Ad description

An in-app ad for Whispers – Romance n Choices, an online drama story game, seen on 29 July 2022, in the app Animal Shelter Simulator. The ad showed an animated sequence involving a woman wearing a black dress and high heels sitting on a dentist’s chair, with a male dentist stood behind her. A speech bubble appeared and the woman said, “I’m terrified of ….” and she was heard whimpering. The ad then focused on the dentist’s face who was shown considering his next action. Two boxes appeared beside him, offering choices for the game player. One box said, “Calm her down” and the other said, “Start treatment”. The first box was selected and the dentist was shown putting his finger in the woman’s mouth. The woman was heard making a sucking noise and white liquid appeared at the side of her mouth. The dentist whose cheeks were shown to go red said, “Whoah” and “Yeah”. Two boxes appeared offering choices for the player. The first box said, “Keep at it” and the other said, “Start treatment”.


The complainant, who believed the ad objectified and sexualised the woman, challenged whether the ad was offensive.


Gamehaus Network Technology Co Ltd did not respond to the ASA's enquiries.

Digital Melody, who made Animal Shelter Simulator, said ads in their games were displayed using external ad systems and they had no direct influence on the ads shown. However, they passed information regarding the age of users to the systems and would not allow controversial categories of ads to be shown. They had not received any complaints about the ad.

AppLovin Corporation, who ran the network that served the ad, confirmed that the ad had breached their terms of use agreement. They had already been made aware of the ad and acted quickly to ensure that the ad, and similar ads, did not appear on the “Animal Shelter Simulator” or other mobile apps served by their platform. They had also warned the advertiser that future similar ads would result in the termination of their ad campaigns and an account ban.


The ASA was concerned by Gamehaus Network Technology Co Ltd’s lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rules  1.7 1.7 Any unreasonable delay in responding to the ASA's enquiries will normally be considered a breach of the Code.  (Unreasonable delay). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.


The ASA noted the ad was animated and featured a scene in which a woman attended a dental surgery staffed by a male dentist. The woman was dressed in underwear and high heels, which was incongruous given the setting. Further to that the ad portrayed the experience of the man’s finger being sucked, shown by the dentist’s cheeks going red and his verbal exclamations of “Whoah” and “Yeah”, as a sexual one. Therefore, the combination of the woman’s presentation, in the specific context of the ad, and the dentist’s actions meant the woman was depicted in a sexual way.

In addition, a speech bubble for the woman expressed her fear and she was heard to be upset at the outset. She then appeared visibly uncomfortable with the man’s finger in her mouth. The woman therefore was exclusively shown as passive, without agency and subject to a sexual act with no clear sign of agreement.

Because the ad depicted a woman in sexual way, subject to a sexual act apparently without consent, it objectified her and was likely to cause serious offence, we therefore concluded that it breached the Code.

The ad breached CAP Code (Edition 12) rule  4.1 4.1 Marketing communications must not contain anything that is likely to cause serious or widespread offence. Particular care must be taken to avoid causing offence on the grounds of: age; disability; gender; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; and sexual orientation. Compliance will be judged on the context, medium, audience, product and prevailing standards.

Marketing communications may be distasteful without necessarily breaching this rule. Marketers are urged to consider public sensitivities before using potentially offensive material.
The fact that a product is offensive to some people is not grounds for finding a marketing communication in breach of the Code. 
 (Harm and offence).


The ad must not appear again in its current form. We told Gamehaus Network Technology Co Ltd to ensure future ads did not cause serious or widespread offence, including by objectifying women. We referred the matter to the CAP compliance team.

CAP Code (Edition 12)

1.7     4.1    

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