ASA Adjudication on Tombola (Alderney) Ltd

Ad

Two TV ads for online bingo: Tombola.co.uk.

a. The first ad showed "Tombola world" which was populated by an assortment of fairground attractions, including a ferris wheel, a big top and a rollercoaster. Animated, brightly coloured bingo balls were shown on each of the different rides and bouncing around the fairground. On-screen text at the start of the ad stated “18+. Terms apply. £10 deposit required. gambleaware.co.uk”. The voice-over said "Every day, thousands of people join in the fun at Tombola.co.uk. With over 35 chat rooms to choose from, you can join the ride, make new friends and play your favourite bingo games. Plus join now for more chances to WIN with up to £25 Money Match!". The voice-over continued "tombola.co.uk where the fun goes on and on". The claim was repeated as on-screen text.

b. The second ad showed the same fairground scene with the brightly coloured, animated bingo balls. It also featured a hot air balloon and a 'battleship'. On-screen text at the start of the ad stated “18+. Terms apply. £10 deposit required. gambleaware.co.uk”. The voice-over said "With loads of great prizes to be won, thousands of people are joining in the fun at tombola.co.uk. We've got exclusive games you won't find anywhere else. Play longer for less with Bingo-lite from just 2p a ticket. See if you can sink the fleet with Battleships. Why not try your hand with Cinco? Or stick to your favourite bingo games. Plus join now for more chances to WIN with up to £25 Money Match!". The voice-over continued "tombola.co.uk where the fun goes on and on". The claim was repeated as on-screen text.

Issue

1. One viewer challenged whether ad (a) was likely to be of particular appeal to children or young persons.

2. The ASA challenged whether ad (b) was likely to be of particular appeal to children or young persons.

BCAP TV Code

Response

1. & 2. Tombola said their intention was to create ads that acted as a metaphor for the online bingo experience and which would attract new bingo players but not attract a younger audience.  They said they took into account other examples of animated ads that targeted adults and acted on the advice given by Clearcast to ensure that the ads appealed to those over 18 years of age.  Tombola said they had no interest in targeting or appealing to under 18s; the ads were scheduled to target an adult audience and they took rigorous steps to ensure that under 18s were unable to play on the Tombola site.  They said the numerous references to bingo throughout the ads and the reference to 18+ in the on-screen text clearly positioned these as ads for an adult product aimed at an adult audience.  They added that a large part of the bingo playing experience was the community aspect of the game and therefore the reference to chat rooms in ad (a) was not only relevant but recognisable as a positive feature to the bingo playing public.  When reviewing music choices for their ads, Tombola said they steered clear of current or recent chart music and deliberately chose a track from 1962 as a reflection of the brand.  They said the ads had been widely broadcast between August and November 2008 and they had received no complaints.

Clearcast said they were involved in approval of the animation from the early stages of the campaign and took the view that the ads were no more likely to appeal to children just because they were animated. They believed the dark background of the ads rendered them more adult in style and pointed out that the animated balls were not particularly cute.  Clearcast also believed the fairground setting had a more general, than youth, appeal.  They noted hot air balloons featured and a reference was made to the game 'Battleship' but pointed out that neither could be described as having youth appeal. One company offering hot air balloon rides required passengers to be aged over 18 years and the game 'Battleship' pre-dated the First World War and was typically played by adults.  Clearcast added that the music featured in the ads dated from 1962 and was unlikely to appeal to children.

Assessment

1. Upheld

The ASA noted the theme of ad (a), "Tombola World", was based on a fairground and included a big top, an ice-skating rink, a helter-skelter, a rollercoaster and fireworks. These were all things likely to be of particular appeal to children, those aged 15 and under, and young persons, those aged 16 or 17.

We noted that the brightly coloured and animated bingo balls had happy, smiling faces and were shown bouncing around the fairground and playing on the rides.  We considered that, in some scenes, the bingo balls looked like brightly coloured sweets.  In one scene, a smiling bingo ball, wearing a hard hat, was fired from a cannon and landed in the ice-skating rink, knocking over other bingo balls to the sound of skittles being bowled over.  We considered all these elements would be likely to be of particular appeal to children.

We noted there was also a reference to chat rooms where you could "make new friends" which we considered would have particular appeal to older children and young persons.

Finally, although we noted the song dated from 1962, we considered that the catchy, energetic and repetitive nature of the lyrics "Tombola, tom, tom, tombola", which were repeated throughout the ad, would be of particular appeal to children.  Taking all the elements into consideration, we concluded that ad (a) would be likely to be of particular appeal to children and young persons.

Ad (a) breached CAP (Broadcast) TV Advertising Standards Code rule 11.10.2(b) (Rules for gambling advertisements).

2. Upheld

We noted ad (b) used the same theme, "Tombola World", as ad (a) but featured a big top, a rollercoaster, a hot air balloon and a battleship.

While we noted it did not focus on the faces or features of the balls in the same way as ad (a), we considered that they still resembled brightly coloured sweets.  We also noted the lyrics of the song, 'Tombola', were only heard towards the middle and end of the ad but considered that the tune was still catchy and energetic.  We considered that those elements were still likely to be of particular appeal to children.  We also considered that the reference to one of the games, "... sink the fleet with Battleships", could have particular appeal to some children or young persons.

We noted the reference to playing small, obtainable amounts of money, "2p a ticket" and while we did not object to the reference per se, we considered that it was problematic in an ad which featured elements likely to be of particular appeal to children or young persons.  On balance, we concluded that ad (b) was likely to be of particular appeal to children or young persons.

Ad (b) breached CAP (Broadcast) TV Advertising Standards Code rule 11.10.2(b) (Rules for gambling advertisements).

Action

Ads (a) and (b) must not be shown again in their current form.

Adjudication of the ASA Council (Broadcast)