Privacy Watchdog Ensures Fast Retailing Brands Adhere to Digital Advertising Privacy Best Practices
McLean, VA – October 20, 2026 – BBB National Programs’ Digital Advertising Accountability Program (DAAP) has worked with Fast Retailing Co., Ltd. and four of its brands to bring their websites and mobile applications into compliance with the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for online interest-based advertising (IBA).
Fast Retailing Co., Ltd. is a global apparel retailer that operates UNIQLO, G.U. CO. LTD. (GU), Theory, and Helmut Lang.
As part of its routine monitoring, DAAP reviewed the online properties of UNIQLO and GU and observed data collection by third-party companies known to engage in IBA. DAAP identified potential issues concerning whether the websites and mobile applications provided consumers with the transparency and choice mechanisms required by the DAA Principles.
DAAP subsequently expanded its review to the websites of Fast Retailing’s Theory and Helmut Lang brands, and the mobile applications operated by UNIQLO, GU, and Theory.
The review found that the UNIQLO, GU, Theory, and Helmut Lang websites did not provide consumers with appropriate enhanced notice for IBA, that is, a clear and prominent link to information explaining data sharing for IBA and a mechanism to opt-out of such sharing. While privacy policies contained much of the information required under the DAA Principles, the information was scattered throughout the policies rather than presented in a clearly identified IBA disclosure. As a result, consumers may have had difficulty finding information about IBA and mechanisms available to exercise choice with respect to IBA.
DAAP also found that the UNIQLO, GU, and Theory mobile applications did not provide appropriate enhanced notice under the DAA’s Mobile Guidance. The apps did not provide clear and prominent access to IBA disclosures and choice mechanisms at the times and places contemplated by the Mobile Guidance, including through app settings. The apps’ use of an infinite scroll format also prevented users from readily reaching disclosures and opt-out links to privacy information located at the bottom of the screen.
In response to DAAP’s inquiry, Fast Retailing worked with DAAP to review the websites and mobile applications of all four brands and implemented a range of changes to strengthen transparency and consumer choice.
The updated “Ad Choices” sections explain IBA, include a statement of adherence to the DAA Principles, provide a functioning link to an industry-developed consumer choice mechanism, and explain how consumers can withdraw consent.
At DAAP’s recommendation, UNIQLO and GU also added a link at the top of their privacy policies directing consumers to the “Ad Choices” section.
Theory eliminated the infinite scroll feature from its app, added “Ad Choices” to its in-app settings, and added a link to the DAA’s consumer choice tools in its mobile privacy policy. Helmut Lang does not offer a mobile application.
All BBB National Programs case decision summaries can be found in the case decision library. To access all DAAP decisions, visit the DAAP decisions webpage.
Fast Retailing Co., Ltd. is a global apparel retailer that operates UNIQLO, G.U. CO. LTD. (GU), Theory, and Helmut Lang.
As part of its routine monitoring, DAAP reviewed the online properties of UNIQLO and GU and observed data collection by third-party companies known to engage in IBA. DAAP identified potential issues concerning whether the websites and mobile applications provided consumers with the transparency and choice mechanisms required by the DAA Principles.
DAAP subsequently expanded its review to the websites of Fast Retailing’s Theory and Helmut Lang brands, and the mobile applications operated by UNIQLO, GU, and Theory.
The review found that the UNIQLO, GU, Theory, and Helmut Lang websites did not provide consumers with appropriate enhanced notice for IBA, that is, a clear and prominent link to information explaining data sharing for IBA and a mechanism to opt-out of such sharing. While privacy policies contained much of the information required under the DAA Principles, the information was scattered throughout the policies rather than presented in a clearly identified IBA disclosure. As a result, consumers may have had difficulty finding information about IBA and mechanisms available to exercise choice with respect to IBA.
DAAP also found that the UNIQLO, GU, and Theory mobile applications did not provide appropriate enhanced notice under the DAA’s Mobile Guidance. The apps did not provide clear and prominent access to IBA disclosures and choice mechanisms at the times and places contemplated by the Mobile Guidance, including through app settings. The apps’ use of an infinite scroll format also prevented users from readily reaching disclosures and opt-out links to privacy information located at the bottom of the screen.
In response to DAAP’s inquiry, Fast Retailing worked with DAAP to review the websites and mobile applications of all four brands and implemented a range of changes to strengthen transparency and consumer choice.
Enhanced Notice of Website Data Collection for IBA
To comply with the DAA Principles’ enhanced notice requirements, UNIQLO, GU, Theory, and Helmut Lang:- Added an “Ad Choices” link to their website footers that is separate and distinct from each brand’s general privacy policy link and appears on every page of the website.
- Directed the “Ad Choices” link to the IBA section of each brand’s privacy policy to provide consumers with direct access to information about IBA and available choice mechanisms.
- Consolidated IBA-related information into a dedicated “Ad Choices” section of each brand’s privacy policy.
The updated “Ad Choices” sections explain IBA, include a statement of adherence to the DAA Principles, provide a functioning link to an industry-developed consumer choice mechanism, and explain how consumers can withdraw consent.
At DAAP’s recommendation, UNIQLO and GU also added a link at the top of their privacy policies directing consumers to the “Ad Choices” section.
Enhanced Notice for Third-Party Interest-Based Advertising
To comply with the DAA Mobile Guidance, UNIQLO and GU implemented changes to provide consumers with clearer and more prominent notice of cross-app data collection for IBA, including:- Adding a link to an IBA disclosure and DAA consumer choice tools at the top of their mobile privacy policies.
- Eliminating the infinite scroll feature that had prevented users from readily reaching menu and footer links, including links to privacy information.
- Adding “Ad Choices” to their in-app settings, giving users ongoing access to IBA disclosures and choice mechanisms after downloading the apps.
- Adding links within their IBA disclosures to the DAA’s consumer choice tools, including Ad Choices.
- Updating their iOS and Android app store listings with privacy policy links directing users to the top of their Privacy Notices, where consumers can more easily access the IBA disclosures.
Theory eliminated the infinite scroll feature from its app, added “Ad Choices” to its in-app settings, and added a link to the DAA’s consumer choice tools in its mobile privacy policy. Helmut Lang does not offer a mobile application.
All BBB National Programs case decision summaries can be found in the case decision library. To access all DAAP decisions, visit the DAAP decisions webpage.