BBB National Programs’ Digital Advertising Accountability Program closed a review of Fast Retailing on October 20. The case is DAAP Case #149-2026. Fast Retailing owns UNIQLO, GU, Theory, and Helmut Lang. DAAP looked at the websites of all four and the mobile apps of UNIQLO, GU, and Theory. Helmut Lang does not have an app. The brands had third-party companies collecting data for interest-based advertising. They did not have the enhanced notice and opt-out the Digital Advertising Alliance’s Self-Regulatory Principles require. After the inquiry, Fast Retailing added separate Ad Choices links, dedicated IBA sections in the privacy policies, and in-app settings that reach the same choice tools.
What changed on the sites
UNIQLO, GU, Theory, and Helmut Lang each added an “Ad Choices” link in the website footer. The link is separate from the general privacy policy link and appears on every page. It goes to an “Ad Choices” section inside the privacy policy. That section explains interest-based advertising, states that the brand adheres to the DAA Principles, links to an industry consumer-choice mechanism, and tells the reader how to withdraw consent. DAAP also asked UNIQLO and GU to put a jump link at the top of their privacy policies that points to the new section. Both did.
The distinction matters for a retailer. A privacy policy that mentions advertising somewhere in the middle satisfies a lawyer reading the whole document. It does not satisfy the DAA enhanced-notice rule, which wants a link a shopper can see without hunting. The footer Ad Choices link is that link. The dedicated section is the page it has to land on.
What changed in the apps
UNIQLO and GU removed the infinite scroll that buried the menu and footer. They added “Ad Choices” to in-app settings so a user who already downloaded the app can still reach the disclosure and the opt-out. They put a link to the IBA disclosure and the DAA choice tools at the top of the mobile privacy policies. They updated the iOS and Android store listings so the privacy-policy link opens at the top of the notice, where the IBA language now sits. Theory made the same three changes that applied to it: no infinite scroll, Ad Choices in settings, and a DAA tools link in the mobile policy. Helmut Lang had no app to fix.
Mobile Guidance treats the app as its own surface. A website footer that is correct does not cover the app. Settings that a user can open after install are the ongoing notice. Store listings are the notice that exists before download. Infinite scroll that never reaches a footer is the practical failure DAAP flagged.
What the decision does and does not do
This is a self-regulatory resolution, not a fine and not a court order. DAAP monitors, writes up what it sees, and works with the company until the sites and apps match the DAA Principles. Fast Retailing made the changes. The decision summary is in the BBB National Programs case library. No monetary penalty is mentioned. No admission beyond the work done with DAAP is in the release.
For a multi-brand retailer the practical takeaway is the one DAAP already applies brand by brand. Each site needs its own Ad Choices footer link on every page. Each app needs the disclosure reachable from settings, not only from a scroll that may never end. The privacy policy can hold the full explanation, but the link has to be labeled Ad Choices, kept separate from the general privacy link, and pointed at a section that actually describes IBA and the opt-out. Scattering the same sentences through a long policy is what the review treated as non-compliant.
State privacy laws still sit on top of this. CCPA, the other state statutes, and GDPR have their own notice and opt-out rules. The DAA Principles are the advertising-industry baseline DAAP enforces. A brand that has cleaned up the Ad Choices link has fixed the self-regulatory item. It has not automatically fixed a state-law “Do Not Sell or Share” link or a GDPR consent banner. Those are separate controls. The October 20 decision shows what the advertising watchdog checks first on a retail site and app: a visible Ad Choices path, a dedicated IBA section, and an app that does not hide the same path behind infinite scroll.
