Advertising News

An in-game ad and a paid-for social media ad for the mobile app Dialogue: AI Friend Chat Bot:

a. The in-game ad, seen in the Screw Away 3D app on 22 April 2025, featured a video of an AI-generated young female character sitting on a bed. The character spoke directly to the viewer and stated, I'm your AI girlfriend. I'm always here for you. Whether you're bored, sad, or just want to chat, I'm always around. I can be fun, supportive, modest or playful. I can be anything you need. Always by your side. Pheon, your AI friend. Subtitles mirrored the character's speech. The ad also featured on-screen messages that stated, Chat with your AI friend We can discuss anything you want [face with hand over mouth emoji].

b. The paid-for Tumblr ad, seen on 9 April 2025, featured a video of an AI-generated female character sitting on a bed, playing with her hair. The character addressed the viewer and delivered the same speech as in ad (a), with matching subtitles and on-screen messages. Issue

The ASA received two complaints.

One complainant challenged whether ad (a) portrayed someone who seemed to be under 18 years of age in a sexual way. One complainant, who believed ad (b) presented the character as a sexual object, challenged whether it was offensive and irresponsible.

Pheon Inc said the ads had been live for only a short period and would not be run again.

They had created the ads in line with their internal Ad Content Policy, which required that individuals be depicted as aged 18 or over, that bodies be fully covered, that no explicit outfits be shown, and that there be no implied sexual content. However, they acknowledged the complainants' concerns and said they had conducted a full internal review of their advertising. As a result, they had introduced stricter internal approval processes to ensure future campaigns aligned with their stated values of safety and responsibility.

ASA Assessment Complaints upheld

The CAP Code stated that marketing communications must not portray or represent anyone who was, or seemed to be, under 18 years of age in a sexual way.

The ASA considered that the character's youthful facial features and voice, slim frame, smooth skin and mannerisms were likely to lead many viewers to interpret her as being under 18 years of age. We further considered that her brightly coloured, pyjama-style outfit contributed to her childlike presentation in the ad.

We acknowledged that the ad was not explicit. However, the bedroom setting, the character in her pyjamas and her behaviour in tilting her head to the side, leaning forward and addressing the viewer directly gave it a sexually suggestive tone. In that context, we considered the references to being your AI girlfriend, playful and anything you need to imply that she was proposing a flirtatious or romantic relationship. We further considered the text We can discuss anything you want in combination with a face over mouth emoji hinted at sexual content.

Because the ad depicted a person who appeared to be under the age of 18 in a sexual way, we concluded that it was irresponsible and breached the Code.

Ad (a) breached CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.8 (Harm and offence).

Ad (b) featured a character kneeling on the bed with her legs wide apart as she leant forward to address the viewer directly. She was wearing a low-cut vest top and brief-style shorts. She was shown running her hands through her hair and inclining her head in a coquettish manner as she spoke. Although the ad was not explicit, we nevertheless considered that those features made it sexually suggestive in tone.

The character described herself as your AI girlfriend and always here for you. She also said she could be anything you need. The text We can discuss anything you want in combination with a face over mouth emoji hinted at sexual content. We considered that the character was presented as being available to fulfil the viewer's emotional or sexual needs on demand.

We considered that, in combination, those visual and spoken elements reduced the character to a sexual object for the viewer's gratification. Because the ad included harmful gender stereotypes and was likely to cause serious offence, we therefore concluded that the ad was irresponsible and breached the Code.

Ad (b) breached CAP Code (Edition 12) rules 1.3 (Social responsibility), 4.1 and 4.9 (Harm and offence). Action

The ads must not appear again in the form complained of. We told Pheon Inc to ensure that future ads did not portray anyone who seemed to be under 18 years of age in a sexual manner. We also told them to ensure their ads were socially responsible and did not cause serious or widespread offence by harmfully stereotyping women as sexual objects.

A cinema ad for the vegan charity Viva!, seen in March and April 2025, featured a woman placing her sleeping baby in a cot while a lullaby played. After switching off a lamp, she turned around to see the baby in the cot. A silhouetted figure suddenly appeared standing over the cot and the room went dark. The woman switched on a light to reveal a man in a suit running a bottle of milk across the bars of the cot, which was now empty. The woman gasped and asked, What have you done with my baby? The man smiled, revealing misshapen, discoloured teeth, and replied in a low, gravelly voice, You cant keep your baby because we want your milk. The womans scream was cut off and the screen went black. The next scene showed a calf in a pen. The voiceover stated, Almost every dairy calf is taken from their mother shortly after birth so most of her milk can be sold to us. And what do you think happens to thousands of male babies like this one? The words Dairy is Scary and the Viva! logo appeared on a black screen accompanied by a loud, metallic noise and the sound of something falling to the floor.

The ASA received 25 complaints, including one from The Dairy Council of Northern Ireland. The complainants challenged whether the ad was irresponsible, distressing, especially to those that had lost a child, and likely to cause serious or widespread offence.

Viva! said they aimed to raise awareness of standard practices in the dairy industry, particularly the removal of calves from their mothers shortly after birth. The ad was based on factual information and was intended to inform and encourage ethical choices, not to shock. They cited a survey which found that 59% of respondents did not know that cows must give birth in order to produce milk.

Viva! said the ad used metaphor and cinematic techniques, rather than graphic imagery, to draw a symbolic comparison between human and animal separation. The character of the bogeyman was a dramatic device used to prompt empathy. They said it was not intended to trivialise human grief or cause distress to those who had experienced child loss.

ASA Assessment:  Complaints upheld

The CAP Code stated that marketing communications must be prepared with a sense of responsibility to consumers, and must not cause serious or widespread offence, fear or distress without justifiable reason. The fear or distress should not be excessive, and marketers must not use a shocking claim or image merely to attract attention.

The ad, which drew on conventions of horror films, was classified as suitable for audiences aged 15+ and appeared in cinemas. The ASA acknowledged that it was surreal and stylised in tone and did not feature graphic imagery. We understood that the approach was intended to encourage viewers to draw a direct emotional parallel between the separation of calves from their mothers and the imagined loss of a human baby. We considered, however, that while viewers would understand that the ad aimed to raise awareness of animal welfare, the nature of that comparison was likely to be seen as insensitive by many and in particular by those with experience of loss or trauma around parenthood.

The domestic scene of a mother putting her baby to bed abruptly changed with the arrival of a menacing bogeyman figure standing over the babys cot, and the babys subsequent disappearance. We considered that the bogeyman character created a strong sense of unease and threat. Although the ad did not depict the baby being harmed, and it was not shown being physically removed, we considered that its disappearance was likely to be seen as shocking and unsettling. We further considered that the statement You cant keep your baby, in combination with the sudden disappearance of the baby, was likely to be particularly upsetting for viewers with experience of child loss or fertility issues, in particular because the parallel with dairy industry practices was revealed only in the latter half of the ad. We considered that the late reveal, in combination with the unsettling imagery, was likely to increase the emotional impact and amplify distress. We considered that the message of the ad did not justify the distress likely to be caused by the approach, in particular to vulnerable audiences.

For those reasons, we concluded that the ad was irresponsible and likely to cause unjustified distress and serious and widespread offence.

The ad must not appear again in the form complained about.