Today, BEUC and 15 national consumer associations have filed coordinated complaints against Tik Tok, a platform popular with older children and teenagers. The complaint joins items related to purported violations of the Unfair Terms Directive, the Unfair Commercial Practices Directive and the GDPR.
Part of Tik Tok's business model is relatively specific - namely, the platform sells token that can be used to "give presents" to other users as a reward for the performances shown in their videos. BEUC complains that several of the terms regulating these tokens are in fact non-transparent and substantively unfair. The complaint seems to connect nicely to the recent European Parliament report by our very own Joasia Luzak and colleague Marco Loos calling for closer scrutiny of terms of service for online providers.
The platform's young target audience is an important driver behind some of the concerns: hidden advertisement and harmful content are a particularly sensitive issue when minors are involved. Other complaints, such as Tik Tok's nonchalant approach to control over user generated content (see earlier news of users finding themselves included in ads without any previous knowledge or consent from their side) seem to reflect more general concerns with privacy and user control/copyright.
The choice to build up such a large coordinated complaint may be an attempt to circumvent earlier identified problems with enforcing the GDPR against Tik Tok - namely, the lack of clarity as to which authority would be competent under the Regulation's "one-stop-shop" rule. This problem was only partially addressed when the company decided to establish its data processing activities in Ireland, which is also the European data hub for many other tech companies.
