Ad description

Two in-app ads seen in the “Color Hole 3D” app on 29 March 2021:

a. The first ad included text which stated “Gumtree for Sex” and a Union flag in a heart shape. The ad featured the image of a woman who had pulled her top to expose her breast.

b. The second ad included text which stated “Gumtree for Sex” and a Union flag in a heart shape. The ad featured the image of a woman sat on the floor with her trousers pulled down to expose her genitalia.


The complainant, whose 11-year-old daughter saw the ads while playing on the app, challenged whether the ads were offensive and inappropriately targeted.


Person(s) unknown t/a Gumtree for Sex did not respond to the ASA’s enquiries.

Good Job Games Bilişim Yazılım ve Pazarlama Anonim Şirketi, the app developer of Color Hole 3D, said that the ad breached their own internal policies and was not endorsed by them for display on its app. They said that ads served on their app were provided by third-party advertising platforms, using ad-exchanges (which facilitated the buying and selling of ads).

Good Job Games said that when they first received notice that the ad had been displayed on its Color Hole 3D app they immediately took steps to instruct all its third-party ad-exchange partners to stop serving the ad. They said that after investigating the issue, they had removed the ad within three hours of first being notified of its appearance.

Good Job Games said that the advertiser had fraudulently used the domain name of a well-known e-commerce site, which allowed them to pass through both their own and the ad-exchange platform’s safety measure without its content being flagged. They said they had taken action to block advertisers to reduce the possibility of similar occurrence in future. They confirmed that to the best of their knowledge, the ad was no longer being shown on its apps since the issue was reported to them.Good Job Games said that in general they had safety measures in place to prevent inappropriate ads from appearing on its apps. They said they only worked with reputable third-party advertising partners and they said they had promptly notified their partners of the ad and requested its removal. They also said they applied a strict blocking of inappropriate ads by using ad review tools. Good Job Games said those tools monitored all ads and employed machine-learning algorithms alongside human review to flag and block fraudulent ads.


We were concerned by Person(s) unknown t/a Gumtree for Sex's lack of response and apparent disregard for the Code, which was a breach of CAP Code (Edition 12) rule 1.7 (Unreasonable delay). We reminded them of their responsibility to provide a substantive response to our enquiries and told them to do so in future.


The ads contained extremely graphic sexual imagery that was likely to cause offence in an untargeted medium. The ads were seen while playing on the app Color Hole 3D, which was a simple puzzle game that we considered was likely to have appeal to a general audience, including to children. We noted the ad was seen by the complainant’s 11-year-old daughter while playing the app. Because we considered the app would have general appeal, we concluded that it was not appropriate for the ads’ content to appear in such a medium.

Because the ads contained extremely graphic sexual imagery and were shown in a medium that would have general appeal, including to children, we considered the ads were likely to cause serious and widespread offence and had been inappropriately targeted.

The ad breached CAP Code (Edition 12) rules 1.3 (Social responsibility) and 4.1 (Harm and offence).


The ads must not appear again in the forms complained of. We told Person(s) unknown t/a Gumtree for Sex to ensure their ads did not cause serious or widespread offence and were not inappropriately targeted. We referred the matter to CAP's Compliance team.

CAP Code (Edition 12)

1.3     4.1    

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