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United Kingdom
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Key definition
Consumer definition

What does Consumer mean? A consumer is, in practice, an individual who acquires goods, services or digital content for personal use, not for the purposes of a trade, business, craft or profession. The precise meaning is statutory and context‑specific. England & Wales and Scotland: The Consumer Rights Act 2015, s2(3), defines a consumer as an individual acting for purposes wholly or mainly outside their trade, business, craft or profession (capturing mixed‑purpose purchases where the business purpose is not predominant). The Unfair Contract Terms Act 1977 instead asks whether a party “deals as consumer”, a distinct test relevant to exclusion and limitation clauses. The Sale of...

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In-app purchases: UK consumer protection, advertising, online safety and best practice (CPUTR to DMCCA transition, CCR digital content, CMA/ASA/CAP guidance)

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Practice notes
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This Practice Note discusses the key legal and commercial issues relevant to in-app purchases and Consumer protection.

It explores the context and key terms, outlines the present consumer protection regime covering in-app purchases, and also considers forthcoming changes, relevant non-binding industry guidance, and practical best practice suggestions for developers. Mobile applications now permeate daily life, mirroring the widespread adoption of smartphones, tablets and other portable computing devices. As usage has expanded, developers have increasingly sought to generate income from substantial user communities. Paying for content or functionality within apps—rather than, or alongside, paying for the app itself—has become the norm. However, developers have been criticised for not ensuring that in-app purchasing is sufficiently transparent or easy for consumers to understand and control.

This Practice Note:

  • Reviews the background and terminology from a UK consumer law perspective
  • Sets out the current UK consumer protection framework for in-app purchases and anticipated developments
  • Identifies non-binding industry guidance that may apply to in-app purchases and provides best practice tips for developers

For a general background to the app development environment...

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Sophie Stoneham
Sophie Stoneham

I enjoy helping consumer-facing brands launch and operate e-commerce platforms, marketplaces, online shops, websites and other applications. I often work on complex international projects where clients are looking to set-up, operate and comply with local laws and regulations globally. My areas of expertise include advising on regulatory compliance issues, particularly in the field of consumer law and marketing, user journeys and customer purchase journeys. I also assist clients with various types of terms and conditions, notices, subscription contracts, EULAs, commercial contracts, influencer contracts, product/service launches and advertising campaigns.I also spent six months working in the Consumer Enforcement Team at the UK’s Competition and Markets Authority. In addition to my specialism in business-to-consumer matters, I assist clients with business-to-business transactions. In particular, I have worked on franchise agreements, distribution agreements and other service contracts.I have a keen interest in video gaming, and enjoy working with...

Robert Turner
Robert Turner

As a Partner in our Commercial Group, I advise clients on complex, cross-border commercial transactions, with particular expertise advising sports and consumer brand clients.I have extensive experience advising on commercial transactions in the Sports sector, acting both for sports rights-holders and sponsors / licensees in relation to sponsorship agreements, licensing arrangements, wagering rights agreements, media rights agreements, agency agreements and hosting agreements. I have acted on many of the highest value commercial deals in the football industry, including advising on the majority of the current shirt sponsorship agreements for the Big 5 Premier League Clubs. I also advise sports clients on their licensing arrangements, both in relation to physical and digital merchandise and wagering rights agreements.My other main area of focus is advising consumer brands when they sell to, or otherwise interact with, consumers. I Co-Head our...

Web page updated on 29/05/2026

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