During the 2025 Christmas season, fast-food giant Jollibee launched a digital campaign titled “Buo ang Saya ng Pasko” on the popular messaging app Viber. The campaign, intended to spread festive cheer, utilized an innovative (and controversial) method: automated branded greetings and digital stickers that appeared within personal and group chat interfaces when users typed certain keywords like “Christmas.”

These visual elements, prominently featuring the Jollibee logo and holiday messages, would briefly pop up in private conversations. While the intent was clear—to amplify brand presence and festive spirit—the delivery method ignited significant controversy online. Many users found the unexpected insertion of brand content into their private digital spaces to be intrusive, sparking a widespread debate about digital marketing ethics and user privacy.

National Privacy Commission Investigation and Public Reaction

The strong public backlash against Jollibee's Viber campaign quickly caught the attention of the National Privacy Commission (NPC) in the Philippines. Responding to a deluge of user complaints and media reports, the NPC initiated a formal inquiry, demanding explanations from both Jollibee and Viber. The core of their investigation focuses on whether the campaign involved the unsolicited processing of personal data, such as keywords from user messages, to deliver targeted content without a valid legal basis or explicit user consent, as mandated by the Data Privacy Act of 2012 (DPA).

The NPC underscored that any processing of personal data for direct marketing purposes must adhere strictly to the principles of transparency, legitimate purpose, and proportionality. Crucially, if personal data were indeed utilized, consent must be specific, freely given, and easily revocable, with users fully informed of their right to object to such practices. This scrutiny highlights a critical juncture for digital marketers navigating the complexities of data privacy regulations.The campaign sparked a nationwide discussion among netizens and privacy advocates.

Many users labeled the ads "intrusive," not necessarily due to the content itself, but because of its uninvited appearance in private chat environments. Critics voiced concerns that such marketing tactics could erode trust in messaging platforms, arguing that while platforms permit advertising via established policies (e.g., device identifiers, aggregate data), users do not anticipate brand content being interwoven into personal conversations without clear opt-in consent. This incident occurs amidst a heightened regulatory focus on digital privacy within the Philippines, signaling a growing demand for ethical marketing practices that respect user boundaries. Is it time for a more stringent policy covering digital platforms?