Summary of Council discussion:
Two issues were investigated, both of which were Upheld.
Two paid-for Google search ads for the online casino 32Red, seen 25 April 2019, which were displayed when the search term “jack and the beanstalk” was used:
a. The first ad stated “Jack and the Beanstalk 32Red.com Get a 150% Bonus up to £150. First Deposit Bonus & My Red Rewards Daily Offers. Join 32Red Casino today & get £15 free for every £10 deposited up to £150. 24/7 Support”.
b. The second ad stated “Jack and the Beanstalk Get a 150% Bonus up to £150 32Red.com 32Red.com – First Deposit Bonus & My Red Rewards Daily Offers. Join 32Red Casino today & get £15 free for every £10 deposited up to £150. 24/7 Support. Award Winning Casino. Fast Payments. Types: 550+ Online Slots, Progressive Jackpots, Table Games, Live Casino”.
The ASA challenged whether the ads were:
1. Likely to be of particular appeal to children; and
2. Directed at those aged below 18 years of age through the selection of media or context in which they appeared.
1. & 2. 32Red Ltd confirmed that the ads were served as part of a group of ads which were targeted to Google users who used search terms which corresponded with the names of 32Red games, such as “Jack and the Beanstalk”. They said they classified the Jack and the Beanstalk game as a high risk game, which meant that visitors to their website would not be able to see the game listed unless they had been age-verified. However, in this instance the Jack and the Beanstalk game had been included on their website’s list of slot games in error.
They said they removed the ads as soon they were brought to their attention and also checked that other high risk games also were not being actively advertised. They had put in place steps to ensure that any such high risk titles did not appear in keyword lists for ad targeting in future.
1. & 2. Upheld
The ASA noted that the first page of organic search results for the term “jack and the beanstalk” all related to the classic children’s fairy tale of that name. We acknowledged that the ads’ only reference to Jack and the Beanstalk were in the headings in a plain font and that they did not, for example, include any child-friendly imagery. However, we considered that because it was a highly popular classic children’s fairy tale, the inclusion of a reference to Jack and the Beanstalk meant that the ads were likely to be of particular appeal to children. The ads were served to those who entered “jack and the beanstalk” into the search engine. Because it was a highly popular classic children’s fairy tale, we considered that there was a strong possibility that this search term would be input by children, or adults who were accompanied by a child. We therefore considered that, by targeting ads to search engine users who used that term, 32Red had not specifically and carefully targeted the ad only at those aged 18 or over, and had therefore directed gambling ads to those aged under 18 years of age.
We welcomed 32Red’s action in swiftly removing the ads, but concluded they had breached the Code. On that point, ads (a) and (b) breached CAP Code (Edition 12) rules 16.1, 16.3, 16.3.12 and 16.3.13 (Gambling).
The ads must not appear again in the form complained of. We told 32Red Ltd to ensure their gambling ads did not have particular appeal to those aged under 18 years of age and were not directed at those aged below 18 years of age through the selection of media or context in which they appeared.