C099

Bumble introduced an AI Icebreaker feature which feeds users data to OpenAI which provides them with tailored opening messages. Users started to receive a pop-up as soon as they opened the app, which said: “AI breaks the ice. We use AI to help you get started with chatting. This allows you to ask questions that match the profile information of our members.” The banner clearly is designed to nudge users to click “Okay” and reappears every time users open the app. The banner resembles a consent collection banner but Bumble actually (unlawfully) relies on its legitimate interest for the processing in relation to the Icebreaker feature. Bumble also failed to fulfill the access request of the complainant.