Dating apps are a world of their own. They have become a very popular way of meeting new people; so much so, that dating apps have developed their own “niches”. Online Classifieds AG t/a PURE ("Pure"), who could be a considered to be in the extravagant niche, caught the eye of the Advertising Standards Authority ("ASA"), which led to a decision that serves as a useful lesson to creatives looking to maintain their edginess whilst respecting the limits of regulatory acceptability.

The ad

The ads in questions were two poster ads promoting the Pure dating up, seen in March 2024.

The first one is below…

… whereas the second one depicted a cartoon head of a princess with text that stated “DON’T PLAY WITH MY EMOTION, PLAY WITH MY” and then a cartoon image of a clamshell.

The ASA launched an investigation following complaints that challenged whether the ads were 1) offensive and, 2) inappropriate for display in an untargeted medium where they could be seen by children given that the ads were displayed near two schools. 

Pure exaggeration

Pure denied wrongdoing, calling the complainants' interpretations “exaggerated and unfounded”. They considered the ads to be “playful, yet ambiguous”, which left consumers free to interpret them. There was no explicit content or use of direct references.

Shifting the blame onto the billboard owners, BUILDHOLLYWOOD, Pure said that they were the ones who chose the poster locations. Pure claimed that it was not their idea for the ad to be displayed in areas “frequented by children”, nor would they have approved of locating the posters near schools, had they been made aware. 

BUILDHOLLYWOOD also denied any wrongdoing. However, they acknowledged how placing these ads near schools might not be acceptable, vouching to improve their internal processes. 

Not always a good day to get some head

The ASA clarified its position in relation to the placement of sexual imagery in outdoor advertising near schools following the publication of the Department for Education's report, 'Letting Children be Children', in 2011. The report set out various concerns about the sexualisation and commercialisation of children and childhood.  The ASA tightened its policies as a result, prohibiting imagery that can be considered ‘overtly/explicitly sexual’ in outdoor, untargeted, media, such as billboard ads; and requiring that imagery in posters that is ‘sexually suggestive’ should have a placement restriction, so that they do not appear within 100 metres of a school.

In this case, the ASA upheld both challenges, ruling the ads to be in breach of CAP Code rules 1.3 (Responsible advertising) and 4.1 (Harm and offence). The ASA considered the references in both ads to be overtly sexual because they suggested that oral sex could be sourced on the Pure app. The implication is that even if these posters had been more than 100 metres from the nearest school, they still would not have been appropriate for billboard advertising because they were overtly or explicitly sexual. 

The ASA also noted, however, that the ads were displayed on poster sites across London in an untargeted medium, including less than 100 metres from the nearest school. As older children were likely to have greater awareness of the sexual references, the regulator considered them irresponsible and likely to cause widespread offence. 


What isn't open for debate is Pure's responsibility for what may have been a hiccup on the part of the third party media owner. Brands must therefore remember that they remain responsible for actions taken by third parties on their behalf. 

Whether the ads were “overtly sexual” is more subjective. In fact, the Pure's ad to the left of the ad in question (in the image above) appears to be just as overtly sexual, or even more so. Regardless of the contents, placing posters for dating apps less 100 metres from a school may not have been a wise move, and highly likely to provoke complaints. The cynics among you may speculate as to whether this was the plan all along, in order to draw attention to an otherwise unknown dating app. If so, it worked, as this ad drew 23 complaints and the adjudication as gained considerable media coverage. 

Nevertheless, advertisers must remember that to take account of the placement of ads and, even if an ad is only sexually suggestive rather than overtly sexual, they must hold sufficient substantiation to prove that the ads will not be seen by a significant number of under 18s, probably in the form of written instructions to their media buyer and/or the media owner to avoid sites less than 100 metres from the nearest school.