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The UK Office of Fair Trading has published a consultation into what they describe as 'The OFT takes the view that some 'freemium' model buy-through games and apps aimed at children are likely to breach UK consumer laws.' The issues that have upset the OFT can be summarised as follows:
Transparency - where consumers basically don't know what they are getting into nor how much gameplay will end up costing.
Misleading consumers - where consumers are not aware of the freemium model, namely to take money from you over time.
Exploitation of children - by aggressive marketing practices.
Direct exhortations to children to buy - including persuading their parents to buy things.
Deduction of payments without the account holder's knowledge, express authorisation or informed consent.
The documents issued by the OFT contain references to the multifarious applicable laws, regulations and official guidance, ranging from the codes of the ASA, OFCOM and PPP through to consumer protection regulations. However to sweep it all up and make it into an understandable piece of self-enforceable business practice, the OFT are proposing a number of 'Principles' that require clear, accurate and prominent pricing information. The OFT do not want players getting a quarter of the way into a game only to find that they need to start buying extra functionality in order to enjoy meaningful gameplay.