Ad description
An in-game ad for the film "The Purge", which appeared in the game app "Real Football 2013", included various scenes of violence. At one point a group of people carrying weapons approached a house, and a man's voice said, "Anybody tries to come in, you blast them." Towards the end of the ad, the man told a woman "Everything is gonna be OK." She replied tearfully, "Nothing is going to be OK."
Issue
The complainant challenged whether the ad was irresponsible, because it appeared on an app that might be played by children.
Response
Universal Pictures International UK & Eire Ltd (Universal Pictures) acknowledged that the ad contained some moderate violence and alarm, but said they had taken reasonable measures to ensure that it would be targeted to an audience aged 15 and over, who would not find the content unduly shocking or distressing. They said it had been cleared for TV broadcast with a post-9 pm restriction. Based on both that and the film's "15" certificate, they had assigned the ad a "15+" designation and had asked their media agency to target online audiences of 15- to 24-year-olds. They did not have visibility of the individual sites on which the ad was placed.
Universal Pictures noted that the complainant's son had seen the ad at around 9 pm whilst playing the game "Real Football 2013". They acknowledged that that game carried ratings of "4+" and "Low Maturity" on the app stores from which it could be downloaded, and said the "4+" rating was described as signifying that the app contained "no objectionable material". They did not, however, believe that "Real Football 2013" was aimed primarily at, or would appeal to, children, because alongside controlling players on the football field, gameplay involved strategic activities such as signing stadium sponsors, hiring doctors and investing in auxiliary facilities. They further stated that audience composition data from Gameloft (UK) Ltd (Gameloft), the owners of the game, indicated that 87% of users of their games were aged 18 or over, and they understood that the "Real Football 2013" audience was likely to be older in general than that of other games that Gameloft produced. They considered that the game in which the ad had appeared was not primarily targeted at children, had limited appeal to children and had a very low audience share of children, and that the serving of the ad had therefore not been irresponsible.
Gameloft, as the owners of the game "Real Football 2013", had not received any complaints about the ad. They said the ad network used by Universal Pictures had considered the first copy of the ad supplied to them to be too graphic and so had secured the revised version, which was the only copy to have run in "Real Football 2013". They understood that the ad had been certified as suitable for those aged 15 and over.
Gameloft stated that over 82% of "Real Football 2013" users were aged 18 and over. Those figures were derived from Facebook demographics, which they said were very accurate, but only covered users connecting games to their Facebook accounts. This could be slightly skewed if parents registered their accounts and the children used the game. They explained that the ad campaign had also been time-targeted, to ensure the ad would only be served to users of the game between the times of 8 pm and 6 am. They said they had subsequently amended that targeting to begin at 9 pm instead of 8 pm.
Assessment
Not upheld
The ASA considered that the themes of violence and fear contained in the ad were likely to cause distress to young and early teenage children, and that care was therefore needed to ensure responsible targeting. We understood that the same ad had received a post-9 pm restriction when it was cleared for broadcast on TV, and that Universal Pictures had asked their media agency to target those aged 15- to 24-years when placing the ad. We were satisfied that the content of the ad would be suitable for audiences aged 15 and over, and considered that Universal Pictures should have taken steps to ensure that the ad was targeted as far as reasonably possible to that age group.
The complainant reported the ad having been served to their seven-year-old son at around 9 pm, whilst he was playing the game "Real Football 2013". Whilst we noted Universal Pictures' views on the content of "Real Football 2013", and acknowledged that the game was not explicitly targeted at children, we considered that the type of strategic gameplay described was likely to appeal to some children, and particularly teenagers interested in football. We also noted that the figures provided by Gameloft, which indicated a high proportion of users aged 18+, were based only on those users who connected the game to their Facebook accounts and relied on accurate self-reporting of age to that site. We therefore considered that the audience composition data provided for "Real Football 2013", whilst it suggested that the proportion of users aged under 15 was likely to be relatively low, was not in itself sufficient to demonstrate responsible targeting of the ad.
We understood, however, that the ad had been served on a time-targeted basis, meaning that it would not be shown to users before 8 pm or after 6 am. Gameloft had subsequently extended the restriction to begin at 9 pm. We considered that showing the ad only after 9 pm was likely to successfully minimise the risk of children aged under 15 seeing it, and that the 9 pm to 6 am time-targeting was therefore sufficient to ensure responsible delivery of the ad. Although we welcomed Gameloft's subsequent decision to ensure the ad was not shown earlier than 9 pm, because the complaint related to a particular instance of the ad having been shown at 9 pm, we concluded that it had not on that occasion been inappropriately targeted and was not irresponsible.
We investigated the ad under CAP Code (Edition 12) rules 1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society. (Responsible advertising) and 4.2 4.2 Marketing communications must not cause fear or distress without justifiable reason; if it can be justified, the fear or distress should not be excessive. Marketers must not use a shocking claim or image merely to attract attention. (Harm and offence), but did not find it in breach.
Action
No further action necessary.
