Ad description

A mobile display ad for Hotspot Shield showed an image of Katy Perry and logos of YouTube, Skype, Facebook and hulu. Text stated "Hotspot Shield - Access blocked sites at school - Get It Now [link]."


A complainant challenged whether the ad was harmful and irresponsible, because it encouraged children to remove internet blocks while at school without the consent of their parents.


AnchorFree Inc t/a Hotspot Shield (Hotspot Shield) said the ad was targeted at university students and not children. They said it was never possible to guarantee that someone under 16 years of age would not see an ad, but that where they could target by age, they targeted people over 18. They said they otherwise targeted content or content categories that would be more likely to be frequented by adults. They said they never knowingly targeted children or content that was primarily consumed by them and that their aim was to upgrade users to a paid subscription, for which children would not have the credit cards or paypal accounts to pay.



The ASA acknowledged that the ultimate aim of the ad was to encourage adult recipients to upgrade to a paid subscription, an option that would not be available to children directly because it required payment by credit card. Nevertheless, we considered Katy Perry was likely to appeal to children and that Hotspot Shield had not demonstrated that they had procedures in place which would prevent the ad being sent to them. If the ad was received by children, we considered it appeared to address them at school and encouraged them to remove blocks on internet sites that they would not normally be permitted to access. Because of that, we considered the ad was harmful and irresponsible and breached the Code.

The ad breached CAP Code (Edition 12) rules  1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society.  (Responsible advertising) and  5.1 5.1 Marketing communications addressed to, targeted directly at or featuring children must contain nothing that is likely to result in their physical, mental or moral harm:  (Children).


The ad must not appear again in its current form. We told Hotspot Shield to ensure their future advertising was prepared with a sense of responsibility and contained nothing that was likely to result in physical, mental or moral harm to children.

CAP Code (Edition 12)

1.3     5.1    

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