some of her cleavage. Another image showed a woman who appeared to be about to lift up her top to expose her breast.

The advertised ToChat app had an age rating of 17+years. We considered, therefore, that any ad for the app should have been targeted responsibly, including limiting the audience to users aged 17 years and over. That should have been achieved using age verification measures which included interest-based targeting factors that described an adult audience and excluded a child audience. However, the Goodville: Farm Game Adventure and Block Blast game apps had age ratings of 12+ in the Apple App Store and “Everyone” in the Google Play App Store and were therefore likely to be played by children as well as adults.

We considered that consumers playing unrelated games would not expect to be served ads for an app which contained content which had an age rating of 17+ years. Because ToChat had not provided us with evidence that they had taken appropriate action to minimise the risk of under-17s being served the ads, we concluded that the ads had been irresponsibly targeted.

The ads breached CAP Code (Edition 12) rule 1.3 (Responsible advertising).


The ads must not appear again in the form complained of. We told First Action Holdings Ltd t/a ToChat that in future they must ensure their ads are responsibly targeted.

CAP Code (Edition 12)


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