Ad description

A banner ad for a solitaire game, seen on the lock screen of a phone that was running the AVG Cleaner app in October 2016, featured three women in bikinis posing in a suggestive manner.


The complainant challenged whether the ad had been inappropriately and irresponsibly placed, as it had appeared untargeted on a device used by children.


Queens Solitaire Games, whose product was promoted by the ad, did not respond to the ASA’s enquiries.

AVG Technologies UK Ltd, in whose app the ad appeared, stated that, in order to prevent improper ads from appearing in their apps, their ad providers automatically blocked ads referencing several categories, including sex and sexuality. However, on rare occasions, inappropriate ads could bypass this screening. They said that this usually happened when the advertiser categorised or named the ad in a misleading manner. When made aware of such an incident, they immediately blocked the ad manually on all ad networks and sent it to their ad providers for investigation.



The ASA was concerned by Queens Solitaire Games’ 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 response to our enquiries and told them to do so in future.

We considered that the sexualised nature of the images meant that they were not appropriate to be seen by children. We noted that the ad appeared in an anti-virus app that would be ready-installed on many phones and would not have been selected due to any particular interests on the part of the individual consumer using it. We also noted that the ad had appeared on the lock-screen, meaning that it could have been seen even when the phone wasn’t in use. Given the very broad and general audience for the app, which would have included children, we considered that steps should have been taken to ensure that ads appearing within it were appropriate for that audience.  We considered that Queens Solitaire Games held primary responsibility for ensuring that the content and placement of the ad complied with the CAP Code, and that they should have correctly flagged the content of the ad to the publisher. However, we considered that AVG Technologies was also responsible for ensuring that ads in their apps were targeted appropriately. We acknowledged that they had systems in place to prevent ads with sexual content from appearing in their apps, and welcomed their prompt action to remove inappropriate ads. However, we were concerned that their procedures had not been adequate to prevent the ad from appearing in an inappropriate medium in this case. We therefore concluded that the ad had been placed irresponsibly.

The ad breached CAP Code (Edition 12) rule  1.3 1.3 Marketing communications must be prepared with a sense of responsibility to consumers and to society.  (Social responsibility).


The ad must not appear again in an untargeted medium. We told Queens Solitaire Games to ensure that ads were appropriately targeted. We referred Queens Solitaire Games to CAP’s Compliance team.

CAP Code (Edition 12)


More on