Ad description
A paid-for TikTok video by Buzzy USA, seen on 24 June 2022, featured a woman dancing with superimposed text that stated, "Celebrating the fact that I'm no [red cross emoji] longer broke [dollar sign eyes emoji]. This summer is gonna be soooo LIT [fire emoji] thanks to my credit card [heart eyes emoji].” Further superimposed text towards the end of the video stated, “Swipe left!”. In the bottom left-hand corner of the video there was an animated image of a generic credit card. A caption accompanying the video stated, “Online credit card application!”.
Issue
The complainant challenged whether the ad was irresponsible because it took advantage of consumers’ inexperience or credulity.
Response
Buzzy USA Inc did not respond to the ASA’s enquiries.
TikTok said the ad violated their Ad Policies and was shown in error. They confirmed the ad had been removed from the platform and was no longer being shown.
Assessment
The ASA was concerned by Buzzy USA Inc’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 1.7 Any unreasonable delay in responding to the ASA's enquiries will normally be considered a breach of the Code. (Unreasonable delay). We reminded them of their responsibility to provide a response to our enquiries and told them to do so in the future.
Upheld
The ad featured a young woman dancing with text claiming that she was “no longer broke” and was looking forward to an enjoyable summer thanks to her credit card. The ad used terms associated with youth culture such as “LIT”, and made prominent use of emojis. The ASA considered it was therefore particularly targeted at young adult users of TikTok.
The ad featured an animated image of a generic credit card and we considered that, when viewed alongside the reference to a credit card in the superimposed text, and the caption at the bottom of the ad that stated, “Online credit card application!”, consumers would understand the ad was making claims about credit generally. Additionally, the ad stated, “This summer is gonna be soooo LIT [fire emoji] thanks to my credit card [heart eyes emoji]”, which we considered implied the individual shown intended to use a credit card to finance her spending that summer. We considered consumers would understand the contents of the superimposed text in the ad, and its tone, as referring to spending on non-essential goods and services.
Payments made using a credit card were added to an ongoing balance that the cardholder owed to the card issuer, and typically attracted interest, sometimes at a high level, if not paid off within a fixed period of time. We considered the ad’s messaging, which was particularly targeted at young adults and made reference to financial difficulty, implied that consumers who were in financial difficulty could use a credit card to facilitate spending on non-essential goods and services. We also considered the ad’s use of the term “LIT” and emojis had the effect of trivialising the use of credit cards.
We therefore considered the ad irresponsibly encouraged, and trivialised, using a form of credit for spending on non-essential goods and services by those who were in financial difficulty, and was in breach of 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. (Social responsibility).
Action
The ad must not appear again in the form complained of. We told Buzzy USA Inc to ensure that their future marketing communications did not encourage, or trivialise, the use of credit by those who were in financial difficulty to facilitate spending on non-essential items. We referred the matter to CAP’s Compliance team.
