Ad description
A paid-for Reddit ad for gaming website, MrQ.com, seen on 29 June, featured an image showing three cartoon Spiderman figures pointing at one another with a text box stating “MrQ” over their heads.
Issue
The complainants challenged whether the ad was likely to have particular appeal to children and therefore breached the Code.
Response
Lindar Media Ltd t/a MrQ.com said that the ad had been placed by an agency which had followed audience targeting to ensure that it targeted people who were already interested in gambling and, because of that, they believed it was unlikely to be seen by children or young people. They said that, although they had approved the copy, they had not seen the images before the ad was placed. Their marketing terms and conditions stated that agents should not use images of famous individuals or brands and that they had terminated the relationship with the agency because the Spiderman imagery was used without their approval. They acknowledged that the images in the ad might appeal to children.
Reddit said they had not received any direct complaints about the ad. They said that, in response to the complaint, they had amended their policy to exclude the use of cartoon characters in paid-for gambling advertising.
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 must not, therefore, have content that would appeal more strongly to under-18s than it would to over-18s, regardless of whether they were appropriately targeted.
The ASA understood the ad was making reference to a popular meme. Nevertheless, we considered that a cartoon depiction of Spiderman, a popular comic book character, was likely to appeal more strongly to under-18s than it would to over-18s. We therefore considered that the ad, which featured three cartoon depictions of Spiderman, was likely to have particular appeal to children and concluded that it 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 the form complained of. We told Lindar Media Ltd to ensure their gambling ads did not have particular appeal to those aged under 18.
