In-app purchases and consumer protection
Produced in partnership with Hunton Andrews Kurth
In-app purchases and consumer protection

The following TMT practice note produced in partnership with Hunton Andrews Kurth provides comprehensive and up to date legal information covering:

  • In-app purchases and consumer protection
  • Definitions
  • Regulatory framework
  • Background
  • The Consumer Protection from Unfair Trading Regulations 2008
  • The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013
  • Advertising law
  • The Geo-blocking Regulation
  • Best practice
  • The CMA’s principles for online and app-based games

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for TMT?

Mobile applications (apps) have become as ubiquitous as the smartphones, tablets and other mobile computing devices that support them. With the growth in the popularity of apps, developers have increasingly sought ways to earn revenue from the often large user bases that their apps support. In-app purchases, where developers charge users for content within apps, rather than (or in addition to) the app itself, have become common. Developers have however been criticised for failing to ensure that their in-app purchase mechanisms are transparent and consumer friendly. There have been several high profile cases in which consumers have been charged, in some cases several thousands of pounds, for in-app purchases they claimed were unauthorised.

In September 2014, Google entered into a settlement agreement with the US Federal Trade Commission (FTC) to refund at least $19m to parents for unauthorised charges incurred by their

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