Ad description
A website, www.slotser.com, promoted an online casino.
The home page included a cartoon-like image of a meerkat at the top of the page. Below that were a number of games, including "Piggy Payout", "Fluffy Favourites", "Legend of the Fairies" and "Farmania", which were also accompanied by cartoon-like images.
A page entitled "Promotions" included various cartoon-like images, including a meerkat and a fairy.
Issue
The ASA challenged whether the ad was likely to be of particular appeal to children or young persons and was therefore irresponsible.
Response
Ever Adventure IOM Ltd said their brand offered both real money and fun games, designed to appeal to their target audience of female players over 30 years of age.
They said they did not target anyone under 18, that their social media advertising was age-gated, and that their website would be so outranked in a search as to make it irrelevant if someone was searching for one of the elements which might have appeal to children such as "meerkat" or "fairies". They said to reach their website one would either need to know the URL or be directed there by an ad external to the site. They said there was no realistic prospect of the URL being guessed and there was no advertising carried out or caused by them which would be likely to draw the site to the attention of under-18s. They said their view was that the characters in the ad were of general appeal, not particular appeal to under-18s.
Assessment
Upheld
The CAP Code stated that gambling ads must not be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture. Gambling ads could not therefore appeal more strongly to under-18s than they did to over-18s. We considered that the use of cartoons or cartoon-like imagery had the potential to appeal to under-18s, and it was therefore important that they were used carefully in ads for gambling products.
We considered that a number of the games had names that were likely to appeal to under-18s, such as "Farmania", "Fluffy Favourites", "Legend of the Fairies", "Kitcats", "Piggy Payout" and "Candilicious". Those games were also presented with colourful and exaggerated cartoon-like imagery, which was likely to strengthen that appeal. We considered that the presentation of those games, along with the image of the meerkat on the home page and a fairy with confetti in the background on the "promotions" page, meant that the overall theme of the website was child-like.
For those reasons, we considered that the ad was likely to be of particular appeal to under-18s, and therefore concluded that the ad was irresponsible and breached the Code.
The ad breached CAP Code (Edition 12) rules 16.1 16.1 Marketing communications for gambling must be socially responsible, with particular regard to the need to protect children, young persons and other vulnerable persons from being harmed or exploited. and 16.3.12 16.3.12 be likely to be of particular appeal to children or young persons, especially by reflecting or being associated with youth culture (Gambling).
Action
The ad must not appear again in its current form. We told Ever Adventure IOM Ltd to ensure in future that their ads for gambling products did not appeal particularly to children or young persons.
