Ad description
A post on Buzz Bingo Grimsby’s Facebook page, seen on 12 April 2025, included a cartoon figure of a woman in a box labelled “[NAME] ACTION FIGURE”. The box also contained a bingo dabber, bingo cards, and a numbered ball. A caption on the post stated, “For a limited time only Buzz Bingo Action Figures [crying laughing face emoji] Only available at Buzz Bingo Grimsby! [eyes emoji] T&Cs Apply […] Player Together [sic], Safely […] Over 18s Only” and included a link to gambleaware.org.
Issue
Two complainants challenged whether the ad included imagery which was likely to be of strong appeal to those under 18 years of age and therefore breached the Code.
Response
Buzz Group Ltd stated that they did not believe the ad was of strong appeal to those under 18 years of age. They explained that the individual featured in the ad was the General Manager of Buzz Bingo Grimsby; an employee with no celebrity or influencer status who was not widely recognisable. They considered that the style and presentation of the image was neutral in tone. The cartoon figure appeared in plain office clothing and was not smiling. The items accompanying her were intrinsically associated with the game of bingo and did not incorporate design elements that might typically appeal to children, such as bright, cartoon like graphics or licensed characters. The post was aimed at a local audience using a staff member in a humorous format for community engagement.
Buzz Group stated that whilst the post was associated with a popular trend on social media, they believed they had incorporated it into their ad responsibly. They stated the social media trend itself did not inherently target or appeal to children and was used widely across different demographics and platforms.
They highlighted that the post was seen on the Buzz Bingo Grimsby Facebook page, which utilised Facebook’s platform controls to restrict access to users who had self-verified as 18 and over. The post was only visible to users who were logged in to their Facebook account and were already following the Buzz Bingo Grimsby Facebook page. They understood that the Industry Group for Responsible Gambling (IGRG) considered Facebook’s platform controls sufficient for compliance with gambling marketing requirements.
Assessment
Not upheld
The CAP Code stated that gambling ads must not be likely to be of strong appeal to children or young persons. CAP guidance on “Gambling and lotteries advertising: protecting under-18s” stated that advertiser-created characters that were colourful or had exaggerated features were more likely to be of strong appeal to under-18s, and that characters with similarities to soft toys should be avoided. Characters that were more obviously life-like or adult in style and appearance were more likely to be acceptable.
The ASA understood that the format of the ad was based on a popular online trend in which people used artificial intelligence to generate images of themselves as dolls or action figures. The figure in the ad was labelled “[NAME] ACTION FIGURE”, and we considered that action figures or dolls were likely to appeal to some under-18s. However, we considered that despite the image being computer-generated, the overall style of the ad was realistic rather than cartoon-like. The figure depicted was an adult who did not have exaggerated features, was wearing a simple shirt, and was not a recognisable or well-known character. The colours were muted rather than bright and were not reminiscent of dolls or action figures that were typically marketed towards children. We considered that the “action figure” depicted was unlikely to be viewed by children as an appealing toy to play with. The items which accompanied the figure in the box had a similar realistic and muted aesthetic and were associated with the game of bingo, which we considered was not an activity that was likely to appeal to most under-18s. We therefore concluded that the ad was not likely to be of strong appeal to those under 18 years of age.
We investigated the ad under CAP Code (Edition 12) rules 16.1 and 16.3.12 (Gambling), but did not find it in breach.
Action
No further action necessary.
