1. What measures does the Act take for the protection of minors?
Providers of online platforms that are accessible to minors are required to take measures to ensure a high level of privacy, safety, and security for minors, on their services. Additionally, targeted advertising to minors using their personal data is prohibited.
Important note:
Platforms are considered accessible to minors if they allow minors to use their services.
2. What measures does the Act provide for advertisements on platforms/online services?
The Digital Services Act (DSA) prohibits personalised advertising (based on a user’s profile) on digital services which:
- is addressed to minors (Article 28),
- uses special categories of personal data (Article 26), such as sexual orientation or religious beliefs.
It also strengthens the ability of users to understand and make decisions about advertisements (Article 26). In this context, users must be clearly informed if and why they are being targeted by advertising, who has paid for it, and if the content is sponsored.
In the case of very large online platforms/search engines (VLOPs/VLOSEs), additional special measures are provided (Article 39) to mitigate risks and facilitate oversight.
3. What does the Act provide for dark patterns / misleading presentation of a digital service?
The Digital Services Act (Article 25) prohibits the use of so-called “dark patterns”. This refers to a method of designing platforms that providers use to manipulate and guide users into making choices they would not otherwise make. For example, they may encourage users to share more information than they would otherwise provide, or they might advertise a cheaper but unavailable product and then direct users toward more expensive, similar products.
4. In what cases should I contact EETT? What actions does it take?
If the problem you are facing is related to any of the following issues, you can lodge a complaint with EETT by completing the More information.
- Restrictions on communication with the provider of the intermediary digital service.
- Restrictions on the ability to report illegal content.
- Insufficient justification from the provider for blocking your account due to content you posted or for the deletion of the content itself.
- Restrictions on the ability to lodge a complaint with the provider.
- Difficulty in locating or finding the terms of use.
- Restrictions on providing information about the possibility of out-of-court dispute settlement or no cooperation during resolution process.
- Violations of obligations of intermediary digital service providers regarding the protection of minors.
- Misleading presentation of services.
- Violations of obligations regarding the way personalised recommendations for content and product purchases are configured.
- Violations of obligations regarding the way advertisements are displayed and targeted.
You are advised to consult EETT’s responsibilities (see General Information, Q. 3 and General Information, Q. 4).
Important notes:
EETT:
- assesses whether providers comply with the obligations set out in the Digital Services Act to address illegal content, e.g., whether they provide users easy-to-use tools that allow the reporting of illegal content
- neither determines the legality of content nor is responsible for removing illegal information/services/products,
- is not authorized to resolve disputes regarding decisions taken by providers to impose restrictions on users,
- exclusively oversees and enforces the obligations established by the Act and is not responsible for enforcing other legislation that regulates intermediary digital services (e.g., legislation on e-commerce, consumer protection and product safety, personal data protection, or copyright and related rights),
- does not review complaints that are anonymous, vague, manifestly unfounded, or submitted abusively.
The complaint shall contain all necessary information to support the alleged violation of the Digital Services Act, and include information about any prior written communication with the provider.
After submitting the form, you will receive confirmation of receipt. EETT will then assess the complaint. If it is determined that the issue concerns a violation of the Digital Services Act, EETT will determine whether the complaint should be handled by itself or forwarded to another body, as appropriate:
- The National Council for Radio and Television (NCRTV), regarding the display of advertisements on online platforms (Article 26) and the adoption of measures for the protection of minors (Article 28).
- The Hellenic Data Protection Authority (HDPA), regarding the information provided to users on how advertisements are displayed and targeted (Article 26), as well as the protection of minors’ personal data (Article 28).
- The Digital Services Coordinator of the provider’s country of establishment, when its main establishment is not in Greece.
- The European Commission, transmitted by the Digital Services Coordinator of the provider’s Member State of establishment, if the issue concerns specific obligations of very large online platforms (VLOPs) / search engines (VLOSEs).
In the event that your complaint is forwarded to another body or does not concern a violation of the Digital Services Act, you will be duly informed.
Further details are available in Article 53 of the Act.