Ad description
Three banner ads for Play’n GO, a provider of casino gaming content, seen in April 2025:
a. The first ad, seen beside the email inboxes of two children, featured a cartoon Easter bunny in a superhero outfit. The rabbit held a silver egg in one hand and a basket of eggs in the other. Text stated, “MYSTERY EGG SURPRISE”, “Easter Eggs” and “EASTER EGGSPEDITION”. The ad also featured the Play’n GO logo and an 18+ symbol.
b. The second ad, seen beside an email inbox, featured a cartoon robot DJ with a purple screen for a face, displaying white pixels. One arm was raised and the other hovered over a turntable. Text stated, “SPINNING RECORDS INTO THE BEAT”. The ad also featured the Play’n GO, Gambling Commission and BeGambleAware.org logos, and an 18+ symbol.
c. The third ad, seen beside a child’s email inbox, featured three anime-style, cartoon princesses. Text stated, “Moon Princess Origins”. The ad also featured the Play’n GO, Gambling Commission and BeGambleAware.org logos, and an 18+ symbol.
Issue
Two complainants, who had seen the ads beside their own or their child’s email inbox, challenged whether the ads featured content likely to be of strong appeal to those aged under 18 years of age.
Response
Play’n GO Malta Ltd said that the three ads were for three separate slot games: the Moon Princess series; Spinnin’ Records into the Beat; and a game with an Easter theme. Each featured their trademarked characters and were designed to appeal to players of the legal age to gamble in their own jurisdiction. They believed the images were popular with adults and accepted that they could be appealing to children. However, they said game play required an adult mindset and could not therefore be attractive to children.
Play’n GO said their advertising was run through a programmatic advertising platform, Adroll. It did not carry age restrictions. However, Play’n GO told us that during the bidding process for advertising space, their ads were identified as related to gambling to ensure they were only served to websites that had opted to include gambling ads. Play’n GO said all their ads carried 18+ labelling, responsible gambling messaging, and the logos of the UK Gambling Commission and BeGambleAware.
They explained that users who had visited their website could be retargeted with their ads when visiting other websites. However, a cookie-consent banner on their website meant tracking or retargeting activities were only undertaken with a user’s consent.
Although Play’n GO was not a gambling operator, nor did it provide direct gambling opportunities via its website, they required visitors to confirm they were of legal gambling age in their own jurisdiction before accessing the website. Play’n GO saw this as an additional safeguard to help ensure that re-targeted ads were subsequently directed towards individuals aged 18 and over in the UK.
Play’n GO believed there was a possibility that an adult user could previously have visited their website and provided consent, and then a child could see the retargeted ad alongside a free, web-based email account because they were using the same device at the same IP address. Play’n GO described that as an acknowledged limitation within programmatic advertising.
They therefore believed there had been appropriate audience targeting but acknowledged that the ads had been inadvertently served alongside a child’s mailbox due to factors beyond their direct control.
Adroll, the programmatic advertising platform, said that while Play‘n GO delivered its games to regulated casino operators, their website was exclusively for entertainment. It offered free-to-play games with no money changing hands. Each of its webpages had small print in its footer making that clear.
Nonetheless, AdRoll stated that Play‘n GO took measures to deter players under the age of 18 through the age-gate on the website. Website visitors were required to confirm they were of legal gambling age in the jurisdiction where they resided.
Adroll said that Play‘n GO did not serve the ads with the intention of reaching individuals under the age of 18. They believed the ads were not directed at, or likely to appeal to, those under 18, and had been either a “lookalike” prospecting or retargeting campaign. A lookalike prospecting campaign was aimed at individuals whose browsing behaviour resembled Play‘n GO’s legal audience. A retargeting campaign was enabled by a visitor to the website having previously stated they were of legal gambling age in their jurisdiction.
Assessment
Upheld
The ASA understood that, while consumers could not place bets on their website, Play’n GO provided gambling software to the industry and were licensed by the Gambling Commission. Section 16 of the CAP Code (Gambling) covered ads by gambling operators licensed in Great Britain that were likely to have the effect of promoting gambling.
The Code stated that gambling ads must not be likely to be of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. They must not include a person or character whose example was likely to be followed by those aged under 18 years or who had strong appeal to those aged under 18.
The CAP guidance on “Gambling and lotteries: Protecting under-18s” (The Guidance) stated that child-oriented cartoon content or animated styles, characters like princesses, superheroes or robots (especially those with exaggerated features), and cultural characters such as the Easter Bunny, were high risk of being of strong appeal to children and therefore should be avoided in ads for gambling products.
Ad (a) featured a cartoon image of the Easter Bunny holding a basket of eggs, suggesting an Easter egg hunt, which was an activity enjoyed by children. It was also dressed as a superhero. We considered that because of those elements, the image was likely to strongly appeal to under-18s.
Ad (b) featured a cartoon image of a robot who was seen DJ-ing, an activity likely to appeal to young persons. We considered that imagery was likely to strongly appeal to under-18s.
Ad (c) featured cartoon princesses who had colourful costumes and anime styling, including large eyes. We considered that because of those elements, the image was likely to strongly appeal to under-18s.
We considered therefore the ads were likely to be of strong appeal to under-18s.
We considered that it would have been acceptable for the ads to appear in a medium where under-18s could, for all intents and purposes, be entirely excluded from the audience. That would apply in circumstances where those who saw the ads had been robustly age-verified as being 18 or older, such as through marketing lists that had been validated by payment data or credit checking.
We considered that the targeting measures used by Adroll, which relied on self-declaration of age of users entering the Play’n GO website and retargeting based on that data, as well as prospecting targeting using browsing behaviours, were not sufficiently robust to ensure under-18s were entirely excluded from the audience. We also understood that two of the ads had been served to space alongside the email inboxes of children.
We therefore considered that Play’n GO Malta had not excluded under-18s from the audience with the highest level of accuracy required for gambling ads, the content of which was likely to appeal strongly to that age group.
For those reasons, we concluded that the ads were irresponsible and breached the Code.
The ads breached CAP Code (Edition 12) rules 16.1 and 16.3.12 (Gambling).
Action
The ads must not appear again in their current form. We told Play’n GO Malta Ltd not to include imagery that was likely to have strong appeal to those under 18 years of age in their ads in future.
