Ad description
A banner ad for Hollywood bets seen on www.the-VFL.com, a website for Virtual Football League, an EAFC (EA SPORTS FC) e-sport statistic website, seen on 10 April 2025.
The ad contained the Hollywood bets logo, and text that stated, “UP TO £30 BACK AS FREE BETS + 20 FREE SPINS” and featured a “SIGN HERE” button. The ad also included an image of people dressed in sports clothing, and featured a footballer, a tennis player, a golfer, an American footballer and a jockey riding a horse.
Issue
The complainant, who was aged under-18 and had registered their date of birth to create a profile on the site, challenged whether the ad was appropriately targeted.
Response
Hollywoodbets International UK Ltd t/a Hollywoodbets said their ad was placed on the-VFL.com by their affiliate partner Playhill Ltd t/a Clever Advertising.
Clever Advertising explained that the-VFL.com hosted the Virtual Football League, where players participated in organised competitive matches, modelled after real football leagues, and that close alignment with real-world football and competitive play positioned the platform closer to traditional sports where, they said, consumers were familiar with seeing gambling ads.
They also said VFL’s gameplay format, (The Pro Clubs 11v11 gameplay option on the video game EA Sports FC) required team coordination, scheduling and commitment, which they believed was more typical of older and more mature players, often over-18. In light of the nature of the content of the website, and the gameplay functions it promoted, they believed that the ad had been appropriately placed to appear on the-VFL.com,Clever Advertising further said they had a dedicated team which manually reviewed websites. They matched content to appropriate audiences based on interest, age and location. They served ads on EA Sports FC related websites, based on the latest demographics for the video game, which indicated that children accounted for less than 25% of the players. They also worked closely with publishers to block or target content, based on identified criteria. They said that the ad in question was approved for display on the VFL homepage, meaning it should have been visible to visitors before they logged in, but not after.
The-VLF.com said they did not select the ads that appeared on their website, and once they were made aware of the complaint, they contacted their partners to have the ad removed.
Assessment
Upheld
The CAP Code required that marketing communications for gambling must not be directed at those aged younger than 18 years through the selection of media or context in which they appeared.
The ASA noted that the complainant, aged 16, had created an account for the-VFL.com, for which they had registered their date of birth. We acknowledged that Clever Advertising maintained that the ad was approved from display prior to user log in, but understood the complainant was logged in when the ad was served to them. Because the ad was served to a user of the website who was known to be under 18 by their registered login details, we considered that the ad was directed at those below the age of 18 through the selection of the media in which it appeared and therefore breached the Code.
The ad breached CAP Code (Edition 12) rules 16.1, 16.3 and 16.3.13 (Gambling).
Action
The ad must not be used again without further, specific targeting to minimise the likelihood of under-18s being exposed to it. We told Hollywoodbets International UK Ltd t/a Hollywoodbets to ensure that their ads were appropriately targeted and not targeted at under-18s.
