Aren't advertising requirements that constrain subject matter effectively a mechanism for banning content?

One of the reasons given for rejection was:

Referencing topics such as: Paedophiles, Rapists, Murderers, Enemies of the state, Journalists, Refugees, Controversial opinions, People’s bedrooms, Police officers, Children’s headsets … is inappropriate and irrelevant to the average consumer’s experience with a VPN.

That doesn't seem to me like the sort of criteria that a rule-enforcement agency should be using for determining whether something should air. (For what it's worth, refusing to air this in the US would absolutely be considered a freedom of speech issue.)