Snapchat Blocked by German Court Over AI Chatbot Data and Minor Targeting
The Regional Court of Cologne has barred Snap Group Limited from processing personal data collected through its “My AI” chatbot for advertising without a legal basis. The full judgment also prohibits the platform from using pre-checked boxes for ad consents and preselecting alcohol and gambling themes in minor accounts, finding violations of the General Data Protection Regulation and youth media protection laws.
Launched in spring 2023, the “My AI” feature appears as a standard contact in the Snapchat app for users starting at age 13. When opened for the first time, the chatbot presents a brief notice stating that user inputs may improve products and personalize advertising, requiring only an “Okay” button to proceed. The Federation of German Consumer Organisations tested the system by posing as a 14-year-old girl asking for cocktail recommendations, receiving suggestions for mojitos, margaritas, and piña coladas.
Cologne Court Rules My AI Violates GDPR Data Protections
The 33rd Civil Chamber of the Regional Court of Cologne ruled that “My AI” is inherently designed to process sensitive categories of personal data under Article 9 of the GDPR, such as health details, religious beliefs, and sexual orientation. Snap argued that it does not intentionally query sensitive information, but the court held that the absence of intent does not exempt a company from strict statutory bans when users disclose private struggles or concerns to an AI companion.
The court also invalidated the single “Okay” button as a valid legal basis for data processing or advertising consent. Pre-checked boxes found in the app’s ad preferences—including activity tracking outside the app and data sharing with third-party networks—failed to meet active consent standards established by European and German jurisprudence.
Restrictions on Minor Accounts and Advertising
Beyond chatbot data handling, the court scrutinized account settings for young users. In the lifestyle and interest categories of minor accounts, topics including alcohol and gambling were enabled by default. The court determined this practice violates Section 6 of the Interstate Treaty on the Protection of Minors and Section 5 of the Interstate Treaty on Gambling 2021.
Snap maintained that internal guidelines already block age-restricted ads from reaching minors, but the judges ruled that designing the app with these options enabled leaves open the risk of exposure.
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